9. Requirements for Traded Products
9.1. Product Design/Development
FUNDAMENTAL
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Clause 9.1.1
The company shall have a documented supplier approval procedure which identifies the process for initial and ongoing approval of suppliers and the manufacturer/processor of each product traded. The requirements shall be based on the results of a risk assessment which shall include consideration of:
Clause 9.1.2
The company shall have a procedure for the initial and ongoing approval of manufacturers of products. This approval procedure shall be based on risk and include either one or a combination of:
Clause 9.1.3
Records shall be maintained of the manufacturer's/packer's approval process, including audit reports or verified certificates confirming the product safety status of the manufacturing/packing sites supplying the products traded. There shall be a process of review and records of follow-up of any issues identified at the manufacturing/packing sites with the potential to affect food products traded by the company.
Clause 9.1.4
There shall be a process for the ongoing review of manufacturers/packers, based on risk and using defined performance criteria, which may include complaints, results of any product tests, regulatory warnings/alerts, customer rejections or feedback. The process shall be fully implemented.
9.2. Product Inspection and Laboratory Testing
FUNDAMENTAL
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Clause 9.2.1
Specifications shall be available for all products. These shall either be in the agreed format as supplied by the customer or, where this is not specified, include key data to meet legal requirements and assist the customer in the safe usage of the product.
Clause 9.2.2
The company shall seek formal agreement of the specifications with relevant parties. Where specifications are not formally agreed, the company shall be able to demonstrate that it has taken steps to ensure formal agreement is in place.
Clause 9.2.3
Companies shall operate demonstrable processes to ensure that any customer-specified requirements are met. This may be by inclusion of customer requirements within buying specifications or by undertaking further work on the purchased product to meet the customer's specification (e.g. sorting or grading of product).
Clause 9.2.4
Specification review shall be sufficiently frequent to ensure that data is current or at a minimum every 3 years, taking into account product changes, suppliers, regulations and other risks.
9.3. Product Inspection and Laboratory Testing
FUNDAMENTAL
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Clause 9.3.1
The site shall have a product sampling or assurance programme to verify that the products are in accordance with buying specifications and meet legal and safety requirements.
Clause 9.3.2
Where verification of conformity is provided by the supplier (e.g. certificates of conformity or analysis), the level of confidence in the information provided shall be supported by commissioning periodic independent product analysis.
Clause 9.3.3
Where claims are made about the products being handled, including the provenance, chain of custody and assured or ‘identity preserved' status of a product or raw materials used, supporting information shall be available from the supplier or independently to verify the claim.
Clause 9.3.4
Where the company undertakes or subcontracts analyses which are critical to product safety or legality, the laboratory or subcontractors shall have gained recognised laboratory accreditation or operate in accordance with the requirements and principles of ISO 17025. Documented justification shall be available where non-accredited test methods are used.
Clause 9.3.5
Test and inspection results shall be retained and reviewed to identify trends. Appropriate actions shall be implemented promptly to address any unsatisfactory results or trends.
9.4. Product Inspection and Testing
FUNDAMENTAL
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Clause 9.4.1
The company shall have documented processes to verify the legality of products which are traded. These processes shall include as appropriate:
9.5. Product Labelling
FUNDAMENTAL
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Clause 9.5.1
The site shall maintain a traceability system for all batches of product which identify the last manufacturer or, in the case of primary agricultural products, the packer or place of last significant change to the product. Records shall also be maintained to identify the recipient of each batch of product from the company.
Clause 9.5.2
The company shall test the traceability system at least annually to ensure that traceability can be determined back to the last manufacturer and forward to the recipient of the product from the company. This shall include identification of the movement of the product through the chain from the manufacturer to receipt by the company (e.g. each movement and intermediate place of storage).
Clause 9.5.3
The traceability test shall include the reconciliation of quantities of product received by the company for the chosen batch or product lot. Traceability should be achievable within 4 hours (1 day when information is required from external parties).