It is my understanding from SQF that your risk analysis of the vendor and the ingredient determines what requires a COA. Your process parameters can also reduce risk or add to it depending on what you use the item for.
Charles C., what are your thoughts on this avenue of thinking? Thanks!
the SQF9 Standard has -
2.3.4.2 The approved supplier program shall be based on the past performance of a supplier and the risk level of the raw materials, ingredients, processing aids, packaging, and services supplied, and shall contain at a minimum:
i. Agreed specifications (refer to 2.3.2);
ii. Reference to the level of risk applied to raw materials, ingredients, packaging, and services from the approved supplier;
iii. A summary of the food safety controls implemented by the approved supplier;
iv. Methods for granting approved supplier status;
v. Methods and frequency of monitoring approved suppliers;
vi. Details of the certificates of conformance, if required; and
vii. Methods and frequency of reviewing approved supplier performance and status.
2.3.4.3 Verification of raw materials shall include certificates of conformance, certificates of analysis, or sampling, and testing. The verification frequency shall be identified by the site.
As I read the above -
(a) SAP / 2.3.4.2 (vi) is ambiguous regarding certificate of conformance (note - not analysis), (ie when is it not required ? eg Only for Contractual reasons ?)
(b) Verification / 2.3.4.3 permits absence of COC, COA if replaced by sampling and testing.
The current SAP Guidance does not refer to COC or COA but is also IMO not compliant with the Standard's text, eg -
[SAP] It may be based on the risks presented by the material/input or based on historical performance or prior history of the supplier to the site.
- - - - - - -
Supplier assessment should be risk-based and may be as simple as a good supply history, sourcing from certified suppliers (e.g., SQF certified suppliers)
or personally auditing/inspecting the material supplier’s operations, depending on risk, supplier knowledge and past history.
(Words matter )
Regardless of the above I get the impression from previous threads that SQF auditors normally require to see COAs.. Hence my request in Post 6
PS - JFI, BRC8 has -
The company shall have a procedure for the acceptance of raw materials and primary packaging on receipt based upon the risk assessment (clause 3.5.1.1). Acceptance of raw materials (including primary packaging) and their release for use shall be based on either one or a combination of:
• product sampling and testing
• visual inspection on receipt
• certificates of analysis (specific to the consignment)
• certificates of conformance
.
Edited by Charles.C, 14 June 2021 - 09:22 PM.
aded PS