Traceability exercise from agents

Look at clause 3.5.1.2.

Details what to do if suppliers are NOT GFSI accredited.

For example, we have SALSA certified suppliers, whom i have completed RA's for and as they are non-GFSI we conduct a traceability study annually from.

Most suppliers are aware of the BRCGS expectations and as such are happy to complete and send over traceability evidence.

Clauses tell your what you SHALL (must as used the word SHALL) do..

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. The approval procedure shall be based on risk and include either one or a combination of:

• a valid certification to the applicable BRCGS Standard or GFSI-benchmarked standard. The scope of the certification shall include the raw materials purchased

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. The audit shall ensure that these plans form part of the supplier’s product safety management system and that any resultant actions are implemented. The supplier audit shall be undertaken by an experienced and demonstrably competent product safety auditor. Where the supplier audit is completed by a second or third party, the company shall be able to:

• demonstrate the competency of the auditor
• confirm that the scope of the audit includes product safety, product security and food defence plan, product authenticity, traceability, HACCP review and good manufacturing practices
• obtain and review a copy of the full audit report

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. At a minimum, the questionnaire shall have a scope that includes product safety, product security and food defence, product authenticity, traceability, HACCP review and good manufacturing practices. The questionnaire shall have been reviewed and verified by a demonstrably competent person.

1.  Do you have to use them?  The reason I ask is that while a BRCGS or GFSI cert isn't a guarantee of quality or food safety, it's also not a good sign that a company isn't prepared to do it.

2.  If it's a yes, and I've been there, then audit them.  

As it's an agent / broker, this is the kind of thing I'd look for (please chip in anyone if I've missed anything), I'm assuming they don't open packaging at all:

• Delivery notes of items.
• Delivery records including a check of the condition of the vehicle, including temperature if appropriate and that the item came from the expected source (authenticity).
• I'd like to see on those records that the expected product was labelled as expected (i.e. authentic) and any testing carried out as appropriate even if that's just visual inspection.  
• Checking these records are signed by an employee and a record they were trained to do the check.
• Storage conditions and locations for the item(s).
• Any picking records if relevant.
• Despatch records including condition of vehicle / temperature and training.

I'd also check out the storage, that there are no signs of pests, it's at the right temperature, that there are no signs of spillage.  Pallets are off the ground or fast moving and away from the wall to facilitate inspection.  I'd ask to see the last 3 pest visits and open some bait boxes if possible.  Fabrication I'd check to see if it's good. Doors are shut.  Allergens stored below non allergens ideally in designated areas.  

As above I'd also ask to see HACCP, food defence plan and VACCP / authenticity plan.  But as I'm walking I would also look for signs it's not being followed like doors without access control, unlabelled items etc.  You'd also want to see the training records for the team members of those plans.

All in all that's probably half a day's work on site and probably the same again writing up depending on the size of the site, how experienced your auditor is and how efficient your systems are.  But worthwhile time and needed for your GFSI / BRCFS accreditation.