Clarification of Clause 3.5.1.1
Analysis of the audit data has highlighted that Clause 3.5.1.1 may be misinterpreted. This clause includes the requirement for sites to ‘take into account the potential for substitution and fraud’ (see Clause 5.4.2). The purpose of this reference is to highlight that supplier approval processes must include consideration of any risks highlighted during the vulnerability assessment, such as those identified when completing activities for Clause 5.4.2.
Clause 5.4.2 clearly states that it is only relevant to food raw materials (it does not cover packaging raw materials, so we do not expect supplier approval processes for packaging materials to include an assessment for substitution or fraud). All other requirements of Clause 3.5.1.1 apply to all raw materials (both food and packaging raw materials).
When supplier approval is based upon certification to a GFSI recognised scheme, auditors should be verifying certificates. For example, if a site claims that they are using BRC Global Standards certification, they should be able to demonstrate to the auditor that this can be verified via the BRC Directory; the same process would apply to other Standards such as SQF and IFS.
We will provide a full break down of nonconformity patterns and grading results at the European CB/ATP Conference in London on November 18 and 19 and the results will also be covered in the CB/ATP Americas Conference early next year, when we will have more information.