8 replies to this topic

[Dr. Donal Hughes]

Hi all,
I am in the process of finishing a quality system for a meat company based on the Global Standard For Food Safety Issue 5.

I have written a quality manual based on the clauses of the standard. It's an effective roadmap which directs the reader to the various procedures, protocols etc. So that's Manual 1.

Next is the HACCP Manual, I have set this out in the standard codex format until I get to the pre-requisites section (I always think of this as part 2 of the manual)

Here is where I am torn as to what should I include in the pre-requisites section and what should I divert to a third Manual. Is there a defintive "cut and dried" list of pre-requisites? It would be super if anyone would advise on what should go in to what manual. Does anyone have just a quality manual and a HACCP Manual? Is there some jargon that allows you to put extra headings in the pre-requiste section? My aim is simplicity, yet I want of course to fit in with industry norms.

Here are the topics I have addressed in my now bulging pre-requiste section of the HACCP Manual. Which if any do you think should be diverted to another manual?
(Note: there are 3 sop sections in this list- does this warrant having a whole other manual or can they blend in here?)


1. Cleaning. 4
2. Maintenance. 35
3. Pest Control. 38
4. Calibration. 40
5. Personal Hygiene. 42
6. Training. 47
7. Allergens. 49
8. Traceability. 54
9. Microbiological Testing. 57
10. Glass and Foreign Bodies. 67
11. Waste Management. 69
12. Non-Conforming Product and Recall . 70
13. Production Standard Operating Procedures. 77
14. Non Production Standard Operating Procedures. 88
15. Quality Office Standard Operating Procedures. 10
16. Internal Audit. 103
17. Product Design/ Development. 105
18. Supplier Approval. 106
19. Complaints. 107
20. Shelf Life Testing. 110


Thanks in advance,
Donal

[YongYM]

Dear Dr. Donal:

We do not have a separate manual for BRC but made a link or cross-reference to the HACCP/GMP Manual.

[We in Malaysia (certified by the Ministry of Health) required to have a separate manual for HACCP and PRP or GMP Manual. So, different BRC clauses will be cross-referred to either HACCP manual or GMP manual]


Yong

Edited by YongYM, 17 June 2009 - 02:27 AM.

[Charles.C]

Dear Donal,

You are perhaps slightly atypical (and lucky) in that starting from a flat baseline. Makes things like documentation relatively less complicated.

[added - AFAIK, BRC 5 does not stipulate that one’s prerequisite programs must match any specific Codex document unlike it’s adherence to the Codex HACCP plan layout. I can see you fairly closely followed the pre-HACCP sections of CAC/RCP 1-1969, rev. 4 -2003 which is understandable. The Codex HACCP section itself leaves the exact choice of prerequisite programs open and clearly many people will already hv some of the items in its (very wide) scope suggestion set up in various other locations. Presumably Codex wisely took this into account as per their typical recommendation-only role.]

I doubt that there is a “norm” for a variety of reasons. Some examples –

(1) Many people come to BRC having previously “done” HACCP and 9001. This means they will likely hv already produced separate multiple manuals (eg 9001 - 2-3 [Q.man / Q.procs / work functions]) for auditing convenience (but not necessarily).
(2) For HACCP, people have variously used pre-requisite lists derived from Codex or NACMCF. Or one of the many national others spun off from those 2. ISO 22000 has another nice long list. All of them hv similar core topics but varying expansions. Some people don’t use pre-requisites, as such, at all.
[added - some original lists are collected and compared here (2002)
http://www.fsis.usda...erequisites.htm ]
(3) For HACCP again people hv often used routes based on their own legislation / industry norms and location, eg USA/seafood favours SSOP manual / SOP manual / HACCP manual and offers a very prescriptive treatise on the subject. Canada (cfia) also has a massive websitewith detailed formats.
(4) QA people had a lot of related procedures in their “QA manuals” prior to BRC so that xreferencing now came in (or re-writing the set-up – not to be undertaken lightly).

Simon’s posted packaging HACCP plan + the associated hygiene procedures is probably a good example of a dedicated package but (obviously) doesn’t require a number of the food-specific programs and apparently hasn’t incorporated so many of the 9001 expectations. (I guess the latter, not my area.

[ added - I predict many people focus more on the USA - GMP / sanitation style, eg as in ISO 22000, for their basic list of PRPs]

Interested to see what other people say.

Rgds / Charles.C

[Amber McCreary]

This is a very interesting discussion, it is something I am dealing with myself.
(Background: We are in our first year of BRC)

We currently have a HACCP Manual and A BRC Manual but no Quality Manual. Both the BRC and AIB auditors last year suggested we take our QA Manual and change it into a "BRC format style manual" -getting rid of the Quality Manual all together. My only concern with this is although it is "easy" to present for our audits-that we may be short cutting ourselves.
**Also one thing we didnt realize before jumping in head first; was that we now have nothing to present to potential customers. So Im struggling with what the logical combination might be,..... maybe:

A. A Quality Manual, HACCP Manual, and a BRC quick reference guide of some sort

or

B. A BRC book, HACCP manual, and maybe some kind of Customer Handbook

Please lets discuss some of the pro and cons of some of the different routes.

Edited by QualityAMBakeries, 30 November 2009 - 07:21 PM.

[Amber McCreary]

Edited by QualityAMBakeries, 30 November 2009 - 07:22 PM.

[Zeeshan]

Hi to all!
Just sharing my knowledge related to the issue being discussed.

We are currently planning to integrate BRC requirements in our ISO 22K compliant FSMS. One food safety auditor who performed our gap-analysis and one consultant have suggested to simply make a BRC manual additional to our existing ISO22K compliant FSMS documentation.

BRC manual will contain:
1- Cross references to other documents that already exist and can smoothly fulfills BRC requirements along with ISO 22K ones.
2- Description of requirements not addressed elsewhere. Manual will cover all requirements related to QMS and remaining prerequisites such as security, control of chemical & physical contamination, metal detection etc.

BRC Manual would be something different as what QualityDirectorAMBakeries specify "BRC quick reference guide". AFAI think it would contain only part-1 as above.

100% agreed with Charles regarding industry norms. Every industry has set its own standards. Also as far as my existing knowledge is concerned, no standard ISO 22K, ISO 9K or BRC demand any specific style or format of documentation (I have not studied BRC requirements completely, so if I am wrong, members are requested to please correct me). You can make one consolidated manual that includes all procedures, diagrams, prerequisite programs etc. Or you can make separate manuals to address different groups of activities such as related to QMS, related to prerequisites, related to HACCP etc.

Regards:
Zeeshan.

[Allsafe]

Try not to over complicate things.
For our clients we simply set up a HACCP manual and a separate BRC Manual (or Food Safety Quality Manual) this includes policies, procedures etc...for all clauses of the BRC Standard in order of the standard (so it is easy for you and auditors to find dopcuments). It also includes the master records etc... in relevant sections. Insection 2 of this manual we have no more than the HACCP policy (as this and all other HACCP related documents are in the HACCP Manual itself).
This is all you need but of course there will be other manuals e.g. pest control, cleaning - these will be referenced to in the Quality Manual (but not included in it).
Certainly works for us will all our clients A grade and some with no non-conformities!!!
All the best,
Russell.

[Tony-C]

We would normally have a Food Safety Management System, a HACCP Manual and a Laboratory Manual. Please see the attached on how IFSQN have structured the BRC Food Safety Quality Management System:

 BRC_Food_Safety_Quality_Management_System.pdf   1.4MB   283 downloads

Regards,

Tony

[Amber McCreary]

We would normally have a Food Safety Management System, a HACCP Manual and a Laboratory Manual. Please see the attached on how IFSQN have structured the BRC Food Safety Quality Management System:

 BRC_Food_Safety_Quality_Management_System.pdf   1.4MB   283 downloads

Very interesting. I like this approach.