16 replies to this topic

[mgourley]

This topic was just gone over at the BRC Americas conference.

 

The top 5 globally:

 

1) Supplier Approval

2) Cleaning

3) Vulnerability Assessment

4) Raw Material and Packaging Acceptance and Monitoring

5) Chemical Control

 

The top 5 in the US:

 

1) Chemical Control

2) Ceilings and Overheads

3) Equipment

4) Doors

5) Cleaning

 

Marshall

[Charles.C]

Hi Marshall,

 

Thks for above.

 

One wonders if any attempt is made to rule out local biases within the auditor ranks, eg perhaps Americans are more sensitive to Doors and Ceilings ?

[mgourley]

I think it's probably more likely that in the US, we have a better grasp of and better implementation of some of the other programs and thus more NC's are to be found during the actual plant walk arounds.

 

Don't know how accurate that is, but I suppose it's a possibility.

 

Marshall

[Charles.C]

I think it's probably more likely that in the US, we have a better grasp of and better implementation of some of the other programs and thus more NC's are to be found during the actual plant walk arounds.

 

Don't know how accurate that is, but I suppose it's a possibility.

 

Marshall

 

I suspect it's certainly true in respect to adulteration. But perhaps Necessity is the mother of invention.

[Simon]

Thanks for posting Marshall and interesting to see the difference in the US.  

 

Any ideas why chemical control would be number one? I guess under this umbrella could be not having data sheets, or not storing, handling, labelling, using chemicals in a good way.

 

Regards,

Simon

[mgourley]

Simon,

 

The presenter was not specific as to the reasons. 

My guess would be lack of an approved list. followed by labeling, followed by training.

 

Marshall

[Simon]

Ok thanks Marshall.  Was it a good conference?  Any news?  I guess with Issue 7 food and Issue 5 packaging recently upgraded then a little quiet?

[GMO]

I think it's probably more likely that in the US, we have a better grasp of and better implementation of some of the other programs and thus more NC's are to be found during the actual plant walk arounds.

 

Don't know how accurate that is, but I suppose it's a possibility.

 

Marshall

 

Not sure, it might be due to auditor differences.  I would say in the UK compared with the US plants I know, we are more heavily audited by multiple agencies (think we're up to 80 days a year now) which means that BRC are just one of many, many audits I have and so the time I can spend on BRC prep nowadays is probably a tenth of the time I could spend on it 10 years ago so I probably got more "caught out" on some of the finer detail points than I would have in the past.

[mgourley]

Ok thanks Marshall.  Was it a good conference?  Any news?  I guess with Issue 7 food and Issue 5 packaging recently upgraded then a little quiet?

Yes, it was a good conference. I like the BRC ones because they are relatively small (compared to Food Safety Summit or IAFP), almost always have really interesting presentations that mostly do NOT have to do with BRC and at least two of the last three years, been less than an hour away from where I live.

 

There was some very good info this year about the legal side of FSMA as well as a fairly informative presentation from the Food and Feed Program Director from FDA about the latest on FSMA.

FDA is supposedly going to be providing implementation guidance documents for the different regulations in FSMA, But when I asked the presenter whether there is any timeline for their publication, I was told "no".

Seems like FSA is looking at the end of May for issuance of the Intentional Adulteration Rule.

Other presenters also some good stuff on recall and food fraud.

 

I guess the only "BRC News" is that they will shortly introduce their Standard for Retail an well as a couple of voluntary audit modules, one of which is about a food safety culture.

 

Marshall

[Simon]

Thanks for the update Marshall, yes I forgot the retailer standard...about time, hairnets at last for food workers!   And yes food safety culture is the big area of development.  I know GFSI have a working group on it at the moment; one of the FSF webinar presenters is on the group.  No doubt there will be some requirements in the future that help stimulate commitment and positive culture change.  Good stuff.

 

Regards,
Simon

[Anika]

Hi Everyone,

 

We are currently going through our BRC 7 audit. We have two auditors, the main guy and he's being shadowed by another more experienced guy who is auditing the first one.

 

Day 1 -walk through. HACCP, GMP, Management review, CAR follow-up, More walk through plant. Sanitation, Pest Control. Overall  day 1 went pretty smoothly except for one pest control issue. One of the outside traps had an open lid and the lid can only be opened with lock so it seems very suspicious that it can just fly away.

Day 2-Mock recall, traceability, Internal audit, Walk through, personnel lockers and still going on...

He mentioned, the water temperature in the washrooms were not warm enough. Not sure whether it will be a minor or not.

 

DAY 3- he is supposed to finish the rest of the section by EOB. Let's see    

[Charles.C]

Hi Everyone,

 

We are currently going through our BRC 7 audit. We have two auditors, the main guy and he's being shadowed by another more experienced guy who is auditing the first one.

 

Day 1 -walk through. HACCP, GMP, Management review, CAR follow-up, More walk through plant. Sanitation, Pest Control. Overall  day 1 went pretty smoothly except for one pest control issue. One of the outside traps had an open lid and the lid can only be opened with lock so it seems very suspicious that it can just fly away.

Day 2-Mock recall, traceability, Internal audit, Walk through, personnel lockers and still going on...

He mentioned, the water temperature in the washrooms were not warm enough. Not sure whether it will be a minor or not.

 

DAY 3- he is supposed to finish the rest of the section by EOB. Let's see    

 

Hi Anika,

 

I suggest you ask to see the Standard's specified limit for water temperature. Sounds like running out of possible accusations.

[ViandGroup]

BRC has a booklet that list the top nonconformance's by each category and overall for each category.  It is very informative.

[Anika]

Thanks Charles,

 

The temperature part, was not put in as a Non conformance. So we received 6 minors overall for BRC I7.

[Anika]

Hi Everyone,

 

Update on our BRC I7 audit.

 

*Pest Control-Bait station lid was off

*HACCP-Metal detector in CCP check-sheet is every 2 hours but HACCP procedure said hourly checks.

*Maintenance-Air hose was observed next to extruder and seemed damaged or frayed.

*Wood control-Broken pallets, nails protruding

*Housekeeping-a couple of very minor observations

*Training-Operator was seen reaching under a protective guard on a running machine

 

We thought, the auditor was thorough in the plant but not so much when going through the documents. previous auditors would want to see examples or paper trails but this auditor seemed satisfied with the SOP or going through the procedure itself verbally and through the SOPS.

The last one under training was more a safety issue not food safety but he still put it under training or lack thereof I guess.

There is no lack of safety training but operators here think they are superheroes.

 

Anyways....wood control well... we knew this was going to be an issue again.

Housekeeping, HACCP and Pest control were all one off thing that could have been avoided.

 

We thought this audit was much better than we expected it to be and he actually complimented Supplier approval process and traceability and I honestly think we could do a LOT more on traceability but obviously did not mention it.

 

 

Thanks to everyone for helping me with problems. IFSQN has been extremely helpful and I look forward to coming here soon to bug people or help out in any way I can.

[trubertq]

Well done you!!

[Charles.C]

Hi Anika,

 

Yes Indeed !

 

Congratulations !

 

And thanks for the feedback.