Raw material and supplier risk assessment
Back in December 2015 we published this article about raw material risk assessment and the changes in issue 7. For Issue 8, BRC have added some additional changes, so I’ve updated the article to include these and bring it up date. The original information and action still stands, so I thought it best to keep it and build on it. I’ve highlighted in the article though, which parts are new for Issue 8.
So, here we go! First let’s break down clause 3.5.1 into its separate parts and explain the aim of each part:
22.214.171.124 – a raw material risk assessment is required, to determine the inherent risk of the raw material. The output of the risk assessment is to produce:
- Goods in acceptance criteria
- The initial raw material assessment, that feeds into the supplier approval & monitoring risk assessment
126.96.36.199 – a supplier approval & monitoring risk assessment, to determine the risk of using that supplier. The output of the risk assessment BRC states is to determine:
- The criteria for how each supplier should be approved
- How the supplier should be monitored
In my opinion there should be a third as well – to start the process of working out what risks are associated with raw materials and therefore risks to the finished product, this information should be used as a base for your HACCP hazard analysis.
188.8.131.52 – that where agents and brokers are used, the manufacturer should be assessed rather than the agent/broker, UNLESS, the agent/broker has a:
- BRC Agents & Brokers certificate (or another comparable GFSI recognised certificate)
- Storage & Distribution certificate WITH wholesale module
- Food Safety certificate WITH the Traded Products module that covers the product you’re buying
- Or, for packaging – a Packaging certficate WITH the traded products module that covers the packaging you’re buying
184.108.40.206 – that exceptions are handled, which means how raw materials are accepted in emergencies where the raw material or supplier has not been approved following the normal process.
Up until Issue 7 was published, it was very common for auditors to ask for a raw material risk assessment and if the site produced a supplier risk assessment then this was deemed acceptable. Since Issue 7, this has not been the case, as auditors now recognise that a raw material risk assessment and a supplier risk assessment are two very different things…
The purpose of a raw material risk assessment is to assess the inherent risks of the raw materials. This can happen even before the supplier has been decided.
The purpose of a supplier approval & monitoring risk assessment is to take the output from the raw material risk assessment and combine this with the risk of getting that raw material from a particular supplier.
For example, the raw material risk assessment may determine that raw filleted fish is a high risk ingredient, because of the micro risks from fish and also the possibility of left over bones from the filleting process. The high risk result would then be put into the supplier approval & monitoring risk assessment for each supplier who supplies the fish. One supplier may be really great and therefore they would come out with a lower risk result and another supplier may not be so great and come out with a higher risk result.
The purpose of a raw material risk assessment is to assess the inherent risks associated with purchasing the raw materials, so that controls can be put in place to ensure that this doesn’t impact on production and more importantly on the consumer.
An inherent risk is something that is characteristic of that raw material, a bit like it’s expected that you’ll get a small amount of stones in raw cereals or dried fruit, or salmonella in raw egg. A supplier risk assessment doesn’t assess the inherent risk of the raw materials.
BRC Issue 8 changes…
In issue 8 BRC have added three important changes to this section of the standard, these are:
- Additional inherent hazards
- Constant information inputs
Previously we had to review our risk assessment annually. That’s no longer the case. One of the themes of change in issue 8 is that many frequencies have been removed, as BRC shift to applying a review where something changes. Which makes perfect sense if you think abut it. You don’t wait to change raw materials or suppliers of raw materials until your annual review is due. You do it when you need to. So, your raw material (and supplier) risk assessment should be no different. If you make a change, the risk assessments now need to be reviewed – and this should be done before the change takes place, so any risks involved are managed properly.
Additional inherent risks
So, BRC have added two new risks to consider, these are:
- from legal requirements
- due to species or variety cross contamination
Legal requirements: You should already have any legal requirements built into your raw material risk assessment, so just go back and check you do.
Species or variety: The species and variety requirement, builds on the need to assess vulnerability.
Go through your raw materials and where you’re making a claim about them, due to species or variety as you need to add this to your risk assessment.
For example ‘British’ chicken, ‘Madagascan’ vanilla or ‘Alphonso’ mango.
Now, this is where this gets a little confusing. In issue 7, we were clear that a raw material risk assessment just looks at the risks of the raw materials – not taking the supplier into consideration. We’d then feed the resulting risk, into our supplier risk assessment.
For vulnerability, for species or variety, that’s not purely the case, for two reasons:
1. The location of the supplier may have an impact, e.g ‘British’ chicken or ‘Madagascan’ vanilla
2. The standard refers to species or variety ‘cross contamination.’ So, what other varieties or species your supplier handles will have an impact.
So, what do,we do?
Well, first your raw material risk assessment needs to identify where a claim about variety or species is a risk. The identification of this, should drive a higher risk score, than a material without a claim.
The second thing to do, is when that raw material risk is fed in to your supplier risk assessment, you should in your supplier risk assessment, assess the risk of cross contamination. Let’s work through an example:
You’re buying Alphonso mango from both supplier A and also, from supplier B.
Alphonso mango has a claim so it’s a higher risk. Supplier A only handles Alphonso mango and doesn’t handle any other types of mango. Whereas supplier B handles lots of varieties of mango. Therefore, the risk of supplier A sending you the wrong species, is much less than supplier B. This should increase and reduce the risk from those suppliers accordingly.
In my opinion, we should also be highlighting as a minimum, where meat is used – as a risk. Although cross contamination of one fruit with another is not good (and so we should control it in the same way in principle too), cross contamination of one meat with another is a definite no-no. So, I would carry out a similar risk assessment exercise in my supplier risk assessment for all meat suppliers – to establish if there’s a risk of cross contamination of one meat with another.
Constant information inputs
This is another theme of change for Issue 8; where we now need to listen, and act upon, what’s happening outside of our site.
We need to proactively use external information to our benefit. So, if a recall happens you can learn from it. This means, we need to have sources of information coming in to us. We then need to have a process of logging it, reviewing it and where needed, take action. This doesn’t need to be complicated, a couple of simple email folders called ‘action required’ and ‘no action required’ is sufficient. Just make sure the process and who’s responsible for it, is captured in your procedure. So now, make sure you go through these changes and make all of the necessary amends to your procedure.
We have a downloadable e-documentation pack for Raw Material & Supplier Risk Assessment, which includes everything you need for raw material and supplier approval. It’s compliant with all of the GFSI recognised schemes, including issue 8 and also covers traded products. It also meets the requirements for supplier risk assessment for the FDA’s FSMA rule. Click the link below to view this, you can also order online.
If you have any comments you can share or queries, please add them to the reply box below. Please note, I’ve left the conversation from issue 7 in the comments below, as the comments are still relevant and could be useful to you.
We’ve created a really handy cheat sheet to help you approve suppliers that are sending you certificates for schemes that they are accredited by. This should make it easier for you to understand. It might brighten up your office space too and it’s a great way to see boring information you can digest more easily!
If you’d like one, just complete the form below and we’ll email it to you. You will then be added to our BRC Material & Supplier Approval list so we can update you about our solutions for this area of compliance with BRC Issue 8.