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#83519 BRC v 7 Gap analysis

Posted by agnes on 13 January 2015 - 02:47 PM

Hi there,


I am known to be impatient and I have done gap analysis between v6 and 7. Please help yourself to it. if any mistakes are found please let me know.



Attached Files

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#91342 2.5.1 Responsibility, Frequency, and Methods

Posted by ChocoTiger on 14 July 2015 - 08:37 PM



Here are generic examples of what is needed for,,, and  The programs I included in this are the prerequisite programs required by SQF.


Let me know if you need any additional help.



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#90966 Does anyone know what PIGS stand for?

Posted by Wine Gum on 07 July 2015 - 07:22 AM

The PIGS diagram can be used to formulate hazards comprehensively:


P- presence (qualitative and/or quantitative evaluation of presence of hazards)

I-Introduction (Likely occurrence of hazards and severity of their adverse health effects)

G - Growth (Production or persistence of foods of toxins, chemicals or physical agents)

S- Survival (Survival or multiplication of micro-organisms of concern)


Hope this helps!


Wine Gum

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#60958 Micro. Guidelines for Food Contact Surfaces

Posted by Charles.C on 30 April 2013 - 03:03 PM

Dear All,

I previously posted a table of various micro. guidelines for food contact surfaces which were mostly issued pre-2000 at this link –


To update the earlier info., the attached excel file presents guideline data I have accumulated for 12 countries issued in the period 2000 – 2012. The compilation demonstrates that for a range of food-related scenarios, some “average” opinions for various (just) cleaned surfaces are –

(a) For Aerobic Plate Count (APC) - the majority of data suggests that, for routine cleaning/sanitising, surfaces typically have maximum APC counts in the range 10-100cfu/cm2 .
(b) For factors like Coliform, (generic) E.coli, Enterobacteriaceae, S.aureus, the expected maxima are, predictably, low, eg 1-10 cfu/cm2, or undetected. The latter requirement also invariably applies for “zero-tolerance” pathogenic microbial species.

Hopefully of some interest. Further input / comments welcome as usual.

Attached File  Compilation of International Micro. Guidelines for food contact surfaces, 2000 onwards.xls   993KB   3266 downloads

Rgds / Charles.C

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#96805 Food Safety Morality

Posted by mgourley on 21 December 2015 - 10:30 PM

A lot of us have spent many hours writing policy to make sure that what we do is the right thing to do.

A lot of us have made sure that senior management is aware of said policy, and they always have input into the final product. We may go so far as to include approved exceptions.

Once they approve, or give tacit approval, that document states what we do in a certain situation. 


That policy, procedure, whatever, then governs how "all" people act when that particular situation arises.

After the fact is not the time for higher ups to decide that the policy does not need to be followed.


Make your objections known, CYA, and move on. You are exactly right. You do not want to set precedent. If you do, what's the point in this rule, or that policy?



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#91444 VACCP Risk Assessment

Posted by trubertq on 16 July 2015 - 03:39 PM

Since Storage and distribution is not my area I don't feel qualified to answer however I'm sure some one on here can help him.


I'd imagine his customers are looking for verification that his goods haven't been tampered with or substituted, as well as trying to pass the buck of VACCP onto him.....


I'd suggest going to his suppliers and requesting THEIR VACCP risk assessment and then add in his steps in the chain with his risk assessment.

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#86325 What is a Verification Schedule?

Posted by fgjuadi on 05 March 2015 - 08:41 PM

2.5.3 is your verification schedule,  I use this for verification activities - Verify the metal detector is working every 30 minutes .  Verify chemical concentration every morning via titration.


Internal audits go on 4.5.2 (Validation schedule)


To make it easier, I combine the 2.5.3 form with 2.5.1 (methods and responsibilities) and 2.5.4 (Verification of monitoring activities) .   Basically it's a chart with each monitoring and verification activity, frequency, and responsibility.

So maybe the QA Manager checks the visitor log once a week, but they only conduct a food defense audit annually.  The check goes on verification of monitoring, the audit goes on validation.


It can get very "fuzzy" as SQF does not dictate which activity is which. I attached copies of both if it will help - but don't be surprised if you get some different answers.


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#85923 Supplier Approval of Contract Service Providers

Posted by trubertq on 26 February 2015 - 03:57 PM

Make up a code of practice for them to sign , something simple not full of jargon, what you expect from them, what your Hygiene rules are etc.. I have attached a template

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#83199 Apology to Mr I from Mr IFSQN

Posted by Simon on 07 January 2015 - 09:44 PM

Over the last couple of day's it has become clear to me that I have made an almighty cock-up on MOTM and caused Mr I a huge injustice.


Mr I received the most reputation points in December (by a distance), but I did not award him MOTM because I (mistakenly) thought that once a member had won MOTM they could not win it again. When I checked the rules yesterday I realised I was wrong and a member can win it once per calendar year. I thought that was just an unfortunate, but simple mistake I had made.


However, (to my horror) I have now realized that MR I has NEVER won MOTM...I would have put my mortgage on that he had previously won it. To make matters worse it is likely that in previous months Mr I has scored the highest reputation points and won MOTM and I have overlooked him.


The upshot is I have dealt Mr I a real injustice and I am totally at fault and I have passed on my sincere apologies.  Thankfully Mr I has graciously accepted my apology.


For the record Mr I did not want me to publish this apology, but I want to because it is right to do so. We have some great members around here and Mr I is one of them.


To this end MR I is the first ever recipient of the annual Member of the Year award.   Apart from the title there will be some sort of badge of honour, but I’m working on that…ideas?




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#81054 Micro testing for compressed air (used on food equipment)

Posted by Charles.C on 18 November 2014 - 06:42 PM

Dear Laura,


Thank you for the detailed reply. Much appreciated. I have expanded a little on some of the comments in yr post / links.




I looked at  2 viewpoints, SQF/BCAS, on some desirable Quality characteristics of Compressed Air -

Purity is defined in the SQF Code (Appendix 2: Glossary) and means the absence of contaminants that could cause a food safety hazard. Pure air means the air is free of risk of cross-contamination to the products. Essentially, the air must not contribute any contamination to the product.


Strictly, use of the word “contamination”  as defined by SQF implies that  micro.standards based solely on APC limits could be regarded as safety (ie haccp) meaningless. (In a cleanroom context the situation would likely be rather different,  limits derived for sterile scenarios are in some articles recommended as not being arbitrarily transferred into the food scene without due caution).


Similarly to SQF, BCAS implicitly defines contaminants in its introduction via -


Contaminants that may be a potential hazard in food for human consumption

In the context of the BCAS COP, hazard is presumably interpreted as safety hazard. On this basis, some difficulties also arise IMO, eg - 

The BCAS Food Grade Compressed Air, A Code of Practice states,

"6.2 Microbiological contaminants.

HACCP shall establish the risk of contamination by microbiological contaminants. The level of viable microbiological contaminants in the compressed air shall not be detectable using the method described in clause 7.6." Clause 7.6 refers to ISO 8573-7 test method for viable microbiological contaminant content.


The word "detectable" suggests that any microbial species other than what is (somehow) defined as "natural"  to the specific product have zero tolerance. This seems inconsistent with basic haccp principles. Unless a list of accepably non-hazardous species exists ?


This post primarily focuses on micro. “B” factors, the “C, P” hazards are well over-viewed in the SQF faq (see Excel file/sheet3 below) and the Code’s Guidance documents, eg for parts 2/11.


I have done a little background searching regarding standards, micro.species, filters, etc and pasted some selected extracts into the attached excel book (the earlier studies in this area seem a little neglected these days, maybe justifiably :smile: ) . Most of the content will probably be (only too) familiar to you of course.


The source files are attached below, keyed to the excel sheet numbers.


Attached File  Compilation regarding Micro.Standards,etc for env. air,compressed air,filters in food plants.xls   1.48MB   474 downloads


Attached File  sh1 - microbiological air quality.pdf   489.76KB   590 downloads

Attached File  sh4 - Compressed-Air-in-the-Food-and-Beverage-Industry.pdf   3.82MB   435 downloads

Attached File  sh4.1 - food industry compressed air systems,white-paper.pdf   196.81KB   303 downloads

Attached File  sh5 - compressed air in food plants,white paper,Parker Balston.pdf   522.15KB   298 downloads

Attached File  sh6 - ECFF.pdf   402.26KB   309 downloads

Attached File  sh7 - tesco standard 2014.pdf   1.15MB   371 downloads

Attached File  sh8 - air filtration systems.pdf   193.62KB   314 downloads


Rgds / Charles


PS - Two/three of the above documents are already in the thread linked in post 2 above. I re-used them to allow some convenient integration.


The mystery (to me) of why SQF's faq (typically) refers to 0.1micron filters whereas the guidance document specifies 0.01 micron remains. Nonetheless, if the cost/maintenance/implementation factors are comparable (?), the latter seems a logical investment for an easy audit (also see sheet5 in Excel file). For current purposes i assumed the faq is more "maintained" than the guidance and "acted accordingly". :smile:


PPS - the extensive collection of TA documents available via Laura's links in previous post(s) are remarkable and valuable. Highly recommended for browsees. :thumbup:


P3S – for those interested here are 5 more links, the first two look at typical air sampling devices/procedures (mainly food/cleanroom respectively), the next 3 focus on micro.aspects/standards  as applied in pharmaceutical, cleanroom, sterile work scenarios. The similarities to concepts used (borrowed?) in the food business is clear but there are also significant differences in emphasis, eg the interest in viable/non-viable particles.




http://www.fda.gov/o...ug Products.htm



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#79737 BRC Global Standard for Packaging V5

Posted by cazyncymru on 23 October 2014 - 01:33 PM

Just released for draft consultation


Caz x

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#73564 IQA Salary Survey

Posted by cazyncymru on 09 June 2014 - 09:04 AM

I agree with Slab, yes I get paid more, but I don't just deal with Food Safety; under my umbrella comes Environment & Health & Safety!


Food Safety has changed so much in the last 14 years. I think its changed a lot in the last 5 years and if i'm honest, unfortunately (controversial statement coming), not all Quality Professionals have evolved along the way. Some times I see questions on here, and whilst we all have to start somewhere, I despair. I hold my head in my hands, wondering are they really serious or are they trolls! It does make me somewhat reluctant to respond to some post(ers). It would seem that some people are either unable to think for themselves or unwilling to! To be a quality professional you have to have at least a basic knowledge and I know it is difficult, but please if you haven't had a formal education in food safety, at least read a few books and try to learn something!


I think that we have now become more focussed in assessing risks with risk assessments becoming the backbone of a food safety system. As things have evolved, we are being asked to carry out more and more risk assessments; even if it doesn't truly affect our industry (I think Acrylamide!). Thing is, who's teaching people to do these risk assessments? And who taught them? their all subjective! as long as you can justify how you reached that conclusion, who's to say your right or wrong! In the latest version of the BRC, we are asked to carry out a vulnerability risk assessment. Now I work predominantly in Dairy, and I have interpreted this in risk assessing from the farm to the fork, so my study incorporates animal health as well as abuse by the customer. I'm lucky that in a previous life, I was involved in doing Farm Assurance, so I understand about what can potentially happen on the farm; but I bet I'm in the minority. We're asking quality professionals to assess something they may not have any idea about, and this is where mistakes can be made.


I also think we've become inundated with consultants. I probably get a request daily from either a consultant or a recruiter on LinkedIn!! If I need help I will ask, and if I want a new job, I'm sure I can find one myself! ( I've never used an agency to find a job)


So, those are my thoughts,  I'm sure many will disagree.



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#124839 Hello From Salt Lake City, Utah

Posted by Guy Spagnoli on 02 May 2018 - 08:29 PM

My name is Guy 'Grundy' Spagnoli

I have been in Quality Assurance since 1979

Worked for Space Shuttle NASA Rockwell

Litton Saudi Arabia Limited



Military and Private sector - hardware/software, Auditor from Suppliers to first article to application ( I call it from Womb to Tomb)


Got into the food side by accident working for Mrs. Fields Corporation for 10 years and now for Thrive Life LLC. so yes, I have 40 years now in QA (boy that went by fast) and have enjoyed the experience and learn something new almost everyday.



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#98348 Is it possible to pass a GFSI audit with a poor food safety culture?

Posted by ganderson64 on 10 February 2016 - 12:18 PM

This happens all the time. A company ignores food safety for 9 or 10 months and then there is a big push to get everything in line prior to the audit. Once the audit results are in, back to business as usual. It's sad, but true - in many cases management simply sees a certification as a marketing tool.

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#87819 Are you happy with your job?

Posted by Miss Tammy on 14 April 2015 - 01:59 PM

At times I really love my job, and other times I want to run away and never come back!  We are a small company and all managers wear many hats.  I get very overwhelmed with all of the work I have to do and no matter how many hours I put in it is never enough.  My biggest issue is my support staff.  We are in a rural area and the employee pool is very limited.  We started offering a much better benefit package and increased our starting salary in an attempt to attract better people, but it has not worked.  I try to delegate, but it seems no one can think for themselves.  I get calls all hours where I have to do the thinking for them!  Anyone else have these same issues?  How do you handle it?  I am a quality manager, but this seems to be the case in all departments. 

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#83617 Bread smells like nail polish remover

Posted by mgourley on 14 January 2015 - 07:41 PM

This problem is nearly always caused by the wild yeast, endomycopsis. This yeast is found in nature and is carried into the plant by air currents. The yeast converts starch into acetone, which is the odor detected in the bread. The yeast can best be eliminated by washing the equipment with vinegar.





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#73288 Are beard nets for moustaches required?

Posted by Setanta on 03 June 2014 - 12:15 PM

Me too! Since I shaved my head a couple of years ago as a fundraiser for a coworker going thru chemo, they always blanch a bit when I say, "when I was bald, *I* wore a hairnet, there's NO reason you can't!"

It's fun!
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#61280 Think outside the box for HACCP success

Posted by Simon on 12 May 2013 - 07:13 PM

Think outside the box for HACCP success
Amanda Evans, Certified Auditor and Trainer, HACCP Mentor.

The purpose of this presentation is to educate participants on how critical thinking can be applied to the management of food safety within their food business. Critical thinking involves the participant looking past the “obvious” to ultimately prevent and manage food safety issues. Thinking “outside the box” can move a food business past basic compliance into achieving an exceptional level of business improvement, innovation and growth. The session will focus on how to apply critical thinking to three core areas, namely, complaint investigations, root cause analysis and hazard identification and assessment.

If you have a question related to this presentation please post it below.



<<Link to the Webinar recording>>

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#123937 FDA FSMA Compliance Audit

Posted by mgourley on 11 April 2018 - 10:43 PM

Monday morning a FDA Investigator showed up at my firm to conduct a FSMA Compliance Audit.
Apparently they are reaching into the bucket and drawing names of companies to inspect. Our company does bread/rolls and cookies. The inspector intimated that the reason we were chosen was not because we are a "high risk" facility, but because we have a decent amount of allergens in the facility.

This was an actual FDA guy, not the contracted state officials. The audit was scheduled for 4 days.

This was not a FDA swoop in for massive swab taking. It was an audit to determine compliance to FSMA. Their stated goal is to "Educate while Regulating". 
Of course, if he found something egregious in the process(s), the audit would have taken on a different light.


He reviewed our Food Safety Plans, Recall Plan, sanitation programs, allergen programs, training, supplier verification, approval and monitoring plans, and associated procedures and monitoring records. He collected production records from one specific item. He did his own hazard analysis of ingredients in that product and compared it to my hazard analysis for the same ingredients and accepted by HA, RA and any controls.

He accepted my hazard analysis and determination of Preventive Controls for the process, with a few questions about how I came to the conclusions I did.


He was impressed that I was ahead of the curve in doing vulnerability assessments of ingredients for intentional adulteration/economically motivated adulteration.


He spent probably 8 hours on the floor, observing the process, people and material condition of the facility (we have a total of 6 lines under one roof).


The wrap up meeting is in the morning tomorrow, but there were only a couple of minor findings, which are simple additions to verbiage to a couple of our policies.




Use the FDA guidance documents. If you are doing hazard analysis of ingredients based upon what they have published, you should be good.

FDA is not likely to accept supplier guarantees or COA's as a PC for things like allergens or biological hazard controls.

For allergens, if you can get documentation from your supplier that specifically shows how they control allergens in their facilities, that's a plus.

For things in bakeries, where they may want to see validation of a "kill step", use the AIB Kill Step Calculator. We did this for the bun/roll line, but had not yet done it for the cookie lines.


All in all, a fine audit. We learned what the FDA is looking for, and the inspector was not looking to hammer us, but to explain the guidance documents and how FDA is using them. They realize that industry has questions, and FSMA is a large undertaking. They are learning from us as they do these inspections.


This part can be edited out by Simon or Charles if I am sounding like I am endorsing a sponsor of this forum.


This facility uses SafeFood 360. The Inspector was highly complementary of the "software", in that it allowed me to access policies, documents and records quickly and without having to resort to consulting binders of paper (for the most part).

The Inspector made the offhand comment to the Plant Manager that the QA Manager and I should get a raise for our efforts to comply with the regulation and pare down the scheduled 4 day audit to 3 days, even with a lot of chit chat during the desk audit portion.  :spoton:








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#79618 Preventive action regarding incorrectly filled records?

Posted by fgjuadi on 21 October 2014 - 04:20 PM

corerctive action = what you do to fix the problem

preventative action = what you do to stop the problem from happening


Let's be frank - it probably isn't training.  You employees probably know how to fill out the form.  They probably do not want to be bad employees.  So why aren't they filling out the form? Maybe they're too busy, maybe equipment is missing.  Maybe you have to stand on the floor & watch the employees for a while before you can see the root cause.


So maybe you can translate the form to their language.  Maybe you can move the form closer to the point the check is being performed (or maybe it's too high / far away).  Maybe you can introduce a procedure to physically stop the line until the check is completed.  Maybe their chemicals aren't being filled every shift.  Maybe they ran out of forms and can't find new ones.   Maybe the pens are locked up & only day shift can get them and they hide them.  Etc.


They will make mistakes - just teach them to cross them out with a single line instead of a scribble.


If you know it will not affect business or it's a food safety record, you can put product without correct documentation on hold - depending on the paperwork in question, you can't release without it being correct, etc. 

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