12 replies to this topic

[MDaleDDF]

What are yall doin for this?   

 

Site management shall require raw materials suppliers to notify the site of changes in product composition that could have an impact on product formulation (e.g., protein content, moisture, amino acid profiles, contaminant levels, allergens, and/or other parameters that may vary by crop or by season).

 

I do a spec review every year, but I'm reaching a little with how to show I've required every supplier to do this.   Quite honestly, to many of my suppliers we're the small customer, and they're not going to respond to any of my 'requirements' most likely.   And furthermore, they're going to let me know if such changes do take place anyway.

 

I'm struggle-bussing this one a bit....

[TimG]

For us, reviewing a CoA is part of my incoming approval process. I look at their COA and match it up with what our spec says it should be. If it doesn't match, it gets rejected. I don't have a huge list of incoming though.

I notice some of our bigger customers have a section in their approval process that states 'if you make x/y changes you will notify us.' 

[MDaleDDF]

For us, reviewing a CoA is part of my incoming approval process. I look at their COA and match it up with what our spec says it should be. If it doesn't match, it gets rejected. I don't have a huge list of incoming though.

I notice some of our bigger customers have a section in their approval process that states 'if you make x/y changes you will notify us.' 

Man Tim this is exactly my point.   I do the COA review on incoming too.   Annual spec review.     Supplier review.   But that doesn't satisfy this imho?   I dunno.....  I have a pretty large amount of suppliers, and like I said, some of them are pretty large and I don't like making demands of them, because if I'm them, my attitude towards me is:   "then go somewhere else", which for some items we can't.   

Can I just like send our contacts an email asking for notification, lol?    This one is tough to me....

[TimG]

It will satisfy this. You will want it documented that you do incoming CoA review somewhere to verify it meets spec (ours is documented on incoming goods/receiving). You also want to make sure that the parameters which affect your end product are actually ON the coa. If they aren't, you can still do the testing yourself and approve the ingredient based on your own testing.

You're overthinking it; the big fellas aren't going to reach out to all of their little customers if they slightly change a spec. It's on the little customers to make sure it still is compliant with what the little customer needs before approving for use.

[jfrey123]

The code states we shall "require" our suppliers to notify us of ingredient changes, so we do.  It's in the supplier requirements form I make them all agree to, so they're now "required' to update us when anything changes.  Do they?  Not always.  Same problem others have where we might be buying ingredients from someone too big to take us seriously, or maybe they just don't have their act together the way we need.

 

Now, enforcement is a whole different can of worms as it's not clearly defined in 2.3.2.x.  It means jumping forward to the Approved Supplier Program under 2.3.4.1, which requires you to document the monitoring of things like supplier performance and ingredient specifications.  For periodic monitoring, we'll choose to have QA at one of our sites send a picture of ingredient product labels for us to verify against the published spec.  I request updated specifications at the annual mark, normally when I'm asking for their updated GFSI certs.  If we find a supplier failed to update our spec, it gets noted in their performance score with consideration as to how it affected food safety.  If someone added an allergen without informing us via a spec, they'd be gone.  For minor changes though, we get pushback from our customers and product development alike, as finding a replacement cracker or candy becomes a headache for all involved.

[SQFconsultant]

You said -  And furthermore, they're going to let me know if such changes do take place anyway..

 

So, you just make that your documented requirement of all suppliers - for us and some of our clients it's just written that changes are reported by email to QA (prior to shipping the newly changed items to us) -- we reserve the right to reject.

[foodsafetylady1]

We include an acknowledgement form stating that the supplier will let us know if the following changes occur:

• Changes that may affect the safety, quality, security, shelf life, ingredient statement, allergen profile nutritional labeling or functionality of material produced for XXX– such as changes in materials, formula, raw materials, production line, manufacturing location or processes. XXX must be notify of such changes in writing
• Routine and non-routine Regulatory Authority investigations, testing sampling, reporting or other contact or action with the potential to affect material produced for XXX.
• Any event that leads the supplier to suspect that a non-conformance (specification, regulatory, etc.) exists in product already shipped to XXX.
• Any change to a supplier’s processes, manufacturing facilities and/or sourcing of ingredients that could have an impact on materials supplied to XXX.
• If any of the supplier sites manufacturing materials and ingredients lose their GSFI certification.

 

[GMO]

Agree with posts above.

 

At the sign off of any agreements, I get the suppliers to agree to inform us in advance of any changes likely to impact food safety or formulation and give examples of active changes, e.g. changes of supplier to them but also more passive changes which include informing about seasonal variability.

[MDaleDDF]

Thanks yall.    I drafted an email to send out and I'll add it to supplier evaluation process.    You guys rock.

[G M]

The code states we shall "require" our suppliers to notify us of ingredient changes, so we do.  It's in the supplier requirements form I make them all agree to, so they're now "required' to update us when anything changes.  Do they?  Not always.  ...

 

This is the way.  Just make it part of the contract.  If you word it innocuously enough no one is going to think twice about it, and it just blends in with the rest of the boilerplate.

 

Are they going to 100% remember to actually do it -- probably not.  Then you get to use that in your evaluation process for deciding if you keep them or not.

[LostInTheWoods]

I've also seen (non-food companies) insert something into the Terms and Conditions of  POs, either directly or indirectly.. I've been at places that add in the T&C something like, "by accepting this PO, you agree to follow LostInTheWoods, Inc. Supplier Manual, which can be found at <website>."

 

Do they know it's in there? Probably not, but they technically have agreed to it.

[GMO]

I've also seen (non-food companies) insert something into the Terms and Conditions of  POs, either directly or indirectly.. I've been at places that add in the T&C something like, "by accepting this PO, you agree to follow LostInTheWoods, Inc. Supplier Manual, which can be found at <website>."

 

Do they know it's in there? Probably not, but they technically have agreed to it.

 

Yeah I'm never a fan of putting something in just for compliance reasons but for this I support it. At least it gives you some comeback for a claim if they don't.

[LostInTheWoods]

Yeah I'm never a fan of putting something in just for compliance reasons but for this I support it. At least it gives you some comeback for a claim if they don't.

I agree. It's dirty, but it covers you in that plus other disputes.