7 replies to this topic

[JillClark]

Hello all!

 

How necessary is it to do on-site supplier audits?  The products we manufacture are very low risk, as are the raw ingredients we use.  We've never done an on-site audit for any of our vendors, so curious if this is something we should plan.  We have always done desk audits.  Previous auditors have mentioned it, but it hasn't been an issue and the code doesn't specifically call for on-site audits.   

 

Thanks!

 

Jill

[GMO]

It would depend for me on the risk of the ingredient (which you've said is low) and whether they have a GFSI standard.  If neither then I would audit.  Even if it's low risk. 

[JillClark]

It would depend for me on the risk of the ingredient (which you've said is low) and whether they have a GFSI standard.  If neither then I would audit.  Even if it's low risk. 

Thank you!  We have a few that aren't audited to the GFSI standard and those are the vendors I think we should be doing on-site audits.

[GMO]

I think with many GFSI standards you can get away without a site audit for very low risk suppliers without GFSI but personally I don't see how any ingredient isn't a risk to your business and while GFSI isn't perfect, it does give you some level of assurance that at least the systems are in place.  

 

While it's food safety which is the main concern, there is a concept in UK law of "due diligence" which is drummed into food safety practitioners from day one.  The idea being that things do and will go wrong but under law if you can prove you've done what's reasonable, then you're not likely to be prosecuted.  A supplier without an independent audit on their food ingredient is making me think I'd not be duly diligent if I'd not audited or arranged an independent one.  Same with primary, food contact packaging. 

[Tony-C]

Hi Jill,

 

Site audits aren’t always necessary or the best use of our time.

 

I think for low-risk suppliers, it is possible that a supplier questionnaire that contains relevant information for you to make an informed decision on whether to approve the supplier is sufficient.

 

My confidence in doing this would include supplier history and the amount of checks/monitoring being done on the incoming material.

 

Kind regards,

 

Tony

[GMO]

You have a lot more confidence in low risk suppliers than I do Tony.  Sadly I've seen some appalling standards and it sets hares running in me if someone isn't at least prepared to do a GFSI audit.  Yes everyone has their complaints on GFSI but one of the areas it has worked in helping reduce business to business non retailer audits.  So if you're not allowing a GFSI auditor in, it makes me think, why?

 

I had a primary packaging company where staff were shoving food contact packaging into machinery to cut the packaging with their feet.

 

I had a low moisture activity site where there was extensive pest activity.  Inside and out.

 

And I had another primary packaging supplier where people were not routinely wearing workwear even though that was their standard.

 

I had another operating out of a garage.

 

None of the above was visible on paperwork they supplied.  Some led to advice and a revisit to get to a decent standard to use.  Some we just didn't use at all.

 

You can't do it all, for sure.  But if you allow a lot of non GFSI suppliers what does that indicate?  If you have so many (more than 1 or 2) that it's onerous to visit them, then that probably says something about your culture too, especially what procurement are doing and how much they see food safety as their job.

[Tony-C]

Hi GMO,

 

I’m not sure that the suppliers you mention were low-risk? Normally I would NOT consider a supplier of primary packaging a low-risk supplier or primary packaging a low-risk raw material. Also, I would expect all my suppliers of primary packaging to have certification to a GFSI-benchmarked standard with a scope that includes the packaging supplied.

 

By definition low-risk materials/suppliers are not a priority for site audits.

 

There may be hundreds of raw materials/suppliers to assess so we prioritise supplier approval and monitoring based on our risk assessment: High-risk>Medium-risk>Low-risk

 

Our Supplier Approval Strategy may be:

Highest risk - we decide to conduct a site audit and require certification to a GFSI-benchmarked standard

Medium risk - we require certification to a GFSI-benchmarked standard

Low risk - we prefer certification to a GFSI-benchmarked standard but may accept certification to ISO 22000 or ISO 9001 and a completed supplier questionnaire covering relevant other information.

 

Clearly, we would prefer to have all suppliers certified as above but in certain circumstances we may accept a low risk raw material/suppler without any certification via a completed supplier questionnaire which includes relevant information provided we had a history of supply with no issues and the incoming raw material was monitored to the extent that any food safety risks would be identified.

 

I didn’t realise that you were a pioneer of food safety culture, I thought I was there 10 years before you!   

 

Kind regards,

 

Tony

[GMO]

I think if any primary packaging supplier is low risk then why isn't any ingredient?  Perhaps we're commenting meaning something different.  Secondary packaging?  Yeah sure but anything in or on the product?  There is always risk but many sites will consider some of those ingredients low risk, much as the person who posted the question does.   In fact they believe them to be "very low risk".