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Integrating supplier and raw material risks.
13/08/21 |
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Supplier and raw material risk assessment represent really major systematic challenges to food manufacturers.
- The nature of the technical information requires a specialised field of knowledge to interpret.
- There is a high volume of data being processed, often manually.
- Quality management systems depend on the processed technical information, so supplier and raw material risk assessment information has to be transmitted through instructional and reference documents.
This article examines the process of integrating supplier and raw material risk assessment outcomes into the quality management system, based on the requirements of BRCGS Food V8.
The standard presents supplier and raw material approval as 3 distinct parts:
- Supplier approval.
- Raw material risk assessment.
- Expected outcomes.
Supplier approval
3 acceptable approaches are listed:
Among other things, sites are required to maintain an up-to-date list of approved suppliers and know the identity of the manufacturer or packer. The below is a process flow showing the incorporation of supplier approval information into the QMS:
- Certification to a GFSI-benchmarked standard.
- Supplier audit, contingent on a defined scope, a demonstrably competent auditor, and access to the full audit report.
- Questionnaires, contingent on, a documented risk assessment identifying the supplier as ‘low risk’, a defined scope, review by a demonstrably competent person, and ongoing traceability tests.
Among other things, sites are required to maintain an up-to-date list of approved suppliers and know the identity of the manufacturer or packer. The below is a process flow showing the incorporation of supplier approval information into the QMS:
Interestingly, any of the 3 approaches can be used in isolation – but despite this, many food manufacturers collect supplier assessment questionnaires from suppliers certified to a GFSI-benchmarked standard simply on the basis that (BRCGS) auditors might expect to see questionnaires as approval evidence. For compliance with the BRCGS Food V8 standard, it is sufficient to verify that suppliers are listed on the relevant directory. Approval is based on the supplier’s accreditation, rather than the availability of a particular document.
Also of note, the standard gives a validity period of 3 years to questionnaires before they have to be reviewed (though there is a standing requirement for suppliers to notify in the event of any major changer), while the validity period for audits is not specified. For suppliers based on GSFI-benchmarked suppliers, the validity period isn’t specified but the certificate must be valid.
Also of note, the standard gives a validity period of 3 years to questionnaires before they have to be reviewed (though there is a standing requirement for suppliers to notify in the event of any major changer), while the validity period for audits is not specified. For suppliers based on GSFI-benchmarked suppliers, the validity period isn’t specified but the certificate must be valid.
Raw material risk assessment
Compared with supplier approval, raw material risk assessment is more technically demanding. This is routed in the number of parameters associated with each material, specialist knowledge needed for interpretation, and the number of points of integration with the quality management system.
The standard expects each raw material or group of raw materials to be risk-assessed, taking into account the potential for:
• allergen contamination
• foreign-body risks
• microbiological contamination
• chemical contamination
• variety or species cross-contamination
• substitution or fraud (see clause 5.4.2)
• any risks associated with raw materials which are subject to legislative control.
Consideration must also be given to the significance of a raw material to the quality of the final product.
Unlike with supplier approval, the standard doesn’t dictate methodologies for carrying out the risk assessment, but the risk assessment mut satisfy the requirements of other clauses throughout the standard. This is represented in the following process flow:
The standard expects each raw material or group of raw materials to be risk-assessed, taking into account the potential for:
• allergen contamination
• foreign-body risks
• microbiological contamination
• chemical contamination
• variety or species cross-contamination
• substitution or fraud (see clause 5.4.2)
• any risks associated with raw materials which are subject to legislative control.
Consideration must also be given to the significance of a raw material to the quality of the final product.
Unlike with supplier approval, the standard doesn’t dictate methodologies for carrying out the risk assessment, but the risk assessment mut satisfy the requirements of other clauses throughout the standard. This is represented in the following process flow:
For the purposes of the above diagram, raw material inspection and acceptance processes have not been fully represented because the criteria for acceptance inspections and inspection frequency are contributed to by all of the processes shown. Similarly, supplier performance monitoring should monitor all processes.
Combining supplier and raw material approval
While the standard addresses supplier approval and raw material risk assessment separately, implementation requires that these subjects be combined. Take clause 3.5.1.4, for example:
“The site shall have an up-to-date list or database of approved suppliers. This may be on paper (hard copy) or it may be controlled on an electronic system.
The list or relevant components of the database shall be readily available to the relevant staff (e.g. at goods receipt).
Where raw materials (including primary packaging) are purchased from companies that are not the manufacturer, packer or consolidator (e.g. purchased from an agent, broker or wholesaler), the site shall know the identity of the last manufacturer or packer, or for bulk commodity products the consolidation place of the raw material.
Information to enable the approval of the manufacturer, packer or consolidator, as in clauses 3.5.1.1 and 3.5.1.2, shall be obtained from the agent/broker or directly from the supplier, unless the agent/broker is themselves certificated to a BRC Standard (e.g. BRC Global Standard for Agents and Brokers) or a standard benchmarked by GFSI.”
Producing a list of approved suppliers necessitates associating suppliers with raw materials. Approving the supply of a specific raw material from a certain supplier isn’t a blanket throwing-open of the gates to any material that comes from that supplier. In order to approve the supply of material from a particular supplier, every raw material risk assessment parameter has to be applied to that supply route. This is particularly true of parameters such as allergens and vulnerability to substitution, adulteration, and fraud. The risk assessment outcome is dependant on the supply route, so the two things can’t be taken in isolation.
Acceptance criteria for inspections at goods-receipt presents another example. If there were a list of approved suppliers that was separate and independent of the raw materials for which they had been approved, there couldn’t be a systematic capability for the staff at goods receipt to identify where raw materials had been delivered by a supplier that had been approved for the supply of a different raw material, but not the raw material that had been received. As long as each supplier were approved to supply something, they would be approved to supply anything.
Suppose a medium-sized food manufacturer handles 70 raw material SKUs, across 86 suppliers, and each raw material SKU has a average of 1.9 potential supply routes (taking into account contingency suppliers). Call it in the region of 130 active supply routes.
So if each supply route needs to be risk-assessed for 14 allergens, 5 micro-organisms, 3 chemical parameters, 5 vulnerability factors and a variable number of physical risks, variety/speciation, and legislative risks, then that’s in excess of 3500 individual parameters that need to be processed and incorporated into the quality management system.
Now consider the nature of the outcomes required from the risk assessments. A site’s allergen risk assessment and its vulnerability assessment both need to list all approved supply routes, along with a series of technical parameters that must be accurate and consistent with the raw material risk assessments these documents are based on.
It’s often the case that sites will have inconsistencies in the supply routes expressed across the allergen risk assessment and vulnerability assessment before discrepancies against the raw material risk assessments are event considered – the complexity of the data and the level of duplication across documents makes this a serious weakness in food business’s ability to adequately control this risk information.
Food Portal provides integrated systems for supplier approval and raw material risk assessment, with the automatic generation of version-controlled site controls including: the approved list for purchasing, the allergen risk assessment, the raw material acceptance criteria reference document, the site vulnerability assessment, and raw material surveillance schedules – providing you with confidence that your systems are robust and dependable.
“The site shall have an up-to-date list or database of approved suppliers. This may be on paper (hard copy) or it may be controlled on an electronic system.
The list or relevant components of the database shall be readily available to the relevant staff (e.g. at goods receipt).
Where raw materials (including primary packaging) are purchased from companies that are not the manufacturer, packer or consolidator (e.g. purchased from an agent, broker or wholesaler), the site shall know the identity of the last manufacturer or packer, or for bulk commodity products the consolidation place of the raw material.
Information to enable the approval of the manufacturer, packer or consolidator, as in clauses 3.5.1.1 and 3.5.1.2, shall be obtained from the agent/broker or directly from the supplier, unless the agent/broker is themselves certificated to a BRC Standard (e.g. BRC Global Standard for Agents and Brokers) or a standard benchmarked by GFSI.”
Producing a list of approved suppliers necessitates associating suppliers with raw materials. Approving the supply of a specific raw material from a certain supplier isn’t a blanket throwing-open of the gates to any material that comes from that supplier. In order to approve the supply of material from a particular supplier, every raw material risk assessment parameter has to be applied to that supply route. This is particularly true of parameters such as allergens and vulnerability to substitution, adulteration, and fraud. The risk assessment outcome is dependant on the supply route, so the two things can’t be taken in isolation.
Acceptance criteria for inspections at goods-receipt presents another example. If there were a list of approved suppliers that was separate and independent of the raw materials for which they had been approved, there couldn’t be a systematic capability for the staff at goods receipt to identify where raw materials had been delivered by a supplier that had been approved for the supply of a different raw material, but not the raw material that had been received. As long as each supplier were approved to supply something, they would be approved to supply anything.
Suppose a medium-sized food manufacturer handles 70 raw material SKUs, across 86 suppliers, and each raw material SKU has a average of 1.9 potential supply routes (taking into account contingency suppliers). Call it in the region of 130 active supply routes.
So if each supply route needs to be risk-assessed for 14 allergens, 5 micro-organisms, 3 chemical parameters, 5 vulnerability factors and a variable number of physical risks, variety/speciation, and legislative risks, then that’s in excess of 3500 individual parameters that need to be processed and incorporated into the quality management system.
Now consider the nature of the outcomes required from the risk assessments. A site’s allergen risk assessment and its vulnerability assessment both need to list all approved supply routes, along with a series of technical parameters that must be accurate and consistent with the raw material risk assessments these documents are based on.
It’s often the case that sites will have inconsistencies in the supply routes expressed across the allergen risk assessment and vulnerability assessment before discrepancies against the raw material risk assessments are event considered – the complexity of the data and the level of duplication across documents makes this a serious weakness in food business’s ability to adequately control this risk information.
Food Portal provides integrated systems for supplier approval and raw material risk assessment, with the automatic generation of version-controlled site controls including: the approved list for purchasing, the allergen risk assessment, the raw material acceptance criteria reference document, the site vulnerability assessment, and raw material surveillance schedules – providing you with confidence that your systems are robust and dependable.
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Author: Duncan Lacey - Director of Innovation, Food Portal
Duncan Lacey | LinkedIn |
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