2 replies to this topic

[foodiepro]

I work for a branded product that strictly utilizes the services of contract manufacturers to produce our finished goods. As we grow, we are working to make our food safety and quality programs more robust. With these changes, we are finding scenarios where the comans are not compliant to our quality or food safety specifications (ie CIP cadence, testing parameters, production record sharing, policy/program sharing etc).  Contractually, they have agreed to comply with our parameters, however, when called out on non-conformities, the age old "but this is how we have always handled your product" is typically brought up.

 

When it comes to major non-conformities, what levers are available to hold these contract manufacturers accountable to compliance with our policies? Moving volume away from them may be the obvious solution, but obviously there is a business need to make product and the flexibility to just shift volumes elsewhere is not always there.  What have other companies done in this scenario?  

 

Unfortunately, the greater internal team outside of FS&Q tends to side with the comans and require justification of WHY we have to be "special" and enforce industry standard practices - which shouldn't be considered special at all.

 

I'm hoping to provide some turnkey ideas for the greater team on how to handle the nonconformities as they arise vs just calling out nonconformities with no proposed action behind it. 

[jfrey123]

I know that if you're SQF, you have to hold comans to not only YOUR specifications but also SQF standards.  It may be similar for the other GFSI schemes, I'm not an expert there.  That said, it means an auditor can review and find major violations if the comans are not up to your standards when it comes to food safety.

 

The VP FSQA I work under is used to this type of pushback on various topics, not specifically comans, and has been telling our executive team essentially that it's not the 90's/early 2000's anymore:  auditors and regulators are getting smarter, major retail customers are getting more stringent on following up to track these types of issues.  The "we've always done it this way" adage is losing business across the industry, it doesn't fly as an excuse anymore.  Unfortunately, we can raise the flags and warn until we're blue in the face, but it usually takes a punch in the gut from either regulatory bodies or customers to emphasize the needs with many of these executive "business decisions."

Edited by jfrey123, 20 March 2025 - 04:19 PM.

[GMO]

Firstly, I'm a pragmatic person.  If there is a way of complying to the spirit if not the letter, then I will normally find it and be happy.  Site doesn't want to share records?  Fine, I'll come to you and make sure we look at them together without me taking away a copy.  

 

If that can't be done, I'm not sure how risk management works in the US but in the UK the concept of a "risk register" held normally by finance team members is growing in use and I'm coming across more awareness and interest in it from outside of Technical.

 

It might be worth seeing if there is a similar approach in your jurisdiction in the US and finance people are often allies in this for the simple reason that if something goes wrong, there could be significant financial impacts.  Ultimately the suppliers are in breach of their contracts so there is a risk that now you know that, the insurance that covers your business may no longer cover you for a failure due to that supplier.

 

It might be worth a quiet chat to someone in finance about it.  See what they say and whether they also think insurance cover is a risk in that circumstance.  Especially if they're a small supplier and the impact could be large to you, if they went bankrupt due to an incident, (which happens), what are the financial implications of that?  Get all your ducks in a row about the genuine risks of the gaps you've found as well and see what they say.

 

Ultimately though if you still find it's fallen on deaf ears and you've tried it all face to face and you genuinely think it's a food safety risk, I'd have to do the slightly passive aggressive thing I hate...

 

Stick it in an email. 

 

Copy in procurement and finance.  Point out your concerns from a food safety perspective, the fact the suppliers are in breach of contract and what that means for your certification, risk and potentially insurance and then point out that they're refusing to change. Your recommendation, (to change suppliers or force the change presumably) and then add that into management reviews until someone takes notice.  It's kinda shooting yourself in the foot because it will be raised by external auditors but I always think you're part of the problem or part of the solution if it's serious.  And hiding this stuff eats you up inside.

 

Although honestly I'd struggle to work somewhere like that.  But I have no resilience for companies that don't take food safety seriously.