21.13 `Own label'and other contract manufacture
Where completeor part manufacture is carriedout as an own-label,private-
label, distributor's-own-brand, contractpackingor similar operation,except
where responsibilityis specifically excludedby mutualagreementbetween the
ContractGiverand the ContractAcceptorthe obligation is on the Contract
Acceptor(the actual manufacturer)to ensure that production is carriedout in
accordance with GMP in the sameway thatwould be expected were he
manufacturing for distributionand sale on his ownaccount. This may be
facilitatedif the Contract Acceptor is certified underthe BRCGlobalStandard±
Food.
The ContractAcceptor should ensurethat the termsof the contract are clearly
stated in writingand that rawmaterials and end-productsare covered by
adequately full specifications(as outlinedearlier in this chapter). Anyspecial
GMP requirements shouldbe clearlyemphasised, and quality control, record
transfer, coding, rejection, dispute and complaint procedures should be
identified and agreed. Itemsof possible confidentialityshouldbe identified
and any appropriatesafeguards be mutuallyagreed.
It is normal practice for ContractGiversto imposecontractualconditionsthat
ensure quality standardsand GMP.Thisis desirablyachieved,at leastin the first
instance, by a visitto the manufacturingunit,by the Contract Giver's Food
Control manager.The visitshould includethe following objectives:
∑ to ensure that,withinthe manufacturing environment, the foodcan be
produced safely;
∑ to agreea detailedproduct specificationcovering all aspectsof product,
process, packand delivery,embracing parametersto be usedfor acceptance
or rejection,and any legalrequirementsrelatingthereto;
∑ to agreelevels of samplingof finished products by the customer and sample
plans to be usedin caseof dispute;
∑ to evaluate the adequacyof the control resources, systems, methodsand
records of the manufacturer;
∑ to agree, wherever possible, objective methods of examination; while
subjective measurements should conform to recognised and accepted
standardsif possible.
Agreementin all five areasis essentialfor any manufacturer/customertrading
relationshipand shouldbenefit bothparties.
21.14 Goodcontrollaboratorypractice(GLP)..
A control laboratoryshould be designed,equipped,maintainedand of sufficient
spaceto suit the operationsto be performedin it, and shouldhaveappropriate
premises,facilities and staff,and be so organised, as to enableit to providean
effectiveserviceat all relevant timesnecessaryto fulfil GMPrequirements. This
344 Handbookof hygiene controlin the foodindustry