BRCGS Clause 3.7.5 - Supply Chain Traceability
Hello,
In our attempt to comply to the clause 3.7.5 regarding food chain traceability, we sent a traceability exercise to our suppliers. Some of the suppliers didn't complete the whole test and mention that the information is confidential as per their company's policy. Hence, some parts of the exercise remained uncompleted.
I would like to know if the auditor will accept such traceability exercise as an evidence of compliance to the clause ?
If not what can we do in this case?
Thank you in advance,
Greetings weaam,
Clause 3.7.5 of which standard? Also, I do have to question if there is a possibility for you to review what information you ask for in your traceability exercise? Could it need a makeover?
I ask this because I have seen from time to time some "weird" questions which do fall under GDPR and yes they can be refused to be disclosed. I have done so in some cases too. Some examples are "Mention some of your clients", "Detail the cost of the raw materials used for the product you provide us", "Mention your raw materials suppliers", "Attach your company's legal paperwork" and other more or less similar things.
Point is I don't really know your questionnaire, but one must be careful when creating one, as there are things that are indeed confidential (eg names, cost values etc). The focus of this questionnaire must be solely to help them prove to you that they can trace their product with their raw materials and batches/lots and quantities used/produced.
It may not be the case, as you haven't provided many details, but I can't blame outright the suppliers. A smart auditor may also be able to discern if the questionnaire you use is too "revealing", but if he/she goes by the book then you will propably get an N/C.
Regard!
Sorry for the inconvenience in the post. The clause is 3.7.5 of BRCGS Issue 6.
As for the exercise sent to the supplier, please find it attached.
We understand that the part related to the raw material could be confidential but what about the other parts .Supplier traceability testing.xlsx 11.26KB 37 downloads
I am a bit confused now... What parts don't the supliers usually complete? There isn't any question that can't be safely answered. Maybe the Final / Intermediate Production Process boxes are a bit unnecessary, since you have a box for Raw Materials used. And for the raw materials apart from the used quantities (correcting myself here from the previous post, since the recipe is protected by copyright rules) they can provide ingredients and lots/batches.
Also, for product specification you could ask for an attachment, since it can be a long writing.
They are not completing the intermediate production process and raw material parts.
Just delete this part, it is not important and many may not even have intermediate steps (you do mention also "if applicable"). As for the raw materials mention only 2 clues in the parenthesis that they should be filling, name and lot and press them a bit more.
Sorry, never heard of sending an exercise with test to be completed by a supplier - or was this a questionnaire which is normally a standard thing?
Hi weaam,
Your traceability test is only required for suppliers that have been approved only via a questionnaire and not by an onsite audit or because they are certified to an appropriate GFSI-benchmarked standard.
Relevant BRCGS Global Standard for Packaging Materials Issue 6 requirements and guidance are outlined below:
3.7.5
The company shall ensure that its suppliers of raw materials have an effective traceability system. Where a supplier has been approved based on a questionnaire instead of certification or audit, verification of the supplier’s traceability system shall be carried out on first approval and then at least every 3 years. This may be achieved by a traceability test.
Interpretation - Supply chain traceability
Examples of acceptable traceability include:
• the raw material supplier is certificated to a GFSI-benchmarked standard. Assessment of traceability systems forms part of these audits ….
• the raw material supplier is audited by the site and the audit includes an assessment of the traceability systems…..
• verification of a supplier’s traceability system where approval has been based solely on a questionnaire with no additional testing ….
Traceability verification is a requirement for each raw material supplier. Therefore any traceability test (because the supplier approval is based solely on a questionnaire) should be designed to test the raw material supplier’s systems and not to trace every single material they produce.
Kind regards,
Tony
Sorry, never heard of sending an exercise with test to be completed by a supplier - or was this a questionnaire which is normally a standard thing?
Yeah this is a form of questionnaire to test the effectiveness of the supplier's traceability system.