Using raw materials before getting a CoA from approved suppliers
We frequently get raw materials before obtaining a Certificate of Analysis (CoA).
Interested in hearing how others handle this situation. These are trusted suppliers who typically provide the CoA to us within the week. Do you proceed with using the raw materials before getting a CoA, or do you place them on internal hold until the CoA is received?
For reference we are located in Australia, under SQF.
Cheers,
Hi Nicholas,
Whether to hold would depend on the criticality of the ingredient.
If it was an ingredient where the hazard was removed by the process, I would be less concerned about using it before receiving the COA.
If it was a material that went in your final product without any step that removed or reduced a known potential hazard then I would definitely be holding until the COA was received and probably do some random sampling of the material.
Either way it would be best if you could manage your stock so the COA was received before use unless this wasn't practical because the material is perishable with a limited life.
Kind regards,
Tony
It might be an unpopular opinion, but I don't find much value in COAs, LOGs, etc.
extreme example:
https://www.foodsafe...ent-a-timeline/
Decades ago (HACCP revolution) the industry decided that sampling and testing was a poor way to ensure food safety. For the same reasons, I'm not sure what assurance a COA gives. I once received 13 page list of lots being recalled by an ingredient supplier that "stood by their COA results"
It might be an unpopular opinion, but I don't find much value in COAs, LOGs, etc.
extreme example:
https://www.foodsafe...ent-a-timeline/
Decades ago (HACCP revolution) the industry decided that sampling and testing was a poor way to ensure food safety. For the same reasons, I'm not sure what assurance a COA gives. I once received 13 page list of lots being recalled by an ingredient supplier that "stood by their COA results"
Unfortunately whether they're valuable or not, it's a requirement to have a COA for raw materials used in product by our SQF certification.
I do see their value when they can give details that assist in product use, for example milk and butter, knowing the fat percentage without having to personally do it can be convenient. Regarding food safety I do understand why some regions supply a specification/PiF and a certificate of guarantee of compliance with the provided specs.
Hi Nicholas,
Whether to hold would depend on the criticality of the ingredient.
If it was an ingredient where the hazard was removed by the process, I would be less concerned about using it before receiving the COA.
If it was a material that went in your final product without any step that removed or reduced a known potential hazard then I would definitely be holding until the COA was received and probably do some random sampling of the material.
Either way it would be best if you could manage your stock so the COA was received before use unless this wasn't practical because the material is perishable with a limited life.
Kind regards,
Tony
Hi Tony thanks for the reply.
Good point bring up whether or product non compliance would present a hazard.
Unfortunately some situations with the difficult of getting certain materials, were wanting to use it as soon as it arrives onsite, but conducting risk assessments based on the above would be a helpful exercise.
Cheers.
The COA provides crucial information regarding the quality and composition of the raw materials. It assures us that the materials meet the required specifications and comply with industry standards. This is vital in ensuring the consistency and integrity of our products. I would like to emphasize the importance of conducting internal tests on these raw materials as well. While the COA provides valuable information, our internal tests enable us to further evaluate the quality of the materials and ensure they meet our specific requirements. These tests give us an added layer of confidence in the materials we use.
IN my time I've had two ingredients recalled due to path. Unfortunately neither said so on the COA..... lol.
I tend to agree with Kingstudruler. The talk of others on here about the 'confidence' you have due to that piece of paper is great, but it's false confidence. As soon as there's an issue, it won't be on your COA....
That said, unfortunately I also agree that it's a requirement to the standard.
My suppliers are often a little late with COA's, but generally I have them before product is being run. If it were the day of a product run and I needed to use the ingredient, I'd weight sitting on it vs potential fallout. It would depend on the ingredient, past performance, etc.
There is a no requirement for COAs for every load in the SQF standard. The wording is below. If your procedure says you are not going to receive products without a COA, then don't receive them. If it says you don't use them without a COA, don't use them. Or change your procedure to account for the actual risk of not having them.
2.3.4.3 Verification of raw materials shall include certificates of conformance, certificates of analysis, or sampling, and testing. The verification frequency shall be identified by the site.
We frequently get raw materials before obtaining a Certificate of Analysis (CoA).
Interested in hearing how others handle this situation. These are trusted suppliers who typically provide the CoA to us within the week. Do you proceed with using the raw materials before getting a CoA, or do you place them on internal hold until the CoA is received?
For reference we are located in Australia, under SQF.
Cheers,
COA and LOG are a lot like the theater at airports. Under the right circumstances it can do what people generally think it is capable of, but experience has proven it misses more often than it works, and we just keep doing it anyway because it makes people "feel safe"
That being said, we have in the past held material until documentation was provided, because safety programs said it was required. Just following the basic food safety and quality mantra of "say what you will do, and do what you said you would".
I think there are many assessments/questions you need to ask your self before you can "trust" a CoA:
- what is the nature of the product? Is it possible to make a homogenous sample?
- what parameters are important for you and your product?
- who has issued the CoA? Is it from a lab which is accredited?
- what type of methods are used?
As mentioned above - based on the type of production you have, if microbiology is important for you, but on the same time you have processes to reduce/remove the risk, then it might not be relevant to take verification samples upon reception of the product/raw material.
I would also suggest that these companies need a different risk rating on your supplier approval program
IF they have agreed to your terms that a CoA must be provided WITH the material and they repeatedly fail to do so, that should be reflected
HOWEVER, it is up to you to determine your own program SO depending on what exactly (as you have not given much detail) the CoA is for, you may or may not chose to receive and HOLD pending disposition determination upon receipt of CoA
We really need more specifics to be of real assistance