2 replies to this topic

[FSQAManager2025]

Hello,

I am going over my facility's supplier approval process. According to BRC Issue 9 clause 3.5.1.6, you need a certification or audit to approve a supplier. If you have neither you can approve based on a questionnaire if a traceability test is performed. My question is: does being USDA, FDA, etc. count, or is it enough to approve a supplier without having to perform a traceability test? Or is having a letter of guarantee sufficient? 

[Ishau]

This post was made in the BRCGS Packaging Materials forum, but the text suggests this is a BRCGS Food Safety enquiry. The Standards have some subtle differences, like the review frequency, just something to bare in mind.

To answer the question specifically - there is no specific requirement in either Standard to insist they actually perform a traceability exercise. The Standard allows for you to just request a copy or their procedure (detailed description of the traceability process) or a worked example (so if they have done their own test they can send it to you, no need to do one specifically for you).

It is important to just clarify one thing though. You can approve based on questionnaire if they don't have certification or a supplier audit, but there does still need to be risk justification in place for it.

[GMO]

The questionnaire option is clearly one that BRCGS does not like. If you look at the interpretation guideline there are several caveats around this clause such as:

 

"The auditor will expect to see, and will challenge, risk assessments"

 

It also recommends reviewing the risk assessment on any change. So for example, you do a risk assessment and the supplier origin of one of the ingredients in the supplier material changes. Could the auditor then argue that if there is a risk with that ingredient you should have reviewed your risk assessment.... etc.

 

Across the world, legislation for food industry differs WILDLY. I went to a UK producer (non GFSI) the other day who I am surprised are still trading. I'd say for food ingredients, I'd really wonder why someone doesn't want to go for a GFSI standard unless, perhaps for packaging. I'd wonder even more why our procurement team are insisting on it. And yep I'd be going to visit that team.

While the previous poster is right you don't have to test their trace as part of a questionnaire and you don't have to audit, considering this company doesn't have GFSI and not all legal requirements go as far as GFSI does, I would struggle to see how effective saying "do you have incoming and outgoing traceability?" is as a question without testing it.