24 replies to this topic

[mica]

Hi,

 

Can you help me with a question?

 

My Company is looking into packing soft fruit from Portugal next year. We have the B R C grade A and we are located in England.

 

Our scope is The Packing and storage of whole, fresh soft fruit at the site.

 

Under this certification can we bring in soft fruit from Portugal or any other country for that matter. I would obviously expect our supplier to be B R C certified and we would have to do an audit of the supplier to ensure they complied with the food standards required.

I would also be expected to add the importing to our scope when we next have our audit as we would not be going ahead with this until after our next audit.

I have been looking on the B R C site and have re read the Standard but can't find an answer.

 

Any help would be most welcome and if we can do this any templates for the new paperwork we would need would be appreciated.

 

thank you

Mica 

[TGC]

My experience - I worked for a fruit grower and importer.  We imported product from Holland, Spain, Morocco.  We were BRC accredited to Grade A.  Cant remember the exact wording of the scope but it did include importing.  The suppliers were not BRC accredited but it was managed through Supplier Approval procedures which included the Technical Team auditing them.  Also many are acredited to specific produce/grower audits, the equivalent of our Assured Produce/Red Tractor Audits.

 

Good luck - the paperwork side was easy but getting decent fruit was another story!!!

[Charles.C]

Dear mica,

 

I presume you mean the scope of yr own UK certification to "BRC6", not the suppliers. And more specifically, the implementation of "BRC Guidelines to category 5", within BRC6 food. Don't recall any previous discussion of this extension here.

ie -

http://www.brcglobal...eshProduce.aspx

 

I deduce you are (potentially) equating  "import" obligations with yr own "export".

 

One thing for sure is that you will be the first to know if there is any "Quality" problem at the Customs import control point.

 

I guess the BRC standard focuses on direct capabilities for control. ISO would probably be more intrusive.

 

IMEX of BRC6 (not fruit), the only related audit discussion has been concerning initial "export" procedures / "importation" features inasmuch as reflectable back to "supplier approval", together (sometimes) with traceability considerations.

 

I cannot see any mention of  HMG / any importing storage / transport /  insurance company within the (primary) BRC6standard? Obviously statutory quality factors / other EC requirements are potentially involved at point of import.

 

Rgds / Charles.C

Edited by Charles.C, 18 October 2013 - 05:27 AM.
updated, hopefully relevantly

[mica]

HI

We want to import the fruit to this country for the purpose of supply to British customers.

I am hoping that apart from increasing our scope for next year we would be covered.

But there would be a new paper trail that I would need to set up?

 

Mica

[Tony-C]

Hi Mica,

 

I would think this would come under 3.5 Supplier and raw material approval but would check with your certification body and see what they have to say.

 

Regards,

 

Tony

Edited by Tony-C, 17 October 2013 - 06:10 AM.

[mica]

Thank you, I will contact them, hopefully it will just be a matter of changing the scope.

[Charles.C]

Dear mica,

 

Since you are BRC certified, i presume you hv read the (BRC6) Guidelines to Category 5 (now in ver.2 i think). I hv  scanned 1st version for "import" which only showed section regarding necessity to include the import function within traceability control.

If ver.2 is similar, Tony's suggestion is a logical one IMO.

 

In view of yr intended project, may find these refs of interest -

 

 fr1 - EU requirements for import of fresh fruit, 2006.pdf   307.67KB   22 downloads

 fr2 - Review of UK fruit and vegetable chain, 2007.pdf   739.64KB   16 downloads

 

Rgds / Charles.C

[mica]

Hi Charles

 

Thank you very much, very useful reading indeed.

 

Mica

[Mathieu Colmant]

Hi mica,

 

Just a remembering : When you are in the EU, "importing" means import from outside the EU. So buying fruits from Portugal to sell them in the UK is not an import, with no certificates, no import controls,... except some specific controls when sanitary status of the countries are engaged (example : control of UK meat when you had BSE problems...

 

Kind regards

 

Mathieu Colmant

VeilleAlim.eu sprl

[mica]

HI Mathieu

 

thank you for that information. It will make my job a bit easier for next year if I don't need to create new paperwork.

Would we need to do a visit to audit or would their own paperwork confirming an audit be sufficient?

 

 

regards

 Mica

[Madam A. D-tor]

Dear Mica,

 

In BRC iss 6 it is  (and also in BRC iss 5 it was) not allowed to use the word import in the BRC certification scope. According this guidance note it is not allowed words as: import, export, trade, sale, sourcing, purchase, etc. because these are out of the scope of BRC Food.

http://www.brcglobal...id=884&mid=2030

 

BRC only wants food processing plants to be certificated against BRC Food.

 

However the sourcing and/or importing will be a part of your process and will be audited acording the requirements in chapter 3.5.

According legal requirements you are owner of the process and of the product and therefore has to add the process in your HACCP-study.

 

I hope this answer, was of any help.

[mica]

Dear Madam A D-tor

 

Thank you very much this is very helpful indeed.

 

Within our process at the moment we have no CCP's will I be looking for them with fruit we bring onto the farm?

this is a whole new area for me to get my head around, any help greatly appreciated.

 

Mica

[Madam A. D-tor]

Dear Mica,

 

Are you a packer, wholesaler or are you a grower?

 

You have to follow the HACCP-study to decide which hazards lead to risks that need to be controlled. These risks can be controlled by CCP, but this is not necessarry.

[Charles.C]

Dear Mica,

 

Are you a packer, wholesaler or are you a grower?

 

You have to follow the HACCP-study to decide which hazards lead to risks that need to be controlled. These risks can be controlled by CCP, but this is not necessarry.

 

From the OP, probably a re-packer. After that, no idea.

 

I hv a strong suspicion that post #9 may be the best case scenario. In theory, imports from outside the EC should also have uncontrolled movement within the EC after having been initially checked on arrival. In practice i believe the issue of "sovereign right" can occur. Still, no harm in hoping.

 

Rgds / Charles.C

[mica]

Hi

 

we are predominantly a grower, we pack our own fruit but now we are looking into packing from elsewhere to provide our customer all year round.

 

Mica

Edited by mica, 25 October 2013 - 10:40 AM.

[Madam A. D-tor]

Hello Mica,

 

Now I understand your questions in a better way.

 

Are you planning to buy this fruit on the 'free market' or will you source it from a dedicated supplier?

If you buy on 'free market' the risks are harder to control. If you source from one (or a few) dedicated suppliers, you can request food safety information in the same way your customers are requiring of you.

The hazards are probably the same hazards as you has to control yourself.

[mica]

Hi Madam a D-tor

 

We are planning on buying from a grower, I was planning to send them paperwork to complete, I would want to see copies of their internal audits and HACCP procedures.

 

would we be expected to visit them to conduct our own audit or would the relevant paperwork sent to us be sufficient for BRC purposes 

 

Thank you

Mica

[Madam A. D-tor]

We are planning on buying from a grower, I was planning to send them paperwork to complete, I would want to see copies of their internal audits and HACCP procedures.

Good thinking! 

How about Global Gap Certificate and spraying schemes or records?

 

 

would we be expected to visit them to conduct our own audit or would the relevant paperwork sent to us be sufficient for BRC purposes 

No, If the "paperwork" gives you enough confidence. This is not needed.

 

3.5.1.2 of BRC Food states:

The company shall have a documented supplier approval and ongoing monitoring procedure to ensure that suppliers are manufacturing products under hygienic conditions, effectively manage risks to raw material quality and safety and are operating effective traceability processes. The approval and monitoring procedure shall be based on one or a combination of:
●● supplier audits
●● third party audits or certification, e.g. to BRC Global Standards
●● supplier questionnaires.
Where approval is based on questionnaires, these shall be reissued at least every three years and suppliers required to notify the site of any significant changes in the interim.

So, as you can see is it enough to send a questionnaire (I assume, this is the "paperwork" you want them to complete) or require third party certifications. For growers (no packing) Global Gap is sufficient third party food safety certificate. I would like to see a questionnaire in combination with Global Gap certificate.

[Charles.C]

Dear Mica,

 

As per yr OP -

 

Under this certification can we bring in soft fruit from Portugal or any other country for that matter. I would obviously expect our supplier to be B R C certified and we would have to do an audit of the supplier to ensure they complied with the food standards required

.

The previous post extends yr original opinion.

 

The requirements of your own customers may also be relevant.?

 

Rgds / Charles.C

[mica]

Dear Madam A D-tor

 

Thank you this is extremely helpful.

Yes certification copy required, also health screening questionnaires, traceability, flow diagram, HACCP procedures, plant passports, chemicals used/spray charts, temp control docs, packaging verification and transport safety procedure, cleaning procedures where applicable.

 

Mica

[mica]

Dear Charles C

 

Yes customer requirements would determine what and where we purchased from. I assume they would also have input inot the documentation they would want to see?

 

Mica

[Charles.C]

Dear mica,

 

IMEX of supplying UK importers (not fruit) the major companies QA routinely either personally audit their external suppliers / sub-suppliers or use 3^rd party organizations to do the work for them. Particularly at start-up. This is additional to requiring BRC certification. Questionnaires, pictures, etc can be useful but, from my own experience as an importer, the reality at ground level is sometimes surprisingly different. Either way. A case of seeing is believing.

 

Regarding UK input, I guess it depends on the degree of diligence in the UK fresh produce industry. Maybe a rhetorical comment.

 

Rgds / Charles.C

[mica]

Dear Charles C

 

Yes I was wondering along those lines, paperwork can look very good. I will make the suggestion to my bosses that we need to visit initially at least to satisfy ourselves that we are sourcing from a reliable supplier.

 

Thank you

 

Mica

[Madam A. D-tor]

Dear Mica,

 

You will be fine.

I think you have good ideas, how to control these suppliers.

[mica]

Dear Madam A D-tor

 

Thank you, I will do  my best.

 

Mica