7 replies to this topic

[fractures]

Hi, 

 

I'd appreciate some help to determine if a product we manufacture meets the BRC 3.5.4 definition of outsourced processing in v9. We have been given an explanation from an auditor that is contradictory to my understanding so some clarification would be appreciated.

 

 

Process:

• Raw ingredients arrive at our site 
• Ingredients mixed and treated at our site.
• Ingredients are packed into IBC's (within our scope)
• IBC's sent to another packer. Product is packed into sachets and boxed up into shelf ready packaging, palletised etc
• Finished product is returned to our site for distribution. Product is not subject to further processing steps/modification, just dispatch. 

 

We are not connected to the packer, but have completed due diligence auditing of them. They are BRC accredited. 

 

Thanks in advance, 

[SHQuality]

We are not connected to the packer, but have completed due diligence auditing of them. They are BRC accredited. 

 

Thanks in advance, 

 

Based on the information you provided, it looks like this part of the process is a text book definition of an outsourced process. It's separated at a different location and also by different ownership of the business. I don't see how this could be seen as anything other than an outsourced process.

 

How do you and the auditor disagree?

Edited by SHQuality, 28 February 2023 - 03:26 PM.

[fractures]

They were of the perspective that, because we were not doing anything further to the product, and we cannot make the product at our site, it shouldn't be treated as an outsourced process. As it's not under our scope, 3.5.4 does not apply. We needed to manage it through the supplier assurance programme instead. 

[SHQuality]

Did you read the last two paragraphs of page 34 of the standard and the first two of page 35?

 

This is not related to raw materials that are stored or processed prior to their initial arrival on site. 

It is literally a product you made that gets packed elsewhere, then returned for distribution.

 

My previous employer would consider this an outsourced process too as would several other business and auditors I know.

That said, you've got their BRC and audited them, so I don't see why you can't do both...

[Madam A. D-tor]

Based on the information you provided, it looks like this part of the process is a text book definition of an outsourced process. It's separated at a different location and also by different ownership of the business. I don't see how this could be seen as anything other than an outsourced process.

 

How do you and the auditor disagree?

 

I agree with SHQuality that this is The classical example of outsourced processing in the definition of BRCGS.

[fractures]

Well I thought as much, but had been doubting myself after the audit. Thanks for the confirmation. 

[Bo16]

My understanding is that anything that leaves the plant and goes even to storage and comes back to your plant (they have distance rule I think) is still outside processing.  So even off site storage is an outsourced process.

[Tony-C]

Hi fractures,

 

BRCGS Global Standard for Food Safety Issue 9 BRCGS Guidance offers a nice diagram that explains the situation quite nicely:

 

 BRCGS Food Issue 9 3.5.4 Outsourced Processing.jpg   98.53KB   0 downloads

 

Kind regards,

 

Tony