15 replies to this topic

[sp13]

Hi all, I hope everyone is enjoying their Bank Holiday.

 

I wanted some feedback on a question which has been bugging me for a while:

 

My prerequisite plans cover what is set out in the BRC Standard and other Retailer guidelines we work to. The plans take what is written in the standard and apply it to our site and how we meet it. 

 

(as an example: 'XYZ Foods shall ensure we have a system in place to ensure products are protected from theft or malicious contamination whilst on site. This shall be achieved through.....') 

 

When it comes it Internal Audits (specifically 3.4.1) - We audit all the Sections of The BRC Standard (in our own internal format) - But it also asks to audit prerequisite plans.

 

What I'm struggling to get to grips with is....my prereq plans and QMS are based on the BRC Standard and are extremely similar.....why should I audit them twice?

 

Am I doing something wrong or is there something I don't quiet understand?

 

Any input is very much appreciated :)

SP

[trubertq]

The prerequisite plan refers to the 15 prerequisites which are the basic conditions and activities that are necessary to maintain a hygienic environment. These will inevitably be covered within your FSMS. I audit the prerequisite programme once per year,usually at the beginning of the year, to make sure that everything that should be in place is in place.  The audit basically consists of going through the 15 prerequisites and detailing what the controls are and where I can find the information. I have attached an example of the record.

Attached Files

•  Pre requisite programme.docx   31.66KB   350 downloads
•  Pre requisite Plan Review Checklist.docx   46.16KB   299 downloads

[sp13]

The prerequisite plan refers to the 15 prerequisites which are the basic conditions and activities that are necessary to maintain a hygienic environment. These will inevitably be covered within your FSMS. I audit the prerequisite programme once per year,usually at the beginning of the year, to make sure that everything that should be in place is in place.  The audit basically consists of going through the 15 prerequisites and detailing what the controls are and where I can find the information. I have attached an example of the record.

 

Thanks trubertq - Can I ask, with regard to your prerequisite plans, how detailed are they?

 

I find myself just rewording the BRC Standard & Customer Standards whilst adding a couple of sentences at the end of each point to show how we achieve this or comply to this as a company (procedure references, document references and so on...) 

 

I fear I may be over-complicating things.

[trubertq]

They're bullet points showing what controls we have and then on the next section, which office/area that information can be found in... f ex the preventative maintenance schedule is in the maintenance workshop, nothing too detailed, and yes it is a good deal of repetition, but once you have done it it's easy to review.

 

The main thing is that you can easily show how you are controlling your PRPs 

[sp13]

Thanks for the feedback trubertq - much appreciated :)

[Tony-C]

Hi all, I hope everyone is enjoying their Bank Holiday.

 

I wanted some feedback on a question which has been bugging me for a while:

 

My prerequisite plans cover what is set out in the BRC Standard and other Retailer guidelines we work to. The plans take what is written in the standard and apply it to our site and how we meet it. 

 

(as an example: 'XYZ Foods shall ensure we have a system in place to ensure products are protected from theft or malicious contamination whilst on site. This shall be achieved through.....')

 

When it comes it Internal Audits (specifically 3.4.1) - We audit all the Sections of The BRC Standard (in our own internal format) - But it also asks to audit prerequisite plans.

 

What I'm struggling to get to grips with is....my prereq plans and QMS are based on the BRC Standard and are extremely similar.....why should I audit them twice?

 

Am I doing something wrong or is there something I don't quiet understand?

 

Any input is very much appreciated :)

SP

 

Hi SP,

 

If you look at the requirements of the BRC Food Standard clause 3.4.1:
There shall be a planned programme of internal audits with a scope which covers the implementation of the HACCP programme, prerequisite programmes and procedures implemented to achieve the standard.
The scope and frequency of the audits shall be established in relation to the risks associated with the activity and previous audit performance. All activities shall be covered at least annually.
BRC Guidance:
The site shall evaluate the risk inherent in each section and determine the frequency of audits accordingly.
For example the site should consider the severity of the consequences if the system or compliance with it is inadequate..........
Frequency may also be influenced by known issues, best practice or customer requirements....

Remember there also a requirement for hygiene inspections in clause 3.4.4.. In addition there shall be a programme of documented inspections....

Prerequisites are also mentioned in HACCP section 2.2.1 Prerequisite programmes may include:
Cleaning and sanitising
Pest control
Maintenance programmes for building and equipment
Personal hygiene requirements
Training
Purchasing
Transport arrangements
Processes to prevent cross-contamination
Allergen controls

So your audit programme should cover all aspects annually as a minimum.

 

Areas identified in your HACCP plan would normally be regarded as high risk and audited more frequently. The requirement to duplicate and audit your prerequisite programmes more than once is based on risk. If you consider the prerequisite programmes then things like allergen control, cleaning & prevention of contamination may be considered higher risk and be audited more frequently.

Finally your audit findings should also be considered if there are lots of issues identified during an audit then as an auditor I would expect to see a follow up audit scheduled.

 

Regards,

 

Tony
 

[sp13]

Thank you for taking your time to reply Tony-C, it is much appreciated.

 

With regards to audit frequencies based on risk, I think I am ok and have a relatively good system in place. I'm begining to think the issue is with my actual PR plans.

 

Would it be too much to ask to see an example of a PR Plan from a member here? It will of course be kept confidential and only used as a comparison to mine.

 

Many thanks in advance.  

[Tony-C]

These examples are from the BRC Audit RA Tool provided in the IFSQN BRC Food Safety and Quality Management System

 

 BRC Audit Risk 1.png   312.8KB   5 downloads

 

 BRC Audit Risk 2.png   368.34KB   2 downloads

 

Regards,

 

Tony

 

[sp13]

Many thanks Tony - your help is always appeciated 

[Charles.C]

Hi Tony,

 

Nice graphics.

 

The first one seems to imply that an excellent MS can still produce a lousy FS ? Can they be Independent ?

 

Rgds / Charles

[Tony-C]

Hi Tony,

 

Nice graphics.

 

The first one seems to imply that an excellent MS can still produce a lousy FS ? Can they be Independent ?

 

Rgds / Charles

 

Thank you for your comments Charles,

 

For me it is a food safety management system. Not a management system, a management system is what?

 

You can have great policies and not implement them as I'm sure you know, so it is not just about auditing what we say we're going to do it is more about checking that we are  doing it! Wouldn't you agree?

 

The first image shows assessment regarding policy which is changed infrequently and so audited less frequently for compliance against the BRC standard.

 

The other sections and images represent areas where there is greater risk of change or something detrimental happening, some of it may be covered by GMP audits, hopefully you see the logic.

 

Regards,

 

Tony

Edited by Tony-C, 16 May 2014 - 04:27 PM.

[Charles.C]

Hi Tony,

 

One can also have good / bad Policies of course. And Procedures, etc.

 

I agree with you that it’s necessary to continually be aware of the “Big Picture”. A question of “Structuring” perhaps.? And specific examples ?

 

I also agree as to the usefulness of RA in prioritizing routes for achieving food safety. It’s also a wonderful crutch for avoiding details. And yet maintain support for due diligence.

 

Rgds / Charles

Edited by Charles.C, 17 May 2014 - 05:16 AM.
edited for clarity

[Tony-C]

Hi Tony,

 

One can also have good / bad Policies of course. And Procedures, etc.

 

Rgds / Charles

 

Nope I only have good ones

[Oraine]

how do i download BRC tool

[Tony-C]

how do i download BRC tool

 

Hi Oraine,

 

BRC Audit RA Tool is provided in the IFSQN BRC Food Safety and Quality Management System

 

Regards,

 

Tony

[vazelos64]

Thank you for the files. Most helpful!