6 replies to this topic

[rewel]

Hi all,

 

First off, I am so glad I have stumbled across this website/forums and hope to contribute myself soon. however I do need some help regarding 3.6 Specifications in the BRC standard.

 

First of all I will give you some background. I work for a contract wine bottling company. so we don't actually have any raw materials per se and all product is the customers not ours.

 

So I am doing an audit on specifications and am a little stuck.

 

3.6.5 Specifications shall be reviewed whenever products change  (e.g. ingredients, processing method) or at least every 3 years. The date of review and approval of any changes shall be recorded. 

 

 

So I am trying to review specs of suppliers bottle, corks, closures any primary packaging really and any chemicals that are used in the 'open area. I have obtained the specs but how do I prove that I have reviewed them? or how do I prove that the supplier has reviewed them?

 

Next.

 

3.6.4 The Company shall seek formal agree of specifications with relevant parties. Where specifications are not formally agreed then the company shall be able to demonstrate that it has taken steps to ensure formal agreement is in place.

 

 

What steps can demonstrate that steps have been taken to ensure formal agreement is in place?

 

Thanks in advance

[Sandima]

First things first you are referencing the Issue 6 clauses, are you being audited before July?  If not I would suggest you start transitioning to Issue 7 which is available as a free download.  

 

http://www.brcbooksh...78/brc-bookshop

 

However the clauses you are asking about haven't changed a lot so

           

"3.6.5 Specifications shall be reviewed whenever products change  (e.g. ingredients, processing method) or at least every 3 years. The date of review and approval of any changes shall be recorded. 

 

            So I am trying to review specs of suppliers bottle, corks, closures any primary packaging really and any chemicals that are used in the 'open area. I have obtained the specs but how do I prove that I have reviewed them? or  how do I prove that the supplier has reviewed them?"

 

 

You could keep a list of the specs you have with an issue date and review date or just initial and date the hard copy if that is how you have them.

           

"3.6.4 The Company shall seek formal agree of specifications with relevant parties. Where specifications are not formally agreed then the company shall be able to demonstrate that it has taken steps to ensure formal  agreement is in place.

 

              What steps can demonstrate that steps have been taken to ensure formal agreement is in place?"

 

 

That one is trickier but in the interpretation guide it suggests "where customer's signature or approval is not formally available, proof that specification have been issued (such as an email request for formal acknowledgement or specifications on customer IT specification systems) is required."

 

Do you have a contract with your customer/suppliers (since they are both) stating something to the effect that you are not responsible for the quality of the product beyond defects caused by the bottling process or something like that?

[rewel]

Thank  you for your response. Our audit is in May so issue 6 this time and I have already downloaded issue 7.

 

Most specs are Ok just some are dated back to 2009 and have not changed so the supplier has no need to up date them so the date stays the same. I guess an email from the supplier saying it is current will suffice? I hope.

 

as for the second part that's exactly what I thought. I have a paper trail requesting acknowledgement and our work orders which are signed by the customer act as a contract.

[Sharon]

In regard to the specification review we just add the supplier specs to our document control system and have them come up for review every 12 months.  Any new specs are added to the document control system and are approved by the winemakers etc prior to use and then they go on the yearly review cycle.  We also have issue with our contracts but I would have thought as a contract packer you would have a system in place which requires sign off that the wine matches the parameters it was sent to you with, maybe that will work

[Charles.C]

A 100% Commonwealth thread. (Canada is still in, right ?)

[Madam A. D-tor]

Dear Rewel,

 

Because you are a co-packer, I would not expect you to have specifications from the raw materials.

If you buy your self bottles and lids, you should have these specifications.

You are supplying a service, so you need to have a specification of your services, and these should be agreed by your customers.

[Charles.C]

Dear Rewel,

 

Because you are a co-packer, I would not expect you to have specifications from the raw materials.

If you buy your self bottles and lids, you should have these specifications.

You are supplying a service, so you need to have a specification of your services, and these should be agreed by your customers.

 

I assume you are referring to "responsibility" but I don't quite understand how one can (internally) control their process without RM specifications ?

 

There is also a (vaguely) related (UK) thread here where a copacker receives labels which are observed as incomplete (regarding allergens). Appears the copacker  likely cannot (legally) avoid responsibility by "closing their eyes" if a FS incident subsequently occurs.