8 replies to this topic

[Wine Gum]

Good day Fellow Forum members

i need your help in the interpretation of the requirements as per Clause 3.4.4:

In addition to the internal audit programme there shall be a programme of documented inspections to ensure that the factory environment and processing equipment is maintained in a suitable condition for food production. These inspections shall include:

• hygiene inspections to assess cleaning and housekeeping performance

• fabrication inspections to identify risks to the product from the building or equipment.

The frequency of these inspections shall be based on risk but will be no less than once per month in open product areas.




We are classified as an enclosed production area. Currently we are doing a monthly hygiene and fabrication inspection as per requirement, but after reading the requirement again, I realized that it is not necessary to do it monthly. Am I correct? Can I do a risk assessment to determine the frequency of the audit.

Thanks in advance

Makayla

[Simao Monteiro]

I think, if there is any area with product out os the package, you need to do it monthly.

[GMO]

As it specifies open product areas then you should be fine to reduce the frequency, however, you do need to specify the risk assessment very clearly. An auditor wouldn't accept "we are enclosed product producers". If you have chosen a frequency different to the suggested, you need to justify why.

Is there absolutely no point where the product is open? E.g. filling?

[Wine Gum]

GMO, The filling and closing of the product are fully enclosed - the closing of the product takes place in the same enclosed unit where it is filled. We will do a risk assessment to motivate our decision to change the audit from monthly to 3-monthly. We are already doing daily hygiene inspections during production at prescribed intervals.

Makayla

[Dalways]

Completely depends wat product u producing at that site . For good manufacturing practise I will suggest keep it monthly .
Deb

[GMO]

I would be more inclined to reduce the daily hygiene inspections rather than reduce the monthly ones. The monthly ones are often more in depth and performed by someone more senior.

One thing worth considering if you move to 3 monthly is about non conformances. Are you and your operations team controlled and strict enough to ensure non conformances don't take 3 months to be completed? What if they're not done by the time you reaudit?

[Wine Gum]

Audit non-conformances will be discussed on the monthly BRC meeting - the closing thereof must be within in time frame given on the report. I am therefore feeling at ease to change the frequency to 3-monthly.
The final decision to change will be made on the next BRC meeting.
Thanks for all your input

[agnes]

Hi,


I am struggling with this requirement at the moment.

Has anyone have a pro-form/ checklist to do the fabricationinspections to identify risks to the product from the building or equipment?

Thanks in advance.


Agnes

[bev]

Hi,

Check out a post on the same topic started 11th June on the BRC Forum. Tony very kindly attached an example checklist to that :-)

Bev

Hi,


I am struggling with this requirement at the moment.

Has anyone have a pro-form/ checklist to do the fabricationinspections to identify risks to the product from the building or equipment?

Thanks in advance.


Agnes