11 replies to this topic

[Padfoot]

Hi everyone,

I have a question regarding raw ingredients documentation. We currently have COA LOG and third party audits from all our vendors except for one. One of the ingredients we purchase is small in volume, so we just have it delivered from Costco, the manufacturer is Cheswick. I currently have nothing on file (spec, COA, LOG). What should I do?

 

Thank you!

[MDaleDDF]

imho, not what you're doing.   That it's a small amount of something is a hurdle I've had to deal with at my facility as well, but it's simply a no go for our NSF system.  I had to stop producing a few formulas due to this same issue, and a few others that were important enough that the customer would pay it, I have to order some ingredients in minimums way higher than needed, and throw away what we don't use, and price it into the product.  Unfortunate, but that's our workaround for the issue you're having.

But no spec?  No COA?   Buying raw ingredients from a local store and putting them through your production?   Not acceptable, again, imho...

[Scampi]

I would say this depends on risk

 

A) is the ingredient often the subject of fraud

B) is the package inspected for integrity prior to using

C) did you reach out the actual manufacturer to request more information

D) does you process have a kill step etc.

 

Build a risk assessment to cover this ingredient-----------all you can do is try

 

The reason I'm saying this is due to the costco addendum------if you were talking about your local independent grocery store, my answer may be different----but if we all believe in GFSI (not saying we all do) then the product and company should be vetted enough to meet your needs

[OrRedFood]

I would say this depends on risk

 

A) is the ingredient often the subject of fraud

B) is the package inspected for integrity prior to using

C) did you reach out the actual manufacturer to request more information

D) does you process have a kill step etc.

 

Build a risk assessment to cover this ingredient-----------all you can do is try

 

The reason I'm saying this is due to the costco addendum------if you were talking about your local independent grocery store, my answer may be different----but if we all believe in GFSI (not saying we all do) then the product and company should be vetted enough to meet your needs

 

Scampi/everyone - curious what would you say if it were a local grocery chain that you were purchasing items available to the public for use as ingredients? We are in that situation as well.  Some actual suppliers will provide COAs (Libby's is one), others will not even respond. These are items such as RTE hamburger relish, pickled jalapenos, canned pumpkin, sriracha hot sauce. I've asked this question on this platform before; I'm always interested in how people think about this issue.  We have not been cited for lack of documentation for these items and others purchased in the same way by SQF, but it's bound to happen at some point.  I just have trouble with the expectation that we as a small company have the clout to get a COA for 3 gallons of relish which anyone in the country can purchase safely without concern.  

 

Any ideas are welcome! ☺

[jfrey123]

Costco does deliveries?  I never knew that lol.  Buying retail for food production is a no-go generally because you're outside of the traceability chain if said item was subject to a recall, plus to mention that a grocery/warehouse store is open to the public and goes outside of food defense plans.  I've had auditors really go down the rabbit hole of employees transporting the goods, ex: "well, we sent the employee to buy bags of rice, and he loaded it where he transports his dog from the dog park all the time, and now we can't explain how we brought e.coli into our plant..."  At my first QA job, the plant manager liked buying the isopropyl alcohol we used as a sanitizer from his local drugstore, and they made me put the drug store on our approved vendor list when I pushed back and said it wouldn't fly.  SQF auditor missed it the first year so they felt validated that I was wrong, but second year SQF auditor spotted it and marked it as unacceptable.

 

I agree with MDale above.  Every time I've tried to reason and get retail purchases to fly, it doesn't hold up to scrutiny.  And while most GFSI codes permit for purchases through unapproved vendors, those cases are stated for "emergency situations" where a separate analysis is performed to ensure it is safe for that circumstance.  Doing it routinely because of small order quantities ain't that.

[ColbyHolstein]

Hi Padfoot,

 

I'm not sure if your company is GFSI or not, but I know that for SQF you have to at least have tech specs for all raw materials that you're bringing in. Maybe you could get that from the manufacturer. As for COA, you could always pay to do the testing yourself but seems like it wouldn't be worth it due to the small volume. You'd have to do a risk assessment to determine what lab results you needed. And like Scampi said, criteria like possibility for food fraud and whether the ingredient will be added pre- or post-lethality step will weigh in on what you decide you need for documentation.

[Scampi]

Hi Padfoot,

 

I'm not sure if your company is GFSI or not, but I know that for SQF you have to at least have tech specs for all raw materials that you're bringing in. Maybe you could get that from the manufacturer. As for COA, you could always pay to do the testing yourself but seems like it wouldn't be worth it due to the small volume. You'd have to do a risk assessment to determine what lab results you needed. And like Scampi said, criteria like possibility for food fraud and whether the ingredient will be added pre- or post-lethality step will weigh in on what you decide you need for documentation.

What SQF actually requires is as below:

2.3.4 Approved Supplier Program (Mandatory) 2.3.4.1 The responsibility and procedure for selecting, evaluating, approving, and monitoring an approved supplier shall be documented and implemented.
A current record of approved suppliers, receiving inspections, and supplier audits shall be maintained. 2.3.4.2 The approved supplier program shall be based on the past performance of a supplier and the risk level of the raw materials, ingredients, processing aids, packaging, and services supplied, and shall contain at a minimum:
i. Agreed specifications (refer to 2.3.2);
ii. Reference to the level of risk applied to raw materials, ingredients, packaging, and services from the approved supplier;
iii. A summary of the food safety controls implemented by the approved supplier;
iv. Methods for granting approved supplier status;
v. Methods and frequency of monitoring approved suppliers;
vi. Details of the certificates of conformance, if required; and
vii. Methods and frequency of reviewing approved supplier performance and status. 2.3.4.3 Verification of raw materials shall include certificates of conformance, certificates of analysis, or sampling, and testing. The verification frequency shall be identified by the site. 2.3.4.4 The receipt of raw materials, ingredients, processing aids, and packaging from nonapproved suppliers shall be acceptable only in an emergency situation and provided a receiving inspection or analysis is conducted and recorded before use. 2.3.4.5 Raw materials, ingredients, and packaging received from other sites under the same corporate ownership shall be subject to the same specification requirements (refer to 2.3.2), approved supplier requirements, and receiving inspections as all other material providers.

 

The caveat here is that there is some ambiguity in the language. Since the poster isn't talking about purchasing "raw materials"  and is buying an "ingredient" the requirements are not identical. See above

 

 

As for the comment about local grocers, if they are NOT part of a large chain they are less likely to require their vendors have a GFSI certificate, Costco requires it from almost all vendors (with very small businesses being the only exception)

[MDaleDDF]

The ambiguity in all GFSI systems is what kills me.   Most of these schemes read like they were written by Pythia, oracle of Delphi.....

[OrRedFood]

The ambiguity in all GFSI systems is what kills me.   Most of these schemes read like they were written by Pythia, oracle of Delphi.....

I will volunteer to travel to Greece and see if Pythia is still taking questions!

[MDaleDDF]

I will volunteer to travel to Greece and see if Pythia is still taking questions!

I shall accompany you....

[jfrey123]

The caveat here is that there is some ambiguity in the language. Since the poster isn't talking about purchasing "raw materials"  and is buying an "ingredient" the requirements are not identical.

 

Agree there is some ambiguity in the code itself, but jumping to the definitions included in SQF code presents a loop where I think any SQF auditor looks at ingredients and raw materials the same for purposes of the code.  I'd be hesitant to try and defend small retail purchases of a spice by arguing that it's not really a raw material.

 

Ingredients: Minor materials (e.g., spices) used to supplement the conversion of raw materials in the food manufacturing process (refer to “raw materials”)

 

Raw Materials: The primary material from which a food or feed product is made. Raw materials may be unprocessed, ie primary agricultural materials, or processed, i.e., the form has been substantially changed prior to receipt by the site (refer to “ingredients”).

 

Not to mention I've always had to put my Processing Aids in the same category as my raw materials as far as my supplier approvals go in order to satisfy auditors (one example was using liquid nitrogen in milling of a plant sterol powder).

Processing Aid: Any substances intentionally used in the processing of raw materials, foods or their ingredients to fulfil a certain technological purpose during treatment or processing, but which does not form part of the finished product.

[Charles.C]

Hi everyone,

I have a question regarding raw ingredients documentation. We currently have COA LOG and third party audits from all our vendors except for one. One of the ingredients we purchase is small in volume, so we just have it delivered from Costco, the manufacturer is Cheswick. I currently have nothing on file (spec, COA, LOG). What should I do?

 

Thank you!

Hi Padfoot,

 

So is  there any GFSI-recognized Standard Involved ?