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primary packaging vs secondary packaging

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sean_as

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Posted 17 October 2024 - 09:49 PM

Hi Guys

 

Can someone please shed some light on this if they can. We got audited and got a CAR for using a supplier who isn't GFSI accredited (they only have ISO). Now this supplier only supplies us egg trays/fillers (different names around the world).

 

I was under the impression that it's not necessary a direct contact as egg is still in a shell therefore it wouldn't be that critical to have a more stringent food certification compared to say a vacuum pack bag/liner which directly contacts a meat product. Can someone brief me on how to go about explaining this to an auditor as i don't think our supplier will be willing to get a Gfsi accreditation such as BRC, fssc or sqf at this stage just for us. We have done all the risk assessments & the likelihood of any contamination (micro, phyical, chemical, allergen) has been deemed as low.



SQFconsultant

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Posted 17 October 2024 - 11:08 PM

What standard were you audited under and did the supplier in question qualify per your own supplier approval policy/program?

 

Did the supplier provide you with a copy of their non GFSI Audit?


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sean_as

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Posted 18 October 2024 - 12:38 AM

We were audited against the Coles Standard (Australian standard) which pretty much rivals some of the best GFSI standards. When we did our own supplier approval process on this supplier, we deemed them to be ok to use after having done all necessary risk assessments.

 

They only have ISO 9001 accreditation



Alessandro412

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Posted 22 October 2024 - 02:10 PM

Hi! Is in the Coles standard a requirement stating all the primary packaging suppliers should be GFSI certified? If not, is it in your buying procedure? If both of these are no then there should be no reason for a NC in my opinion.

 

A supplier audit by your company could maybe work if documented right in your internal procedures. 

 

We have stated that primary packaging is everything a consumer takes to their house when its bought.



G M

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Posted 22 October 2024 - 06:39 PM

As a customer audit, what code or requirement did they cite for the non compliance?  Specific wording.

 

Some times it doesn't matter if it makes sense, if their code says X, that's what you do.  Unless you get an exemption in writing.



Tony-C

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Posted 23 October 2024 - 05:35 AM

Hi sean_as,

 

Egg shells are porous/permeable, so the packaging would be regarded as primary.

 

A supplier audit by yourself or a competent contracted auditor would cover this off. Typical requirements are for the scope to include product safety, traceability, HACCP review, the product security and food defence plan, the product authenticity plan and good manufacturing practices. If contracted then you need to have proof the auditor was competent and review the full audit report.

 

Kind regards,

 

Tony





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