SQF requirements for Ingredients available for retail purchase
Hello - We are a small SQF certified processor, we occasionally use ingredients such as canned pumpkin, canned chipotle in adobo sauce, etc., which come in packages with labeling that are retail items in restaurant stores.
Are there any auditors or ex auditors out there who have experience with (SQF) requirements for supplier documentation on these items? As a small processor, we have trouble getting GFSI certificates from a Libby's or similar large companies, especially because we are not buying directly from them. We do get certificates every so often, but that is not the norm. We are using a lot of time to try to chase these certificates down, and I'm trying to ensure it's a worthwhile activity for an item that is available to the general public without a COA.
Thank you in advance.
Before I can answer your question I have sone questions.
1. Since you are SQF certified already how do you approve these sources currently and in accordance with your own approved supplier program?
2. In the event of a recall how do you address this?
3. Have you ever directly aporoached the manufacturers of the ingredients to locate a broker for these items that can sell direct to you - many brokers are GFSI certified or non-scheme audited and follow food safety programs thus you'd be able to get audits, certificates, etc from the broker and be on their contact list in the event of their own recall situations.
It is the recall situations or lack of effective ways to complete a recall or be informed of one that can trip up an audit because places like restaurant depot or Gordans Food for instance do not have effective announcement methods in place other than a printed posting on their in store announcement boards.
Thanks for your reply. Answers to questions:
1. Before I joined the company, the company was reaching out to the actual manufacturers and just asking for the certificates over and over until they got lucky and heard back or gave up.
2. To remedy this, I have written into our supplier approval program that items available to the general public are intended for retail use and because of this we do not require COAs. We have third party audit documentation from Chef's Store, which is owned by US Foods who has third-party audits from the corporate office and individual stores, under a GFSI approved food safety program. I'm still working on Restaurant Depot; we do not purchase much from there.
3. I have classified any liquor ingredients as low risk. We buy that retail.
4. I receive & monitor FDA and USDA recall/withdrawal alerts via email for recall alerts, and stay involved in our local Food Industry group, Food NW.
5. For some of these items, we are too small for even a broker. But we utilize brokers as much as possible. They are good at providing the documentation required.
6. I did call Chef's Store after reading your response to get a written document on how we would be informed of a recall. I hadn't thought of that, thank you.
Very though provoking questions!
I've only had success with retail purchased items when we can quantify that it is for R&D purposes. I see a conflict in buying retail items in supplier approval:
2.3.4.2 requires you to setup a supplier approval program and requires you to maintain 7 key points in regards to these suppliers. I don't know how you get agreed specifications, a summary of food safety controls from the supplier, and a manner in which to review supplier performance when you're merely buying off the shelf retail items. The concern would be that your supplier, aka the retailer, can't guarantee the things you buy won't be discontinued (which puts business continuity into question on your end), nor that they won't change vendors and leave you with a product you haven't validated for your process.
2.3.4.3. requires you to verify raw materials with COA's, or sampling and testing. Again, not sure how you get that retail.
Now, 2.3.4.4. would allow you to get raw materials from non-approved suppliers, but only in an emergency situation and would be subject to a receiving inspection or analysis. Showing that you're doing this routinely would be a hit against this code.
I've worked for companies using the "we're a small business and need to do xyz to make things work" and it can get you through audits with an understanding auditor. If I were in your shoes, I'd try to shift as much of your raw material purchases to brokers you can approve as suppliers, where possible. If you get rejected by brokers due to low volume, keep those rejections handy and use them to support your need to buy the items retail as an emergency (your need to continue production but inability to acquire from approved suppliers may qualify under emergency purchases). Make a list of the items you have to buy retail, and send a letter to your certifying body before the audit asking for notice of exemption for supplier approval on those items. That way the CB knows you have a round peg that won't fit their square hold ahead of time, and you'll have had a chance to explain how you justify the risk.