2 replies to this topic

[johanacHTF]

We have some suppliers of raw materials and primary packaging (as defined by BRCGS) who do not have valid GFSI certification, but have been our supplier for many years with no major food safety issues. My question is if clause 3.5.1.2 only applies for the approval of new suppliers or for all (new and current). My question comes from 3.5.1.3 which talks about ongoing suppliers performance review. We have a supplier re-evaluation procedure where the availability of documentation, compliance with specifications, among other things, such as whether it is certified or not, are evaluated. It has worked for us in our last few audits, but I'm not sure if it will hold up to a tougher auditor.

[SQFconsultant]

I'd just go ahead and either conduct an audit similar to a standard 3rd party audit or commission the audits thru an auditing company like CICS, NSF. etc.

 

No need to hold them to a GFSI type audit. 

[Tony-C]

Hi johanacHTF,

 

You have posted in BRCGS Packaging but I believe you are referring to the BRCGS Food standard. BRCGS Global Standard for Food Safety Issue 9 3.5.1.2 requires all suppliers to be approved:

The company shall have a documented supplier approval procedure to ensure that all suppliers of raw materials, including primary packaging, effectively manage risks to raw material quality and safety and are operating effective traceability processes.

 

Your approval can be based on:

• valid certification to the applicable BRCGS Standard or GFSI-benchmarked standard.

or

• supplier audits, with a scope to include product safety, traceability, HACCP review,

the product security and food defence plan, the product authenticity plan and good manufacturing practices…….

or

• where a valid risk-based justification is provided and the supplier is assessed as low risk only, a completed supplier questionnaire may be used for initial approval.

 

The best practice would be to audit or arrange an independent audit if a supplier doesn't have a suitable certification.

 

The alternatives are if the supplier is low risk then a questionnaire may be sufficient. If not, you may be able to justify ongoing approval based on historic performance but this would be closely scrutinised if there is a significant risk with any of the raw materials or packaging.

From BRCGS Global Standard for Food Safety Issue 9 3.5.1.3 Guidance:

The site is free to determine how it confers continuing approval on its suppliers, but it is important that the site uses a risk-based approach.

 

Kind regards,

 

Tony