FIVE supplier questionnaire mistakes…
There have been a few subtle changes to how you can use supplier questionnaires in version 7 of the BRC. I’m going to go through 5 common mistakes, which cause non-conformances. I’ve also provided you with a free checklist which you can use to help you check your supplier questionnaire system, to make sure you’re not at risk of a non-conformance.
Common Mistake 1:
Using a supplier questionnaire for non-low risk suppliers.
In version 7 it now states that you can only use a supplier questionnaire to approve your low risk suppliers. This means your supplier risk assessment must include a method which determines which of your suppliers are low risk and which are not low risk. To do this the BRC suggest that your risk assessment can take into account your history of trading with the supplier and also the nature (inherent risk*) of the raw material. They provide an example of salt – where the inherent risk associated to it is low, essentially because of the low likelihood of micro growth. Make sure that your supplier risk assessment has a method which takes into account the historical trading relationship/performance and also the inherent risk of the raw material supplied. It must also clearly determine which suppliers are low risk and so can be approved through a supplier questionnaire. If previously you’ve approved all of your suppliers through questionnaire, you need to make sure that any suppliers that are no longer low risk – that you have evidence of their approval by other means before your BRC audit (such as a certificate).
* we explain inherent risk in a previous post about raw material risk assessment – you can read about that here.
Common Mistake 2:
Not verifying the supplier questionnaire once returned
Once a supplier questionnaire is returned, it needs to be checked. Checked to make sure that’s it has been completed sufficiently and also checked to make sure it passes. In order to establish if a supplier passes though, you need a process. If a supplier states no, that they don’t have a particular system, or record, is that ok – or not? Once checked, do you have a sign off box to say that it’s been checked and approved or not approved? If not approved, make sure there is a box to allow documentation of what is going to happen next. The standard now states that the questionnaire must include enough information for the site to make a confident decision on the results from the supplier. So checking of the questionnaire is key.
The BRC also state for supplier audits you must assess product safety, traceability, HACCP review and GMP. Given that a supplier questionnaire is a form of audit, which is taken by your suppliers, it is likely that auditors will be looking for this type of information to be assessed in your questionnaire. These are also key elements that need checking when the questionnaire is returned, so make sure it’s part of your approval criteria.
Common Mistake 3:
Not completing the traceability requirement
Version 7 now states that you must verify the suppliers traceability system if you are approving them using a supplier questionnaire. Unfortunately, BRC haven’t put this requirement in clause 184.108.40.206 where it talks about approval of suppliers. They’ve put it in the traceability section, so it can be easily overlooked (clause 3.9.3).
It states that you must check that the supplier’s traceability system is effective. You can do this by carrying out a traceability test, asking the supplier to provide evidence of one of their own traceability tests or they can provide you with a detailed explanation of how their traceability system works.
Verification of their traceability system needs completing prior to approval and also every 3 years as a minimum. Make sure that where you’ve used just a supplier questionnaire to approve a supplier, that you’ve got evidence of the verification of their traceability system too.
Common Mistake 4:
Forgetting to include allergen information
This only applies really if you’re making an allergen claim on pack, such as gluten free. But if you are, you need to obtain additional allergen information from your suppliers. The aim being, that you must know not only what allergens are contained in the ingredient, and what cross contamination risks there are, but where there are cross contamination risks you need to be confident that the supplier is managing these effectively. To do this, BRC suggests you either audit your supplier or you ask for additional information on supplier questionnaires about their allergen management system.
Common Mistake 5:
Forgetting to re-issue a supplier questionnaire
The standard states that a supplier questionnaire must be re-issued every 3 years as a minimum. It also states that you must inform your suppliers that they must tell you if there are any significant changes to the production of your ingredient. Make sure that you have a statement explaining this on your supplier questionnaire, preferably just above the supplier sign off section. You don’t need to get your supplier to re-complete the questionnaire, you can send them the one you have on file and ask them to check it.