(Section 3.5.1 – with specific reference to clause 3.5.1.7)

It’s almost inevitable that over the coming days and weeks that supply chains of raw materials will continue to be challenged, with normal volumes or normal supply chains unavailable, or with imports from specific countries or regions delayed or periodically not possible. In these circumstances, a site’s raw material buying teams are likely to be working overtime to maintain supply or source alternative materials.

Of course, when doing this it is vital that product safety, integrity and legality systems are rigorous and remain in force, and where there is a need to amend normal approval processes, everyone involved understands the permitted amendments and any limitations.

Certificated food manufacturers should have already thought of this as clause 5.1.7 requires the site to have a plan or procedure to cover instances where normal supplier approval is not possible. So here are our top tips for raw material risk management:

  • Training (section 7.1) – is everyone involved in the process clear on the correct procedures and any amendments?
  • Specifications (section 3.6)– is there a clear specification, does it contain all the relevant information and has it been checked for safety and legality criteria by a competent member of the team?
  • Allergens (section 5.3)– has an allergen risk assessment been completed (section 5.3 of the Standard)? Are the allergens risks the same or are there differences which need to be managed?
  • Hazard analysis/Raw material risk assessment (clause 3.5.1.1) – have both existing and potential new hazards been considered? Include microbiological, physical, chemical, allergens, etc. If the hazards are different, how are the changes to be managed? Consider storage, production scheduling, cleaning, etc. Have any changes been signed-off (clause 5.1.2)
  • Communications – who needs to know? Customers/Brand owners? Others?
  • Food fraud (section 5.4) – unfortunately in challenging times, the risk of fraud increases. Has the vulnerability assessment been considered and reviewed for any new risks?
  • Shelf-life (clause 5.1.4) – has this remained unchanged or has an ingredient change had an effect?
  • Product labeling (section 5.2) – ingredients, claims, allergen labeling, country of origin, etc. could all be implicated by a change in an ingredient.