10 replies to this topic

[Josharp186]

Hello, 

 

I have a unique situation. A supplier who my company has been doing business with for many years and whom we started purchasing co-packed jars from, will not supply us with COAs for those jars without a major cost increase. This same supplier however, will send us COAs for any bulk product we receive which we still have to package and sell. 

 

They came to us with the point that nobody else they sell to co-pack needs a COA since they are purchasing an already finished good, and the company takes all risk. We still need to label the product and sell to the public with our name so there is some risk associated at least without the proper contracts signed. 

 

My question is, are we being unreasonable to ask for COAs in this scenario? My policy is we need a COA showing pathogen testing with negative results is necessary for all incoming product. We, in our receiving do not consider the co-pack a finished good since we still have to label. What is the risk? Should we cave in and call it a finished good upon arrival? Is this supplier being shady? They are not looking to bend on the request without a much larger price increase. And if it were up to food safety, that would be an increase we would take. But you know, classic food safety and operations battle here. 

 

Does anyone have any advice or been through a similar situation? I also feel like the traceability access with the current process is slow and puts both of us at risk if a recall were to occur. In the very end of this, I want to cut them as an approved supplier after the in person audit I performed but I am giving a chance to amend findings as we have a long standing relationship. 

 

Thank you, 

J

[SQFconsultant]

If the relationship is so long and good is there any reason you can't do your own testing and work up your own coa?

Given that. Would there be any reason to cut them for the audit?

[Brothbro]

I too wonder at the comment you made regarding the audit you performed on them. Do you mean that you saw lots of problems during your visit? If you saw things at their facility that indicate a lapse in food safety/quality standards could you not use that fact as justification for why you would need a CoA? Typically providing a CoA with each lot is not a difficult task for a supplier. My hunch is that they aren't performing the testing on their products that you would expect them to. The "high cost" of providing a CoA may relate to funding their efforts to actually do the testing lol.

 

SQF Consultant mentioned this above, you have the option to perform testing on the product yourself as well. But what if it reveals a problem? You'll have to decide if your company would be willing to confront the supplier on the issue and perhaps reject shipments.

 

I would look into other suppliers while you sort this out. Especially if you can get a competitive price elsewhere, you can use that as leverage in your negotiations. No one likes losing a customer!

Edited by Brothbro, 28 July 2023 - 10:08 PM.

[Josharp186]

When I went to perform the audit there were not major or critical findings. They are a very old facility in a rough part of LA and their workforce and programs reflect the age. They are not SQF or a GFSI audit scheme certified so I gave them some things to work towards by the end of the year. 

 

It is definitely my hunch they are not performing all the COAs in a timely fashion, there is also some arguing that they just don't have an individual to process these, which is a good deal of work, but being the guy who does this, I know its not an outrageous process. 

 

I have thought about testing the product that comes in but have not wanted to increase the hold time of being able to use the product before product with hold and release as well as add additional lab costs to my process. Its worth considering in the long term but we do not have this issue with any other supplier. 

 

I guess my main question here is, what risk or legality do we have with receiving an item that comes in prepacked and sealed jars vs. just raw bulk? Do you think its fair for the supplier to claim this is a reason to bypass the COA process? 

[Brothbro]

When receiving this material you need to be assured of its safety and quality. Typically all inbound materials are tested for important parameters before use in production, but exceptions can be made if the supplier goes through a good approval program and has a good track record. In these cases though it's still the COA that is reviewed with every shipment, the benefit is that you don't need to spend time testing the product yourself. In this situation it doesn't sound like you have the justification to just take the supplier at their word that the material is ready to use right away. How can you be sure that -any- routine safety/quality testing is being done on this product? It's your label going on the finished good right? It's farfetched to release product without any data on what is actually inside the jar. Even just quality issues like color and taste. These characteristics are likely important to your company.

 

That's the crux of the issue to me, I wouldn't feel comfortable receiving all these jars without assurance that they've been tested for safety/quality. The supplier shows some risk too in that there isn't much oversight on their operation. If they just stopped testing their product altogether, how would you know?

[SQFconsultant]

Here's the only thing I cared about and looked for when running an analysis of a client's approved supplier program...

If the approval process said that in order to be qualified as an approved supplier each one had to submit × number of items, had to be subject to some type of inspection and if the client said that a coa had to be submitted with each shipment then as far as I was concerned EVERY SINGLE ONE OF THOSE HAD TO BE SHOWN TO BE for a randomly selected number of suppliers.

If the client went ahead and approved a supplier in violation of their own standards they would fail that section and potentially other domino effected sections of the audit.

You either have compliance or you don't.

So basically they came to the party without bringing any gifts and they have no intention to go home and wrap something up for you - so no cake for them!

Edited by SQFconsultant, 31 July 2023 - 08:48 PM.

[Josharp186]

I do appreciate you stringency for compliance SQF Consultant. I also hope you are not my soon to show up unannounced SQF auditor (haha). 

 

Our policy is all incoming raw materials must have a compliant COA before they can be released into production or sold as a finished good. So yes, there is a gap in compliance here which I am trying to straighten out. I am being challenged by the operations team to look at all regulatory guidance to make sound decision that allows us to maintain food safety but also remain good business partners with this supplier (we get some major discounts...)

 

Some very good points made by Brothbro, I am actually quite in alignment with what you are saying. It really does come down to documentation and proof. The only rebuttal to that is we do receive COAs from this supplier for anything that is a raw ingredient in a bulk form, that is INDEED happening. So I know they are testing and I know they are capable of sending COAs, it just becomes a matter of extra work on their end for the multiple lot numbers they would have to make COAs for when doing co-packed jars. 

 

Current options: 

1. Pay the increase for COAs. 

2. Implement a validation procedure after having the supplier sign a contract stating products will meet conformance on internal COAs. Potentially plan to test this supplier in retrieval upon request and then testing received product on hand against specs, once a month (or some defined frequency). Reject all product if specs are not met. (still receive COAs on raw ingredients in a bulk form)

3. Un-approve the supplier and purchase co-pack items elsewhere. 

[SQFconsultant]

Lol...

I do appreciate you stringency for compliance SQF Consultant. I also hope you are not my soon to show up unannounced SQF auditor (haha).

......

No problem, no chance of that - I switched hats 25 years ago from being an SQF Auditor to an SQF Consultant.

[kingstudruler1]

maybe an unpopular opinion....

 

I don't understand the reliance on COAs.   Most companies don't have a statistically valid sampling and testing plans.  The chance of finding a pathogen by testing a few grams of a large lot is pretty small.   Relying on your supplier to fulfill the approved supplier process is not the best idea.  We don't accept 1st party audits why do we accept 1st party testing and coas?

.   

My final straw was when I received a recall notice form a supplier that still "stood by their COA data."   

 

To quote Tommy:

"The point is, how do you know the Guarantee Fairy isn't a crazy glue sniffer? "Building model airplanes" says the little fairy, but we're not buying it. Next thing you know, there's money missing off the dresser and your daughter's knocked up, I seen it a hundred times."

 

If you feel that you need the testing, pay for the coa or sample and test yourself.  

Or get a new supplier / copacker.   

Edited by kingstudruler1, 01 August 2023 - 08:13 AM.

[Scotty_SQF]

Could they supply the COAs from their suppliers for what is packed in the jars?  Will that help the situation?

 

If all else fails as stated above, perform the testing yourself or pay extra for the data you want.

[Josharp186]

Scotty- They perform the packing themselves. They have bulk COAs, which is what they forward to us (I presume) when we purchase bulk. 

 

I am leaning towards a validation procedure until we find ourselves a different Copacker. A great point from kingstudruler1. It does almost seem like more of a formality and CYA move than actually knowing what is there. 

 

What has occurred as was stated on another thread, I have written myself up again a rock and a hard place. I think opening a CAPA and exploring alternative COA options might make sense. And yes, maybe this appeases the business folks but hey, this is business. 

 

At the end of the day, food safety is all about mitigating risk and preventing known hazards. If I can find a solution that works for all these variables and write the policy, I will be good to go.