7 replies to this topic

[mgourley]

I'm re-doing my risk assessments for BRC 6.

Please have a look at the attached and let me know if I am on the right track.

Thanks in advance,

Marshall

Attached Files

•  Sample RA.pdf   17.1KB   1146 downloads

[Charles.C]

I'm re-doing my risk assessments for BRC 6.

Please have a look at the attached and let me know if I am on the right track.

Thanks in advance,

Marshall

Dear mgourley,

Thanks for the example.

Basic layout looks similar to the example for “internal audit” in post below (?) so I guess it should be OK for auditors -

http://www.ifsqn.com...dpost__p__56043

At the risk of boring people, the basic idea is I think something like –

Activity X is carried out by procedure Y (cols 1,2)
Due to W there may be a problem Z (col.3)
Estimate Risk of W (cols 4-6)
Justify (? ) Estimation and (re-)state the result (col7)
Conclude that current procedure(s) give adequate control therefore no further action required. (actions/decs)

Overall the text seemed quite good to me. Only hv few comments and first 3 are probably influenced by IA example in link above. I also have a tendency to nitpick so apologies in advance if necessary.

(a) Col1 - I would make directly aligned to BRC target parameter if possible. (sometimes not so easy due BRC)

(b) Col.3 - First half of sentence looks suspiciously generic but this may well be intentional with further tables in mind . Should still get past auditor ok IMO.

© Col.7 – Maybe a little cursory, eg compare to IA example, but either way the net result is a subjective opinion so why not? (I guess it may also depend on how much scope for auditor comment you are willing to risk).

(d) Personally I find the terminologies “Probability / Significance” as used in the matrix / table not nice but there is definitely no absolute standard for such items.

(e) Deriving from [d], I’m also not enthusiastic regarding “ high severity of risk” or “low probability of risk” (latter would be unobjectionable if table used more conventional terms)

Of course, there are a variety of ways of doing these RAs however the type of hazard does sometimes dictate the easiest way to present the RA. It seems to me that in most cases, BRC are not expecting anything much more than a skeletal offering. I guess one should act accordingly.

I don't recall anyone yet posting that their RA was rejected.?

I’m curious as to yr previous design ? Maybe interesting to compare ?

Rgds / Charles.C

PS - One more thought, it is maybe more accurate to change the heading on the "Risks" column to "Hazard"

PPS - illustration above comments, not a criticism, just an alternative.
 Rev2 - risk assessment layout - Sample RA.pdf   25.63KB   795 downloads

[mgourley]

Charles,

All good comments. I have incorporated several.

The previous design was more along the lines of a HACCP hazard analysis which I was not really happy with.

As you state, it does not seem that BRC is requiring any deeply detailed sort of RA. In which case, I choose to be as uick and easy as possible while still examining the risks present.

Thanks again for the feedback.

Marshall

[Tony-C]

I'm re-doing my risk assessments for BRC 6.

Please have a look at the attached and let me know if I am on the right track.

Thanks in advance,

Marshall

Hi Marshall,

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

I like your document it is quite neat and tidy but.....

Based on risk means you inspect based on the importance of conducting an inspection so high risk areas e.g. filling vs. medium risk e.g. processing vs. low risk e.g. storage. So you will inspect high risk more than medium risk more than low risk if you see what I mean?

Kind regards,

Tony

[mgourley]

Hi Marshall,



I like your document it is quite neat and tidy but.....

Based on risk means you inspect based on the importance of conducting an inspection so high risk areas e.g. filling vs. medium risk e.g. processing vs. low risk e.g. storage. So you will inspect high risk more than medium risk more than low risk if you see what I mean?

Kind regards,

Tony

Tony,

I do see, however our entire facility is low risk and is so stated in the Quality Manual.

But then again, you would not know that, would you?

Marshall

[Charles.C]

Dear Tony,

I do agree that product / area sensitivity could be a component of the procedure for determining inspection frequencies.

However in present context, the BRC’s use of the word “Risk” appears to be somewhat open to interpretation to my eager eyes.
It is not clear to me that BRC are mandating that the frequency of inspection must be adjusted for area sensitivity status. Especially if one’s achieved results can prove un-necessary ?
(I would anticipate that all food factories are making the relevant inspections substantially more than one time per month, regardless open, non-open, product/area type.)

I had the suspicion that the example quoted in my post (and similar to mgourley’s layout) was deliberately designed to neutralise BRC’s attempt to make life a PITA via the topic of risk assessment.

It seemed to me to be that the example’s layout is a sort of statistical hypothesis test, ie the proposed choice of frequency allows a satisfactory result for predicted risk of failure (LxS > Low), as justified by verification data. So the conclusion is that the proposed frequency is satisfactory, ahem, “Based on Risk”.

I may be (auditorially) wrong of course. The Proof of the Pudding……

Rgds / Charles

[mgourley]

Dear Tony,

I do agree that product / area sensitivity could be a component of the procedure for determining inspection frequencies.

However in present context, the BRC’s use of the word “Risk” appears to be somewhat open to interpretation to my eager eyes.
It is not clear to me that BRC are mandating that the frequency of inspection must be adjusted for area sensitivity status. Especially if one’s achieved results can prove un-necessary ?
(I would anticipate that all food factories are making the relevant inspections substantially more than one time per month, regardless open, non-open, product/area type.)

I had the suspicion that the example quoted in my post (and similar to mgourley’s layout) was deliberately designed to neutralise BRC’s attempt to make life a PITA via the topic of risk assessment.

It seemed to me to be that the example’s layout is a sort of statistical hypothesis test, ie the proposed choice of frequency allows a satisfactory result for predicted risk of failure (LxS > Low), as justified by verification data. So the conclusion is that the proposed frequency is satisfactory, ahem, “Based on Risk”.

I may be (auditorially) wrong of course. The Proof of the Pudding……

Rgds / Charles

Charles,

Until BRC or other GSFI standards specifically state "how" you have to meet the intent of their particular standard, I assume plenty of leeway is allowed. By nature, all GFSI standards can't be so specific as to dictate exact procedures, policies or inspections.

I would suppose that hardly any food manufacturers attempting to gain GFSI certifications have no existing programs, policies, etc. in place. Certainly the standard boards understand that and use risk assessments as a way to justify your current system.

One would assume that if your current system showed that there were rats parading around your facility or metal shards were a daily fact of life, you might have attempted to correct that, or just thrown in the towel an gone out of business


Marshall

Edited by mgourley, 27 January 2013 - 10:48 PM.

[Tony-C]

Tony,

I do see, however our entire facility is low risk and is so stated in the Quality Manual.

But then again, you would not know that, would you?

Marshall

Hi Marshall,

No my crystal ball keeps clouding up

The same principles apply assuming you have different areas of risk

It seems like you have gone down the route of all risk is the same and you are auditing at a frequency that should be acceptable to an auditor.

The standard of the factory environment and processing equipment and the number of issues found during inspections will assist in verifying your frequency of inspection.

Regards,

Tony