The company shall have a documented supplier approval and ongoing monitoring procedure to ensure that suppliers are manufacturing products under hygienic conditions, effectively manage risks to raw material quality and safety and are operating effective traceability processes. The approval and monitoring procedure shall be based on one or a combination of:
· supplier audits
· third party audits or certification, e.g. to BRC Global Standards
· supplier questionnaires.
Where approval is based on questionnaires, these shall be reissued at least every three years and suppliers required to notify the site of any significant changes in the interim.
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Given the above, could a facility working toward BRC certification "grandfather" in all existing approved suppliers, as long as the "new" approval and monitoring procedure meets the intent of the clause and there is some documentation that some of the suppliers have been approved according to the "new" approval and monitoring procedure?
This would be a similar situation to the Training clauses. Company "A" has a bunch of employees that have been doing the same job for 20 years, but do not have a piece of paper to show a "documented" training program. Company "A" states that as of a certain date, all employees currently in positions held are deemed "trained and qualified" in that position. However, after that date, all training will have a paper trail of documentation.
As I read the clause above, the only thing that is required (shall) is that the company has a documented supplier and monitoring procedure. It does not say anything about current suppliers needing to be approved according to that specific procedure.
Comments?
Marshall