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BRC Version 7 Draft - What did you think?


Best Answer Rafaelescalera, 12 September 2014 - 05:47 PM

Hi, I leave BRC draft v.07, if you are interested.

regards Go to the full post


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#1 cazyncymru

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Posted 12 May 2014 - 02:01 PM

Anyone seen the draft, what do you think?


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#2 mgourley

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Posted 12 May 2014 - 08:56 PM

No, but I'd like to. Hint, Hint.

 

Marshall


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#3 Simon

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Posted 12 May 2014 - 09:15 PM

The consultation draft is available for download and comment: BRC Global Standard for Food Safety Issue 7 consultation document


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#4 mgourley

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Posted 12 May 2014 - 11:05 PM

You have got to be kidding. I just spent almost an hour reviewing the draft and typing my comments. All lost.

Well, if I have another hour to kill, maybe I will recreate it.

 

Basically, many things are being driven by FSMA. There is also some very specific things about labeling and packaging control. It's now a Fundamental. The other thing I see is that producers are somehow supposed to predict how consumers may misuse the product. The other big thing is that as producers, we are required to carry out a vulnerability assessment of all raw materials that takes into account:

Historical evidence of substitution or adulteration

Economic factors

Ease of access to raw materials through the supply chain

Sophistication of routine testing to identify adulterants

 

Marshall


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#5 trubertq

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Posted 13 May 2014 - 07:21 PM

These are my thoughts on first glance..... with 1 week to go til audit....  :helpplease:

1. What are your Raw materials

2. Where do you source them

3. Risk assess the likelihood of them being substituted or tampered with

4. How can you control access to them between your supplier and you and you and the customer to prevent adulteration/substitution

5. Can you identify adulterants if they have been added

 

Thank you Horse meat scandal for adding another layer of meaningless checks for those of us not in the meat processing industry....


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#6 mgourley

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Posted 14 May 2014 - 04:02 AM

Indeed. We make bread. Bread requires wheat, and milling into flour, etc. We need to ensure, or risk assess, that someone with a communicable disease did not piss in the wheat field?

Illustrating absurdity by being absurd.

 

Marshall


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#7 Hankesg

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Posted 14 May 2014 - 11:50 AM

You should of seen our CEO's eyes glaze over when I went over this in the staff meeting yesterday. He is a classic conservative entrepreneur, and does not enjoy when I talk about FSMA and such, which this new draft appears to be incorporating. 

 

I wasn't too shocked by what I saw in the draft. We're building towards BRC and already had most of this stuff in mind. Honestly, packaging standards being included was probably the biggest "surprise" to me. 


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#8 trubertq

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Posted 14 May 2014 - 06:49 PM

Indeed. We make bread. Bread requires wheat, and milling into flour, etc. We need to ensure, or risk assess, that someone with a communicable disease did not piss in the wheat field?

Illustrating absurdity by being absurd.

 

Marshall

Q.E.D.


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#9 mgourley

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Posted 14 May 2014 - 07:51 PM

My read and comments. I had an hour to kill.

 

Marshall

Attached Files


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#10 Simon

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Posted 14 May 2014 - 07:58 PM

My read and comments. I had an hour to kill.

 

Marshall

 

Tremendous work Marshall, I'm sure that will be an invaluable document for members.


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#11 Snookie

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Posted 14 May 2014 - 08:29 PM

 

Indeed. We make bread. Bread requires wheat, and milling into flour, etc. We need to ensure, or risk assess, that someone with a communicable disease did not piss in the wheat field?

Illustrating absurdity by being absurd.

 

Marshall

 

 

 

Q.E.D.

 

:roflmao:      :rofl2:    :roflmao:   :rofl2:    :roflmao:        :rofl2::roflmao:             

 

 


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#12 dshapos

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Posted 15 May 2014 - 02:45 PM

On the change to how to predict consumer misuse, I feel like we finally are ahead of the curve.  We spent quite some time developing an Abuse Test for our products that takes into account multiple scenarios of abuse against our handling instructions.  It's now incorporated into our standard new product development protocol.  We sell frozen RTE bakery products, so the testing includes multiple freeze/thaw cycles and hold times at or above normal room temperature conditions.  This has helped us to respond to consumer complaints and close issues quickly.

 

Not thrilled about the packaging changes, but not surprised.

 

Will need to give it several more reviews, but glad that we have some time before it's implemented and we are audited against it!


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#13 Avila

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Posted 16 May 2014 - 03:12 AM

Dear All,

What if products which are previously included in audit scope were not produced anymore for the past years (e.g. due to raw material shortage). Could they excluded from scope?

Please advise. Thanks

Rgds,

Avila


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#14 relsbels

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Posted 18 May 2014 - 11:07 PM

Just informed my CEO there is a new version coming and the changes etc....his eyes glazed over and there was minimal response.  He has me working on a project to develop, document and implement a BRC compliant system and just wants it done but doesn't want to contribute...making it very hard...very little cooperation from the floor staff too and when the guy at the top shows disinterest makes it even harder.


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#15 Charles.C

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Posted 19 May 2014 - 02:49 AM

Just informed my CEO there is a new version coming and the changes etc....his eyes glazed over and there was minimal response.  He has me working on a project to develop, document and implement a BRC compliant system and just wants it done but doesn't want to contribute...making it very hard...very little cooperation from the floor staff too and when the guy at the top shows disinterest makes it even harder.

Dear relsbels,

 

i sympathise but one has to remember that BRC is not a non-profit organisation (I presume).

 

One obvious alternative is, customer/product/process/environment permitting, to look for a (probably) more "stable" alternative, eg FSSC22000.

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C


#16 Marco Stefano

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Posted 19 May 2014 - 08:23 AM

Marshall, thanks for your comments doc - very useful. My printed copy was covered in sticky notes last week... The first half of next year is going to be busy.

 

Another I find odd is the new text in 5.3.1:

'A list shall also be available of products which do not contain allergens and therefore need to be protected from contamination.'

 

Surely any product need to be protected from inappropriate allergen contamination, whether it has an allergen in it or not? If egg gets into a peanut-containing product and the egg is not supposed to be there and is not mentioned on the label, it is still a big problem. Hmm.

 

 Marco.


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#17 R.Tindale

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Posted 19 May 2014 - 09:33 AM

What does everyone think of the proposed new grading system of Excellent, Good and Satisfactory?  With a maximum of 3 minors for the top grade it will now be much more difficult to get an Excellent grade.


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#18 R.Tindale

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Posted 19 May 2014 - 10:05 AM

Wow that is great.  My problem is that I am the only Technical Manager in the company and have 9 sites to look after.  I wouldn't mind so much if each site had a Quality Manager but the only other Manager each site has is a Production Manager.  Have managed to get grade A's for all sites with issue 6 but don't have enough time to spend on each site to be on their case enough to enable 3 minors or less for all sites.

 

Oh well, if they want the top grade for issue 7 then they will have to take on additional staff, so won't hold my breath.


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#19 bacon

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Posted 19 May 2014 - 08:38 PM

Just a note on 1.1.3 (saw that coming), there is a handy FDA free download I played with last December: 

 

FDA food defense plan builder (http://www.accessdat.../fdplanbuilder/) is quite interesting once you dig into a wee bit“food defense” with “site security” sometimes called “Operational Risk Management” [Security of Property/Product/Personnel]. This is all GFSI anyway… but don’t know if FDA will push this on FSMA “exempt” industries like 21 CFR 123  (seafood), 113 (L-A canning),  120 (juice)…

 

If you upload it (not very big)

 

An interesting tool:

 

If you download the program:

1)      2nd tab "Broad Mitigation Strategies":

a)      is exactly what I was thinking when tracking the GFSI Benchmarks.

i)        Clause/Section # hierarchy

ii)       Checklist

iii)     Full Clause/Section Description

iv)     Comments

 

2)      3rd tab “Vulnerability Assessment”:

      a)      A rather simple quantifiable risk assessment structure (by flow/process steps) and identify it as a “action” point.

 

3)      4th tab “Focused Mitigation Strategies”:

      a)      keys off of the flow/process steps of the previous tab, a check mark for all “actions” that apply (a good start to show the user the themes of control actions, and later able to input one’s own actions if there is some variation not listed, “Mitigation Strategiesnot linked with “Action Steps tab 6)

 

4)      6th tad “Action Plan”:

     a)      A summary (but “Action Steps” not refresh/linked to “Mitigation Strategies” on tab 4)

b)      Additional comments able to be added at this point.

 

5)      7th tab “Food Defense Plan”:

    a)      A complete write up of all previous tab inputs:

i)        Company info (tab 1)

ii)       "Broad Mitigation Strategies"

(1)    Section (tab 2)

(2)    Plan Content (tab 2)

(3)    Comments (tab 2)

 

6)      8th tab “Supporting Docs”

    a)      Able to upload documents

 

Food for thought… I thought it was pretty well done as far a architecture (apart from some small quirks) and worth poking around.

 

Cheers,

-B


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#20 mgourley

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Posted 19 May 2014 - 08:44 PM

I also ran this through it's paces when it first came out. I agree that is a valuable tool.Since the FDA created it, one would assume that using it would meet any of their requirements in FSMA relating to "Food Defense"

It's simple to use and walks you through the process. 

 

Marshall


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#21 Naamfon

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Posted 01 June 2014 - 12:01 PM

for the new fundamental of this draft at no. 3.5.1.2-3.5.1.3 seem like to force any supplier or source of RM to get BRC certificte or follow the system ..Ho!!


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#22 GMO

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Posted 06 June 2014 - 01:20 PM

When are the key dates for the new standard, does anyone know?


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#23 monet

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Posted 12 June 2014 - 04:57 PM

Has it been taken offline? Does anyone have a copy?


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#24 Tomato

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Posted 16 June 2014 - 01:14 PM

When are the key dates for the new standard, does anyone know?

 

I was told at recent BRC training that it was to go live Jan 1st 2015 and July 1st was to be the first audits against issue 7.


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#25 KevinB

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Posted 17 June 2014 - 01:19 PM

Thought i would share this.

 

 

Issue 7 of the Food Safety Standard will be published in January 2015 and audits against it will begin in July 2015.

 

Feel free to get back to me if you have further questions.

 

Kind regards,

 

Stefano Ghirardi

Technical Team Administrator | BRC Global Standards

21 Dartmouth Street

London SW1H 9BP

Direct line:  +44 (0) 20 7854 8921 | Web: www.brcglobalstandards.com


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