7 replies to this topic

[PackageMarshal]

We are planning on establishing a facility as a contract manufacturer.  Regarding contract manufacturer's the SQF code states the following:

2.3.3.2 The site shall establish a method to determine the food safety risk level of contract manufactured product and shall document the risk. The site shall:

i. Verify compliance with the SQF Food Safety Code: Manufacture of Food Packaging and that all customer requirements are being met at all times.

ii. Ensure changes to contractual agreements are approved by both parties and communicated to relevant personnel.

 

Furthermore, the guidance document from edition 8 stated the following:

Whatever the situation, any contract site used to manufacture, in part or in whole, an SQF certified product MUST fulfill the same requirements as the SQF certified supplier. The responsibility for ensuring that these conditions are met is part of the primary supplier’s SQF System.

 

As I read these things, my perspective is that the contract manufacturer must be specifically compliant with the SQF code.  However, the contract manufacturer has stated the following in argument against necessarily being compliant with SQF:

"SQF and FSSC 2000 are both part of the GFSI benchmark, meaning both schemes are harmonized in food safety standards and you should expect that we have similar compliance activities in place."

 

I know that they are both GFSI certifications and may be fairly similar, but they do have differences in standards.  Am I correct in requiring the contract manufacturer to be specifically compliant with the SQF code, or would are they correct that a GFSI certification is sufficient?

[Scotty_SQF]

I would consider GFSI certification to be sufficient.  I interpret the code as it is your responsibility to show that you feel the contract manufacturer is in compliance, i.e. your requirements to use them as a contract manufacturer and to maintain food safety as it aligns with your site.  In the past when I worked for a company that we had to use contract manufacturing, we had a similar situation set up as we would Supplier Approval.  We required certain documents, we visited the site and sometimes we audited them (if they were not GRSI certified).  We also performed a risk assessment on the sites we used.  All this was used as evidence to show that we approved the contract manufacturer and what the elements were for approval.

[SQFconsultant]

Your supplier is correct and their FSSC cert is eqvl for this purpose.

[jfrey123]

Posting a link to the 9.0 Contract Manufacturers guidance document, as it is more current than OP's info:  

Contract-Manufacturers-Guidance-Document.pdf (sqfi.com)

 

It specifically states, "Contract manufacturers must follow the requirements outlined in the SQF Food Safety Code," not GFSI in general.

 

Are they producing products under your name/label?  If so, I think because these items are outlined in your SQF scope, it may not be sufficient to default to their other GFSI procedures.  There are small nuances between all of the GFSI schemes, a little bit of saber rattling as they are competing with each other for business, and SQF has some small differences between FSSC 22000.

 

One example:  FSSC 22000 v5 states that a plant's Food Fraud Mitigation Plan shall be reviewed "regularly":

Guidance_Food-Fraud-Mitigation_Version-5_19.0528.pdf (fssc.com)Guidance_Food-Fraud-Mitigation_Version-5_19.0528.pdf (fssc.com)

 

SQF 9.0 requires that Food Fraud Mitigation Plans be reviewed and verified annually, with gaps and corrective actions documented.

20227FMIN_FoodManufacturing_v3-2-FINAL-w-links.pdf (sqfi.com)

 

So in this one example, your contract manufacturer could be compliant with their FSSC 22000 regs and be deemed insufficient to meet SQF standard, all while they are manufacturing something under scope of SQF.

 

If someone thinks I'm way off base here, feel free to correct me.  I haven't run into this issue before, but it would make me nervous to have my product made by a contract manufacturer to begin with.

[PackageMarshal]

Reading the guidance document you attached, it states the following:

"The contract manufacturing must be assessed for risk to determine if their process or part of their process in high or low risk.  This will determine how they are managed.  High risk sites must achieve SQF certification and low risk sites must show compliance to SQF or another GFSI recognized program particular food sector category."

Based on this wording, it sounds like whether or not a GFSI certification would be acceptable is dependent on the risk level of the contract manufacturer.  So if a contract manufacturer is performing the entire converting process on our behalf, would I not consider them high risk and specifically require SQF compliance?  Even more than compliance, by the wording of the guidance, I would have to require them to be certified.  That seems extreme to me.

[G M]

It is stating that it is your responsibility to ensure your contract manufacturer has food safety and quality standards reasonably equivalent to those of SQF.  How you ensure that is open to some interpretation -- but I would expect certification under another GFSI scheme to be accepted, especially if you make some periodic first hand review of their programs and/or on site visits.

[SQFconsultant]

Your supplier is correct and their FSSC cert is eqvl for this purpose.

I'm sticking with what I said.

[Tony-C]

Reading the guidance document you attached, it states the following:

"The contract manufacturing must be assessed for risk to determine if their process or part of their process in high or low risk.  This will determine how they are managed.  High risk sites must achieve SQF certification and low risk sites must show compliance to SQF or another GFSI recognized program particular food sector category."

Based on this wording, it sounds like whether or not a GFSI certification would be acceptable is dependent on the risk level of the contract manufacturer.  So if a contract manufacturer is performing the entire converting process on our behalf, would I not consider them high risk and specifically require SQF compliance?  Even more than compliance, by the wording of the guidance, I would have to require them to be certified.  That seems extreme to me.

 

Hi PackageMarshal,

 

You are correct, the question is, have you assessed the risk associated with the process/processes carried out by the outsourced processor and what is the risk?

 

With packaging the risks are likely to be lower but outsourcing the manufacture of food contact packaging sounds more likely to be in a high-risk category.

 

Also note for low risk contract manufacturer’s SQF certification is the simplest way to demonstrate/verify compliance but this can also be done by audit:

 

SQF Food Safety Code - Packaging

2.3.3.2 i. Verify compliance with the SQF Food Safety Code: Manufacture of Food Packaging and that all customer requirements are being met at all times.

 

Edition 9 Guidance Document Contract Manufacturers:

High risk sites must achieve SQF certification and low risk sites must show compliance to SQF or another GFSI recognized program particular food sector category.

 

Kind regards,

 

Tony