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We’ve arrived at the top of the NCN list!

This week we bring you the TOP BRC non-conformance in audits since the launch of version 7.

Supplier approval and monitoring is now the No. 1 non-conformance received by sites, since the launch of version 7. Traceability is now No.2 non-conformance, however one of the clauses in the traceability section, is actually linked to supplier questionnaires, so sits within the supplier approval process too. In this week I’ll cover both, so you can check your system and make sure you’re not at risk of getting these non-conformances on your audit.

I’ve provided you with a check sheet in this post to help you carry out traceability exercises with your suppliers, to meet the standard for low risk suppliers. The non-conformances we will cover in this section are relating to the below clauses:

CLAUSE

3.5.1.1

3.5.1.2

3.9.3 (new clause)

AREA OF COVERAGE

Raw material risk assessment

Supplier risk assessment

Traceability approval of low risk suppliers

NCN SITE %

16.1%

17.8%

10.3%

Clause 3.5.1.1 – Raw material risk assessment

We’ve covered this a number of times before, so I’m not going to go into detail on this clause.  This section now expects the raw material risk assessment to cover 2 new elements, which are:

  1. Fraud
  2. Packaging

Packaging must be included in the raw material risk assessment.  To find out more about raw material risk assessments you can read a previous post:

Food fraud also needs to be included, however I would recommend that you cover food fraud as part of section 5.4 Product Authenticity, Claims & Chain of Custody.  To learn more about how to comply with the food fraud assessment (otherwise known as vulnerability assessment), you can read our previous posts:


If you would like some help putting your vulnerability assessment together, we have published methodology, eLearning and documentation available instantly.  You can check them out and see how much they can help you here:

Clause 3.5.1.2 – Supplier risk assessment

There are a couple of elements which are new to this section, which are tripping sites up, these are detailed below.

Supplier Risk Assessment – The main non-conformances in this area are due to the fact that the risk assessment carried out is not comprehensive enough.  I’ll explain how you can make sure your risk assessment is detailed enough to comply…

Each supplier must be risk assessed, against certain elements. Remember a raw material risk assessment and a supplier risk assessment are different, so ensure that you have both!

A raw material risk assessment looks at the risks involved with the raw material itself (the risk of Salmonella in egg for example), whereas a supplier risk assessment looks at the risks due to a particular supplier supplying you with the raw material(s).

The risk assessment for your suppliers needs to assess the ability of the supplier to provide and deliver the raw materials to the specification agreed, therefore you could assess them on things like:

  • Delivery performance
  • Non-conformances – either from delivery issues or complaints due to the raw material
  • Volume of raw material used
  • The inherent risk of the raw material supplied

supplier risk assessmentThe volume of raw material is a key element.  Flour may be a low risk ingredient – from a microbiological point of view, however if you are a bakery it is a key ingredient.  Lack of supply of flour, or a contamination issue in the flour would have a huge impact on the business, therefore you would expect flour to be assessed by a bakery and it not to come out as low risk.

We have documentation packs which meet 3.5 Raw Material & Supplier Approval & Monitoring and provide you with both a raw material risk assessment and supplier risk assessment systems, plus supplier questionnaires that you can just pick up and use.  Our Bells & Whistles pack even provides you with loads of examples for your raw material risk assessment and goods in systems that you can use.

Scope of the Supplier Audit or Questionnaire

You need to ensure that where you have determined through risk assessment (as above) that an audit or a supplier questionnaire is required to approve or monitor your supplier, you must ensure that the scope of your audit or questionnaire covers:

  • Product safety
  • Traceability
  • HACCP review
  • Good manufacturing practices

The above are new requirements to the standard, so take a look at your audit scope or your questionnaire and make sure that they cover all of the elements above.  It would be a good idea to ensure that they are formatted so that the above titles are used – your auditor will like to see the exact wording from the standard.

I have a couple of other posts that will help you in this area as well, that you can read:


You also need to make sure that if you do supplier audits, that you use a competent auditor.  The BRC does not say that your auditor needs to have formal qualifications (such as lead assessor) however, you need to be able to prove that they are competent.  This is clearly very difficult without any evidence.  One way of doing it, is to have a formally qualified individual shadow your auditor on an audit to assess them and provide them with a certificate if they prove to be competent.

Clause 3.9.3 – Traceability approval of low risk suppliers

BRC have now stated that a supplier questionnaire is only acceptable for approval and monitoring of low risk suppliers.  In addition to this; they have added a new requirement to version 7, where you have to conduct a traceability exercise with all of your low risk suppliers as part of the approval and monitoring.  Unfortunately, rather than putting this in with the supplier approval and monitoring requirements, they have decided to put it in the traceability section – I think this may be why it’s getting missed.

Go through all of your suppliers which have been approved using a supplier questionnaire and make sure you’ve carried out a traceability exercise with them.  This can be a desktop exercise, but you do need to review the information and ‘approve’ the test.  To help you with this I’ve provided you with a traceability check sheet, that you can provide to your suppliers, so that they present the traceability test to you in a way in which you can easily check it and review it.

Finally just behind the top NCN is…

Clause 3.9.1 – Traceability

The second most common NCN since V7’s release is clause 3.9.1.  This isn’t a new clause, but sites are still getting non-conformances because they are forgetting to include traceability of work in progress materials, re-work and packaging.

One way of making sure that this doesn’t get missed, is firstly to carry out a full review, to make sure all elements are covered and then, you could include a question on your routine GMP audits – to check the product being produced at the time – are processing ingredients, rework, WIP and packaging being traced.  Also don’t forget to trace WIP packaging, such as baking paper or plastic sheets on trays.

9 Comments

  • Clem Griffiths says:

    I captured product safety, traceability and HACCP under one grouping called QA Core Competency but I am not sure what elements of product safety are to be considered here.

    • Kassy Marsh says:

      Hi Clem
      Ok, I’ll try to help – can you please give me a bit more context? Newsletter 26 covered quite a lot of topics, so which topic are you referring to?
      Thanks
      Kassy

    • clement griffiths says:

      This is the Supplier audit questionnaire. I have suppliers who are manufacturers, others are distributors and again there are some who import bulk as in spices then re-package in retail units.
      For standard manufacturers the path Is clear, for distributors I believe their DC,s should at least be HACCP certified and for the distributors that also handle or transform ingredients they should be GFSI or subject to a 3’Rd party Food safety audit .
      For each of these 3 levels of suppliers I am also interested in understanding if they have the skill set in place to handle food safety issues.
      I am in Canada and we love your site.

      • Kassy Marsh says:

        Hi Clem
        I’m glad you love the site – hello from the UK! 🙂
        There is no set standard from BRC which defines what type of HACCP qualifications HACCP team members should have, whether they are at manufacturer or distributor level, they just must be ‘competent’. If the site has a GFSI approved certificate, you can rely on this, to have audited the HACCP teams competency. For other sites, you could request a copy of their CCP summary, a copy of team and possibly even evidence of their teams training. However, it is up to you to specify what you feel comfortable with, as there are no rules to go with. Your ability to request this information from your suppliers will obviously depend on the quantity of product that you purchase from them – because if you’re a small customer to them, it will be a lot of work for them…
        I hope I’ve answered you question, if there is anything I’ve missed, please just let me know!
        Thanks
        Kassy

  • Clem Griffiths says:

    Sincere thanks for your time and feedback.

  • Diana Plakan says:

    hello

    first of all, thank You so much on such in-depth explanation (at the same time very simple one) for different BRC standard demands. We have implemented quite similar system of supplier approval and it seems working well for us. But now we are tackling quite different problem which relates to clause 3.5.1.3. regarding knowing the identity of original manufacture. We are BRC certified (against Food safety standard) production company but we are also trading some raw materials. Recently we have been approached by our customers who are asking to disclose to them original manufacture of eached traded goods and provide them with original specification (so far we were issuing our own spec based on original manufacture specification). We were not disclosing original manufacture info nor providing original specs by explaning that we are BRC certified . But now if i read standard precisely it it said that : Information to enable the approval of the manufacturer, packer or consolidator, as in clause 3.5.1.2, shall be obtained from the agent/broker or directly from the supplier, unless the agent/broker is themselves certificated to the BRC Global Standard for Agents and Brokers.
    So should we be then certified against BRC standard for agent and brokers additionally or being certified against Food Safety Standard should be sufficient and we can still use that as a reason for not disclosing our original suppliers?
    I would appreciate Your help and clarification on the matter!

    • Kassy Marsh says:

      Hi, thank you for joining in the discussion and for asking your question. You are correct, your current BRC Food Safety audit would not cover your traded goods, as they are not manufactured at your site and therefore they would be out of the scope of your audit. However, you don’t need to BRC Agents and Brokers as well – as BRC have very kindly brought out a module that you can add to your Food Safety audit, called Traded Goods. This module allows your traded goods to be added to the scope of your Food Safety audit. You can then provide this to your customers.
      I hope that helps, if you have any more questions please add them to the comments.
      Thanks, Kassy

  • Diana Plakan says:

    Dear Kassy!
    Thank You very much for Your response. During last audit our auditor did propose to us to take voluntary module Traded Goods as well, though at that point we did not find it nessesary. What make it more difficult for us as traded goods are materials we are using in our own production or re-selling to customers. So those materials are in fact covered by our HACCP plan, regarding supplier approval/specification approval we are also following BRC Standard. It should give assurance to customer about safety of the materials and in my mind in order for them to make them their own risk assessment it is not nessesary to obtain all info about original manufacture as all risks are already handled by ourselves.

    • Kassy Marsh says:

      I see your point, however the scope of your HACCP will probably cover your finished product in the product description? Therefore, it wouldn’t cover the traded goods. Plus, you would need to process them in some way (such as repacking) in order for them to be covered by your BRC Food Safety audit scope. I would recommend the traded goods module, so you can be confident that you’re covered.
      Good luck with it, and please let me know how you get on?
      Thanks
      Kassy

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