3.6.2 - Methods for supplier approval
Hi all,
In the updated supplier approval section clause 3.6.2 states that supplier approval can be attained via:
How are people interpreting this? To me this is essentially saying (based on risk of course) that ISO9001 + declaration of compliance is valid for approving suppliers. In the past where a site has had ISO9001 we have sent out a secondary 'hygiene questionnaire' to ensure sites comply with the fundamentals of the product safety part of the BRC.
I think I'd be inclined to prefer a GFSI based standard as ISO9001 isn't specifically for food or food contact materials. I think where you do only have ISO9001 with a supplier you need to make sure that some aspects you'd expect to be present for (for example) materials which are linked with food safety (e.g. primary packaging or packaging with legal data on there) has the right controls, including HACCP for example, which won't be called out in that standard. I'd argue that would feed into the "safe and legal" bit.
Might be worth buying the interpretation guideline but broadly it looks like ISO9001 might be ok but I'd make sure there aren't other gaps to the clause.
Hi Paul
'Certification to a globally recognised quality management system…' etc. was one of the changes in Issue 7 as a result of stakeholder feedback. Clearly a much greater number of suppliers of packaging materials are certified to ISO 9001 and this is a sensible change, in fact previous guidance did mention supplier approval of ISO 9000 certified suppliers.
So your system ‘where a site has had ISO 9001 we have sent out a secondary 'hygiene questionnaire' to ensure sites comply with the fundamentals of the product safety part of the BRC.’ would be fine if you add traceability, have agreed product specifications and the scope of the supplier’s ISO 9001 certification includes the raw material/product that you are purchasing.
Kind regards,
Tony
Thanks for the replies.
For clarity we are a label manufacturer, so no direct contact with food and other hygiene sensitive materials. On the basis of risk we have required ISO9001 + the aforementioned hygiene questionnaire and been fine. My interpretation of the new clause is that we can get rid of the hygiene questionnaire and just have a declaration of conformity alongside the ISO9001 - again based on risk and no food contact etc etc.
Tony - you mention that ISO9001 'would be fine if you add traceability.' This is actually a discussion I've had with auditors in the past and has been accepted by them, but wanted to know if others have had similar experiences:
I've always referred to 8.5.2 from ISO9001 which states "8.5.2 Identification and traceability. The organization shall use suitable means to identify outputs when it is necessary to ensure the conformity of products and services. The organization shall identify the status of outputs with respect to monitoring and measurement requirements throughout production and service provision. The organization shall control the unique identification of the outputs when traceability is a requirement, and shall retain the documented information necessary to enable traceability."
I suppose the potential problem here is the wording "when traceability is a requirement." Again though, I've had the discussion with auditors in the past who have subsequently accepted that ISO9001 does include traceability
If you're including food safety information or legality information on your labels, do remember that if they go onto the unit supplied to the consumer, BRCGS deems this "primary packaging" even though that's nobody's definition of primary packaging in the food industry. The point being though that it's part of what goes to the consumer and it does have legal and food safety information on it (as well as claims etc). But either way, it might be helpful to understand the requirements of food businesses onto you and, hence, what you might need to supply them? The appropriate section is 3.5.1.2 and 3.5.1.6 (the standard is free online). Within the food standard it's certainly permitted to have other processes of approval as long as trace is included.
Hi Paul,
Fair comment regarding traceability being included in ISO 9001 and Issue 7 does require it to be incorporated into the recognised QMS.
I was thinking more of the BRC's tendency to like a traceability test with the supplier approval process although based on your experience it seems that is less of a case with your packaging.
Kind regards,
Tony
Thanks chaps for the discussion