11 replies to this topic

[m.erzetti]

Hi,

just one help. If the raw materials risk analysis determinate it is at Hi Risk can I consider to reduce the risk if my supplier is an historical one and then approve it only with the questioner?

Thank you. 

[GMO]

If I understand this correctly, your risk assessment has identified a supplier or raw material as high risk but they're an existing supplier?  Personally I would treat it as any high risk supplier.  But that might not mean going for a visit.  One thing I used to do is ask for the actual audit report of their last GFSI audit.  Not all plants will share it but I found that more useful than just accepting certification.  Then on review of that I'd decide whether a site visit was needed.  I also did a questionnaire because at that plant we were supplying globally and some aspects of our requirements for our customers weren't within GFSI but also the understanding of risk, for example, the level of liability insurance etc.

 

I suppose I'd question myself, is there a chance that this risk assessment is pointing in the direction that this supplier may have been a higher risk than we think?  If so, is it worth more intense scrutiny?  Or have I regularly visited them over the years etc.

[AZuzack]

I've seen risk assessments that combine the raw material and supplier but also ones that treat them separately.  You can evaluate the supplier itself as a low risk supplier since there's a long history of no issues.  So you may not need to visit them, especially if they are providing GFSI certification and COAs.  

[kingstudruler1]

IMO you can reduce the risk of the supplier.   You can not reduce the risk of the raw material - unless you combined the two at one point and the ingredient was only high risk due to the supplier.   High risk products are high risk products regaurdless of supplier.  

Edited by kingstudruler1, 21 March 2025 - 03:21 PM.

[m.erzetti]

Thanks everybody but my question is how interpretate the BRCGS clause.

I know to make a risk analysis if the raw materials (risk or no risk) but I don't understand if after I can reduce this risk with the analysis of the suppliers.

 

The interpretation guide refert to "SUPPLIER RISK" to qualify them. So I can have a raw material classified like RISK but my supplier can reduce it like a NO RISK (but only the raw material coming from this supplier).

 

Now my supplier qualification process evaluate fisrt the raw materials risk then if the raw material is classificate like RISK the supplier must have a GFSI standard or have to be auditated. My process dosn't take in account the possibility to reduce the risk of the raw materials coming from a historical one.

[GMO]

3.5.1.1 is the section which determines the risk of the raw material.  That will not change with the supplier. Suppliers though might be good at controlling hazards and so the supplier risk assessment is separate, in 3.5.1.2.  

 

I think if I understand you correctly, you're asking if you have a great supplier with really good controls if you lower the ingredient risk.  Not to my understanding.  The ingredient risk for an ingredient processed in a certain way will be what it is.  But the supplier risk then gives you an overall risk rating of that ingredient from that supplier.  

 

There are cases where really decent suppliers get misled or let down by suppliers in their supply chain despite good controls.  Everything we do is a sampling exercise after all and the most fraudulent suppliers will find a way to pass tests.  So that section in 3.5.1.1 is, to my understanding a separate thing but helps guide you as to some of the controls you'd want to see in 3.5.1.2.  For example, a company buying in chilli powder will need to do so from a reputable supplier but also have a periodical testing regime for illegal dyes.  It doesn't make that chilli powder less risky especially as supply chains can be so long.

[m.erzetti]

Thank's GMO for the discussion.

 

I understand vey well what you say. But the problem is the qualification of the supplier. All the GFSI auditor told me that is the raw materials is classified like RISK, the supplier MUST be GFSI certificated or must be auditated.

 

What I'd like to do is a sistem like IFS food (see the product fraud mitigation guideline) where you can mix the product risk with the supplier risk, so you can qualify a supplier, ifenif the raw material is RISK, with a questioner and not with the GFSI certification or audit,

[Madam A. D-tor]

[...]

Now my supplier qualification process evaluate fisrt the raw materials risk then if the raw material is classificate like RISK the supplier must have a GFSI standard or have to be auditated. My process dosn't take in account the possibility to reduce the risk of the raw materials coming from a historical one.
[...]

3.5.1.1: asks to assess the risk of the raw materials

3.5.1.2: asks to assess the risk of the suppliers
In the Standard I do not see a link to them.
A high risk supplier (depending fore example, on location, financial situation, contacts, complaints, incidents, producer/ broker, and others) can supply both a low risk ingredient and a high risk ingredient. The same for a low risk supplier.

You do not reduce the risk of the raw materials by the risk of the supplier. These are different things.
 

The question is, why would you approve a supplier only on a questionnaire? On which is your trust in this supplier based, if it is not on audits or third party audits?

[m.erzetti]

Hi Madam A.D.-tor, the problem is that not all the company I follow want spend time and money to qualify a supplier if it is not a GFSI certificated.

But like consultnat I want make a good work with the raw materials analysis and then with a supplier one.

[Madam A. D-tor]

Hi Madam A.D.-tor, the problem is that not all the company I follow want spend time and money to qualify a supplier if it is not a GFSI certificated.

But like consultnat I want make a good work with the raw materials analysis and then with a supplier one.

In that case the question is to your clients, the companies that do not want to make costs: On which base do they trust their supplier? Or are they only buying at these not certificated suppliers, because these have lower prices? 

 

I appreciate your wish to do a good job, however your questions seems a bit like you want to bent the Standard/ Requirement to something that fits you/ the companies that you represent, instead of the other way around: make sure that the company complies to the requirement.
 

[GMO]

your questions seems a bit like you want to bent the Standard/ Requirement to something that fits you/ the companies that you represent, instead of the other way around: make sure that the company complies to the requirement.

 

 

Now that would make a good topic...

[m.erzetti]

Madam A.D.-tor you are right,,,,,, but you have to fight with the old mentality of some bussiness.

I know that the standard is stricktly and you have to apply it as it is written.

For my experience you can satify the standard but if your assessment is not based on the reality or you but a grade per the level RISK t high you satify only the standard but not the reality.

 

However my process is:

1. Assess the raw material (3.5.1.1 amd 5.4.3-5.4.4) to determinate if the raw materia or pack is RISK

2. Send to all the supplier the questioner (so I can know if they are GFSI or not) and then qualify them.

 

The assessment of raw material, as you know, can be done based on the reality or on a empiric and fantastric world ..... (I'm just tray to exprime my thinks)

 

Answering to your qyestion:

1. On which base do they trust their supplier? 

The supplier have to respond to the questioner (question based on: HACCP-Traceabiliy-Food Defence -Food fraud - Specifications -) and to sight it. The company have to make the routinally control when the raw material arrive. If there is not compling with the declaration or qith the specific you can ask them the damage

 

2. Or are they only buying at these not certificated suppliers, because these have lower prices? 

The price is at the base of all purchising ........ you konw also spme of the GDO (Grat distribution organization) do not recognize the more price for the products and someone make the lower price auctions