Good day,
I am needing some assistance/clarity regarding subcontracted activities vs supplier of services.
We produce food contact packaging and I need to better understand how the activities below fall into either 3.9 or 3.10.
- We have a 3rd party on site that is hired to perform our cleaning and maintaining our facilities. They are not allowed to touch any production equipment or are involved with the actual production of packaging material. Their focus is the premises and our employees maintain the production area.
- We use a staffing agency for temporary staff, mainly for jobs that don't require a lot of skill or are not part of the process that create the package itself, but to fill in gaps until a permanent employee can be hired.
- I was just informed that we have hired a 3rd party contracting firm to begin taking over some of our maintenance functions, including some possibility of handling some portions of the packaging process, but all activities will remain on site.
Currently, 3.9 was not applicable to us since we didn't subcontract any process step or have any of our processes outsourced.
Based on the definition that BRC provides:
A firm, company or individual carrying out a process step on intermediate products on behalf of the site being certificated to the Standard
- Does #3 change the applicability of 3.9 to us? What functions would be an example from a maintenance perspective that would make them part of the process step?
- Many of the requirements in 3.9 are referencing outsourced or processes taken off site, but what if it is still on site like #3 situation?
- How can I better explain the difference between staffing agency being a subcontracted service (3.10) vs subcontracted process (3.9)?
- I am constantly being challenged regarding subcontractors being no different then using a temporary agency or using Terminix to monitor our pest management.
Any assistance would be greatly appreciated!!