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BRC v7 audit findings please help

brc risk assessment suppliers vulnerability assessment

Best Answer nkonstas, 30 May 2016 - 06:49 AM

Thanks a lot Karenconstable for your feedback. This excell worksheet is helpful but its not complete and i dont want to pay for something that i can find for free...

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#1 nkonstas

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Posted 20 May 2016 - 02:09 PM

3.5.1.1

Major

Documented risk assessment for suppliers against allergen, micro, chemical, foreign body risks and substitution or fraud not available.

 

5.4.2

Major

No documented vulnerability assessment carried out for raw materials or group of raw materials to assess potential risk of adulteration or substitution. 

2.3.1

Product specifications made no reference to aw (chemical proporty with impact to food safety), foreign bodies and origin of ingredients.

 

Good evening to all,

I am QA Manager and Production Manager in a small company in Greece that produces dry mixtures from powders (main raw materials:milk powder,sodium caseinate,whey,gelatine and other like modified potato starches,perservatives,gums). As we (me and my boss) trying to make an implementation in the above auditors findings we fall in a turbulence of informations & tools in order to fix these issues.

3.5.1.1.: if we ask from our suppliers their Risk Assessment for their raw materials and combine them into a summary table is it ok? If they are BRC or IFS certified isnt enough for me in order to list them as low risk?

5.4.2 : We complete a VA from ssafe but we have a problem to decise in which risk level are we. Is this VA enough ?

2.3.1 : a) Foreign bodies: in our haccp plan we hwve identified tha our ccp is the diametre of foregn bodies larger than 7mm so we have a sieve 7mm. Are we obliged to write this in all our products technical sheets?

Country of Origin: We have 4 suppliers (IFS,BRC,ISO cert like Meggle,Ornua,Carberry F+S) for milk products that Have the oval stamp from EU (Ireland,Germany,Sweden,UK), some other ingredients like Beetroot Red and flavours are from France etc, is it very difficult to change the TD every time that we change supplier. How much important is it. Is there a way to validate that is immposibble to make these changes but I have the treacability system in order to provide the infos to anyone that concerned?

 

We try and we achieve to produce safe and trusted products for the domestic market and for our exports to Balcan area and South Africa so I think that these Major issuses are more burreocratic aspects and could be solved. We dont want to pay extrernal consultants for 1 main reason : we want to learn from this proccess and be more adaptive in any changes.

 

Sorry for the long post and I will be very gratefull in any infos.

 

Attached Files


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#2 Charles.C

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Posted 20 May 2016 - 06:12 PM

3.5.1.1

Major

Documented risk assessment for suppliers raw materials against allergen, micro, chemical, foreign body risks and substitution or fraud not available.

(this implies a response for quality/legality was available - strange)

 

5.4.2

Major

No documented vulnerability assessment carried out for raw materials or group of raw materials to assess potential risk of adulteration or substitution. 

2.3.1

Product specifications made no reference to aw (chemical proporty with impact to food safety), foreign bodies and origin of ingredients.

 

Good evening to all,

I am QA Manager and Production Manager in a small company in Greece that produces dry mixtures from powders (main raw materials:milk powder,sodium caseinate,whey,gelatine and other like modified potato starches,perservatives,gums). As we (me and my boss) trying to make an implementation in the above auditors findings we fall in a turbulence of informations & tools in order to fix these issues.

 

(1) 3.5.1.1.: if we ask from our suppliers their Risk Assessment for their raw materials and combine them into a summary table is it ok?

afaik, this RA relates to the significance (eg high/Low risk) from the POV of your own process. So probably NO.

(2) If they are BRC or IFS certified isnt enough for me in order to list them as low risk?

Please note that BRC7 does not define what BRC means by a "low risk" Supplier, eg does it refer to a Supplier of Low Risk raw material ?

Regardless, evidence of a current,satisfactory Supplier audit for a GFSI recognized Standard should be sufficient for the Supplier's Approval mentioned in 3.5.1.2.

 

5.4.2 : We complete a VA from ssafe but we have a problem to decise in which risk level are we. Is this VA enough ?

Yr attachment IMO is not fully compliant to clause 5.4.2, eg details of detection capability, lack of an overall Result.

2.3.1 : a) Foreign bodies: in our haccp plan we hwve identified tha our ccp is the diametre of foregn bodies larger than 7mm so we have a sieve 7mm. Are we obliged to write this in all our products technical sheets?

A "diameter" would be a Critical Limit, not a CCP. Unclear if this includes items such as metallic contaminants. If yes, the limit is likely to be a Regulatory issue so would be auto-defined. IMEX Customers generally have stricter expectations than 7mm so such a statement might be unusable if a mutually agreed specification involved.


Country of Origin: We have 4 suppliers (IFS,BRC,ISO cert like Meggle,Ornua,Carberry F+S) for milk products that Have the oval stamp from EU (Ireland,Germany,Sweden,UK), some other ingredients like Beetroot Red and flavours are from France etc, is it very difficult to change the TD every time that we change supplier. How much important is it. Is there a way to validate that is immposibble to make these changes but I have the treacability system in order to provide the infos to anyone that concerned?

Sorry, not my area. What is "TD" ? technical data ?

 

We try and we achieve to produce safe and trusted products for the domestic market and for our exports to Balcan area and South Africa so I think that these Major issuses are more burreocratic aspects and could be solved. We dont want to pay extrernal consultants for 1 main reason : we want to learn from this proccess and be more adaptive in any changes.

 

Sorry for the long post and I will be very gratefull in any infos.

 

Hi nkonstas,

 

Hope the above is helpful.

 

Yr BRC queries are good ones but an exact answer is difficult since a variety of user interpretations of the clauses mentioned exists. Seemingly, for auditors also.

Other people here may have some different opinions.

 

PS - Welcome to the Forum !  :welcome:


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Kind Regards,

 

Charles.C


#3 nkonstas

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Posted 20 May 2016 - 08:32 PM

Thanks for your quick response.

I ve read a lot of post that are very helpfull to me in order to make a try to understand these sophisticated interpretantions.

First of all my bussines is certified with brc from 2008 every year (so my boss has a very good sense and for the food safety and for the implementations of the BRC. I think is a very messy aspect this with the food fraud.

 

So concerning your very helpfull answers I also want to give some explanations and to put some further questions. 

 

3.5.1.1 : We have our suppliers questionaires, theis Certification, theis haccp plan, their allergen declaration, technical data sheets from their products we buy. 99% of them are big companies (i.g. newly, kerry, meggle, carberry,eps-liot,cargill,amsland) and we have over 10 years of trusted relationship. So they are trusted suppliers with no incidents in our company (i.g mislabbeled products,bad organoleptic characteristics, expired, misseing bags, foreign bodies etc). And from this point of view I say, if I ask them their food vunerability assessment plus the documents I mentioned before, I summ up them in an appropriate form, and I make a final decision for the risk level of their final products , I can claim that this is a risk assessment for my raw materials.

So i want a appropriate form to sum up these informations.

 

5.4.2  Yes you are right but we dont have preventing and control measures if a fraud happens. To explain if a supplier of us in the sodium caseinate has adultarated it with milk or whey it is very very difficult to recognise it and only the costumer of us can detect them bec their final productfrom our mixtures wont be the same as they have for many years. so our control measure as we dont have the money to make all thes expensive lab analises is the satisafction of our costumers and their final products. maybe we have to establish a method for controlling them. but as for naow we dont have any incidents for fraud. Our  raw materils has no fraud incidents inside EU. Thats why u find 0 in some control measuments at spider webs. If we can validate our answers maybe we can complete the assessment and then we can make an overall report and propose some corrective actions and implement some control points.

 

now for the ccp and haccp plan. this plan has been evaluated every month with no incidents (if they have any at past they crrected them) so the 7mm "diameter" is vald acceptable and passed all the extrernal and internal audits for over 5 years. My question is if i am obliged to write it down in our product technical specs. The auditors mentioned that bec the costumers of our products has to know what is the limit of foreign bodies dimension that we sieve and in order to acieve his limit to continue or not to smaller sieving. As for the other factors, metallic materials and so, our suppliers have metal detectors so we have decided not to install one, we know their size of last filtratio/sieving so we can claim that our ccp is only this..

 

Wish all of you a nice weekend. Thanks for your attention. (I am new in the sector of food so i have many questions. my previous working exp was at paint/adhesives and cosmetics in production)


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#4 Charles.C

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Posted 20 May 2016 - 10:32 PM

Thanks for your quick response.

I ve read a lot of post that are very helpfull to me in order to make a try to understand these sophisticated interpretantions.

First of all my bussines is certified with brc from 2008 every year (so my boss has a very good sense and for the food safety and for the implementations of the BRC. I think is a very messy aspect this with the food fraud.

 

So concerning your very helpfull answers I also want to give some explanations and to put some further questions. 

 

3.5.1.1 : We have our suppliers questionaires, theis Certification, theis haccp plan, their allergen declaration, technical data sheets from their products we buy. 99% of them are big companies (i.g. newly, kerry, meggle, carberry,eps-liot,cargill,amsland) and we have over 10 years of trusted relationship. So they are trusted suppliers with no incidents in our company (i.g mislabbeled products,bad organoleptic characteristics, expired, misseing bags, foreign bodies etc). And from this point of view I say, if I ask them their food vunerability assessment plus the documents I mentioned before, I summ up them in an appropriate form, and I make a final decision for the risk level of their final products , I can claim that this is a risk assessment for my raw materials.

So i want a appropriate form to sum up these informations.

 

Please see Excel attachment in link below which also contains various sub-links.and other attachments -

http://www.ifsqn.com...plier-approval/

(there are also several other links on same topic/sub-topics on this forum)

 

5.4.2  Yes you are right but we dont have preventing and control measures if a fraud happens. To explain if a supplier of us in the sodium caseinate has adultarated it with milk or whey it is very very difficult to recognise it and only the costumer of us can detect them bec their final productfrom our mixtures wont be the same as they have for many years. so our control measure as we dont have the money to make all thes expensive lab analises is the satisafction of our costumers and their final products. maybe we have to establish a method for controlling them. but as for naow we dont have any incidents for fraud. Our  raw materils has no fraud incidents inside EU. Thats why u find 0 in some control measuments at spider webs. If we can validate our answers maybe we can complete the assessment and then we can make an overall report and propose some corrective actions and implement some control points.

Please see above link, particularly Excel, Sheet 2.

 

now for the ccp and haccp plan. this plan has been evaluated every month with no incidents (if they have any at past they crrected them) so the 7mm "diameter" is vald acceptable and passed all the extrernal and internal audits for over 5 years. My question is if i am obliged to write it down in our product technical specs. The auditors mentioned that bec the costumers of our products has to know what is the limit of foreign bodies dimension that we sieve and in order to acieve his limit to continue or not to smaller sieving. As for the other factors, metallic materials and so, our suppliers have metal detectors so we have decided not to install one, we know their size of last filtratio/sieving so we can claim that our ccp is only this..

Yes, a typical Product Specification has details of BCPA characteristics of the Product. This could include statements such as "Foreign Bodies - free of hazardous foreign materials > Xmm". IMEX BRC are very attentive to Metal Detectors, eg clause 4.10.3.1

As to the ("diameter"),  I can only refer you to the Codex definition of a CCP. But not to yr auditors. :smile:

 

Wish all of you a nice weekend. Thanks for your attention. (I am new in the sector of food so i have many questions. my previous working exp was at paint/adhesives and cosmetics in production)

 

Hi nkonstas,

 

Thks for yr detailed comments.

 

Clearly if you have developed a satisfactory auditorial procedure for BRC no reason to change anything.

 

With respect to the 3.5..., 5.4... clauses,  afaik certain items (eg those preceded by a "shall") must be specifically referenced in responses to the related clauses. if yr auditors do not follow this logic that is yr good luck and i am happy for you. (Also perhaps the Greek version does not everywhere exactly match the English one ?.)

 

With respect to the  Vulnerability Assessment, I also suggest if not already done, to have a look at the BRC Interpretation Guidelines document which is quite informative. Again, there seems to currently be a range of auditorial expectations for this "new"  feature (probably triggered for BRC  by the Horsegate Incident).


Edited by Charles.C, 21 May 2016 - 03:49 AM.
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Kind Regards,

 

Charles.C


#5 Karenconstable

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Posted 30 May 2016 - 04:11 AM

Hi nkonstas,

 

With regards to the clause 5.4.2, you have completed a vulnerability assessment with ssafe but say you have a problem to decide which risk level you are in.  There is another tool which might be helpful to you. It has been created by food fraud specialists for people who are new to the food industry like you.  It calculates the risk level for you, based on your answers to questions about your ingredients.  All the calculated results can be over-ridden if you don't agree with them.  It also automatically creates reports for the auditor.  It is based on the BRC's own guidance document for vulnerability assessments. You can find it here  http://www.foodfraud...-tool-for-gfsi/

 

Regarding the 7mm diameter foreign objects, yes, if that is the size you have defined then it should be in your product specification or technical data sheet and the statement suggested by Charles C (above) is very good.


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#6 nkonstas

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Posted 30 May 2016 - 06:49 AM   Best Answer

Thanks a lot Karenconstable for your feedback. This excell worksheet is helpful but its not complete and i dont want to pay for something that i can find for free...


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