|
The case against SAQs.
11/01/22 |
|
The use of supplier assessment questionnaires (SAQs) is ubiquitous throughout the food industry, but in many cases there is no benefit to SAQs for supplier approval decision-making and in fact the habitual use of SAQs for supplier assurance processes can expose food businesses to compliance risks.
This article refers specifically to SAQs in the context of BRCGS compliance, but the principals discussed may have relevance to other compliance schemes.
This article refers specifically to SAQs in the context of BRCGS compliance, but the principals discussed may have relevance to other compliance schemes.
Compliance with clause 3.5.1.2
Clause 3.5.1.2 of the BRCGS Food Standard version 8 lists 3 approaches for supplier approval:
- Valid certification to a GFSI-benchmarked scheme.
- Supplier audits.
- Questionnaires.
While the 3 approaches to supplier approval are not explicitly ranked in order of preference, it is noteworthy that the only stipulation attached to GFSI-benchmarked certification is that the certificate must be valid (must not be expired), whereas supplier audits and questionnaires are subject to a number of conditions in order to present an acceptable basis for supplier approval. This implies that the BRCGS considers certification to a GFSI-benchmarked standard to be the most robust basis for approval.
It is particularly important to acknowledge that the standard states that one or a combination of these approaches to approval may be used – meaning that either certification to a GFSI-benchmarked standard or supplier audits are sufficient by themselves and there is no requirement for an SAQ if either of these methods of approval are used.
It is particularly important to acknowledge that the standard states that one or a combination of these approaches to approval may be used – meaning that either certification to a GFSI-benchmarked standard or supplier audits are sufficient by themselves and there is no requirement for an SAQ if either of these methods of approval are used.
Conditions for acceptability of SAQs
In order for an SAQ to present an acceptable basis for supplier approval, the following conditions must be met:
This is very important, because if any of the above conditions are not met then the completed SAQ will not be considered an acceptable basis for approval.
From a compliance perspective, the conditions placed on the acceptability of supplier assessment questionnaires is deceptively problematic. In particular…
Any site using SAQs for approval decisions might undertake an assessment of a supply site with the best of intentions and with an approach consistent with the spirit of the standard… yet find that they are unable to present acceptable evidence at audit.
- The supplier must be identified as low risk, and a valid risk-based justification must be in evidence.
- The scope of the questionnaire must include product safety, traceability, HACCP review and good manufacturing practices.
- The SAQ must be reviewed and verified by a demonstrably competent person.
This is very important, because if any of the above conditions are not met then the completed SAQ will not be considered an acceptable basis for approval.
From a compliance perspective, the conditions placed on the acceptability of supplier assessment questionnaires is deceptively problematic. In particular…
- No qualifiers are provided as to the validity of a risk-based justification that the supplier is low risk. In this case, the validity of the risk-based justification relies on the auditor’s subjective opinion rather than objective criteria.
- No qualifiers are provided as to the demonstrable competency of the person reviewing the completed questionnaire. It is unclear what would qualify an individual to review completed SAQs.
- The reviewer of the SAQ must both ‘review’ and ‘verify’ the questionnaire, with the standard listing these as separate activities. There is a degree of ambiguity over how the standard distinguishes between the review and verification of questionnaires, or how this could be evidenced at audit.
Any site using SAQs for approval decisions might undertake an assessment of a supply site with the best of intentions and with an approach consistent with the spirit of the standard… yet find that they are unable to present acceptable evidence at audit.
The compliance risk
The approval procedure shall be based on risk and include either one of a combination of the 3 methods of approval (certification to a GFSI-benchmarked scheme, supplier audits, and questionnaires).
If you can demonstrate that a supplier is certified to a GFSI-benchmarked scheme and you have no other evidence in support of the decision to approve that supplier, then there is compliance with the standard.
Conversely, if you can demonstrate that a supplier is certified to a GFSI-benchmarked scheme and you also present the auditor with an SAQ for that supplier, then the certificate and SAQ will be taken in combination and a non-conformity may be issued if any of the conditions attached to the acceptability of the SAQ are not met. Presenting an SAQ as evidence of supplier assurance can actually expose the QMS to non-conformity at audit, despite the supplier being certified to a GFSI-benchmarked scheme.
If you can demonstrate that a supplier is certified to a GFSI-benchmarked scheme and you have no other evidence in support of the decision to approve that supplier, then there is compliance with the standard.
Conversely, if you can demonstrate that a supplier is certified to a GFSI-benchmarked scheme and you also present the auditor with an SAQ for that supplier, then the certificate and SAQ will be taken in combination and a non-conformity may be issued if any of the conditions attached to the acceptability of the SAQ are not met. Presenting an SAQ as evidence of supplier assurance can actually expose the QMS to non-conformity at audit, despite the supplier being certified to a GFSI-benchmarked scheme.
In summary
Supplier assessment questionnaires are often thought of as belt-and-braces for evidence of supplier approval but using SAQs where they are not required can actually expose food manufacturers to compliance criteria that would not otherwise have applied.
SAQs are arguably the least stringent basis for supplier approval because they rely on self-reporting, and this can present a conflict of interest.
BRCGS considers certification to a GFSI-benchmarked scheme or supplier audits to be satisfactory for approval independent of SAQs (provided the conditions for acceptable supplier audits are met). Far from providing extra assurance, the use of SAQs in the context of either of those approval parameters can actually expose food manufacturers to risk of non-conformity at audit.
While there are occasions where commercial availability of raw materials can necessitate sourcing ingredients from suppliers that are not certified to a GSFI-benchmarked food safety standard and there may be factors that make 1st party audit impractical, these are exceptional circumstances and there is no need to universally subject all suppliers to assessment by questionnaire.
SAQs are arguably the least stringent basis for supplier approval because they rely on self-reporting, and this can present a conflict of interest.
BRCGS considers certification to a GFSI-benchmarked scheme or supplier audits to be satisfactory for approval independent of SAQs (provided the conditions for acceptable supplier audits are met). Far from providing extra assurance, the use of SAQs in the context of either of those approval parameters can actually expose food manufacturers to risk of non-conformity at audit.
While there are occasions where commercial availability of raw materials can necessitate sourcing ingredients from suppliers that are not certified to a GSFI-benchmarked food safety standard and there may be factors that make 1st party audit impractical, these are exceptional circumstances and there is no need to universally subject all suppliers to assessment by questionnaire.
|
Author: Duncan Lacey - Director of Innovation, Food Portal
Duncan Lacey | LinkedIn |
|
We hope you've enjoyed this article. We want you to feel welcome to take advantage of our other free services:
|
The Food Portal supplier directory offers all food manufacturers the ability to upload assurance evidence to their company profile, which they can share with their customers. No more having to email all your customers at every accreditation renewal!
|
The Food Portal Library is a free signposting service, connecting food industry professionals with a comprehensive range of resources from major information providers throughout the global food industry.
|
