26 replies to this topic

[binhchau]

 

addendum - to answer my own comment -  this looks like a more precise summary - (3,4,9) look additionally notable points. (5) is nicely subjective.

 

1. Your raw material risk assessment must now be reviewed annually. (Clause 3.5.1.1)
2. The raw material risk assessment must now include substitution or fraud of ingredients (this section covers packaging but substitution or fraud need only cover ingredients), but the vulnerability assessment conducted in section 5.4 can be used to cover this requirement. I’m not really sure why they didn’t include the requirements of 5.4 in this section, it makes it confusing splitting them up. (Clause 3.5.1.1)
3. Supplier approval and monitoring must now include food contact packaging, but also consumer packaging – which means any packaging that the consumer receives with the products (even if it’s not food contact). (Clause 3.5.1.2)
4. The scope of supplier audits has now been defined to include as a minimum HACCP, traceability, product safety and GMP. (Clause 3.5.1.2).
5. Supplier audits must also be carried out by an experienced and demonstrably competent auditor. This means that the auditor doesn’t need to be qualified but must be able to demonstrate that they know how to complete an audit to a good standard. (Clause 3.5.1.2)
6. Supplier questionnaires can no longer be used for any suppliers, other than those that are defined by the supplier risk assessment as low risk. (Clause 3.5.1.2)
7. You also now need to have an up to date list of approved suppliers. (Clause 3.5.1.2)
8. When using agents and brokers, all approval and monitoring criteria must be applied to the last manufacturer or packer of the material, to assess just the agent/broker is not sufficient. Unless, the agent or broker holds a BRC Agents & Brokers certificate – if they do, to assess just the agent/broker is acceptable. (Clause 3.5.1.3)
9. Where raw materials have been used without following the approval process (these are known as exceptions), these exceptions must be made known to your affected customers – implying that they would need to approve. (Clause 3.5.1.4)

 

Hi Charles

I am very embarrassed for 3.5 clause BRC 7, can you give a detailed guideline or template to make this document?.

thank you very much

Ms Chau

Edited by Charles.C, 15 June 2016 - 04:28 PM.
split from topic 25046

[Meat Hook]

Risk assess by commodity and geographic location then you will have a better idea. Some cases COA's by lot will suffice

[Charles.C]

Hi Charles

I am very embarrassed for 3.5 clause BRC 7, can you give a detailed guideline or template to make this document?.

thank you very much

Ms Chau

 

Hi Ms Chau,

 

Can try this thread -

 

http://www.ifsqn.com...al/#entry100194

[binhchau]

Hi Ms Chau,

 

Can try this thread -

 

http://www.ifsqn.com...al/#entry100194

Hi Charles!

Thanks for your information

I have a question: 3.5.1.1 clause included 5.4.2 clause, why does BRC require 5.4.2 risk assessment?

I must do 02 different risk assessment, right?

Wait information from you

BinhChau

[Charles.C]

Hi Charles!

Thanks for your information

I have a question: 3.5.1.1 clause included 5.4.2 clause, why does BRC require 5.4.2 risk assessment?

I must do 02 different risk assessment, right?

Wait information from you

BinhChau

 

Hi BinhChau,

 

As I interpret, clause 3.5.1.1 is an overall risk assessment for raw materials for which it is necessary to provide various inputs.

 

The main haccp plan will probably contain some input for clause 3.5.1.1

 

Clause 5.4.2 details the criteria for the Vulnerability Assessment (VA) which is another input required for Clause 3.5.1.1. (eg see Excel sheet in link/Post 3)

 

The detailed VA could have been included into one sheet for the overall risk assessment (eg see Anika's layout in one of the sublinks of link in Post 3). I chose to separate the VA onto another sheet and use the result in 3.5.1.1. Just depends how one chooses to do it.

 

Hope the above makes sense.

[binhchau]

Hi BinhChau,

 

As I interpret, clause 3.5.1.1 is an overall risk assessment for raw materials for which it is necessary to provide various inputs.

 

The main haccp plan will probably contain some input for clause 3.5.1.1

 

Clause 5.4.2 details the criteria for the Vulnerability Assessment (VA) which is another input required for Clause 3.5.1.1. (eg see Excel sheet in link/Post 3)

 

The detailed VA could have been included into one sheet for the overall risk assessment (eg see Anika's layout in one of the sublinks of link in Post 3). I chose to separate the VA onto another sheet and use the result in 3.5.1.1. Just depends how one chooses to do it.

 

Hope the above makes sense.

Thank you very much

If my supplier have BRC or GFSI recoginised scheme, i will not do 3.5.1.1 and 5.4.2 because BRC controlled these issue, right?

BinhChau

[Charles.C]

Thank you very much

If my supplier have BRC or GFSI recoginised scheme, i will not do 3.5.1.1 and 5.4.2 because BRC controlled these issue, right?

BinhChau

 

Hi BinhChau,

 

Unfortunately not right.

 

You are maybe confusing 3.5.1.1 and 3.5.1.2. (risk assessment of raw materials / Supplier approval).

[binhchau]

Hi BinhChau,

 

Unfortunately not right.

 

You are maybe confusing 3.5.1.1 and 3.5.1.2. (risk assessment of raw materials / Supplier approval).

 

 

Many thanks

5. Supplier audits must also be carried out by an experienced and demonstrably competent auditor. This means that the auditor doesn’t need to be qualified but must be able to demonstrate that they know how to complete an audit to a good standard. (Clause 3.5.1.2).

For above clause, how to supplier audit (direct assessment, indirect assessment, base on history of supplier) for high, medium risk (supplier had not BRC certification or GFSI recognised scheme)

I can choose how to assess, right?

Please help me

Thanks so much

BinhChau

[Charles.C]

Many thanks

5. Supplier audits must also be carried out by an experienced and demonstrably competent auditor. This means that the auditor doesn’t need to be qualified but must be able to demonstrate that they know how to complete an audit to a good standard. (Clause 3.5.1.2).

 

For above clause, how to supplier audit (direct assessment, indirect assessment, base on history of supplier) for high, medium risk (supplier had not BRC certification or GFSI recognised scheme)

I can choose how to assess, right?

Please help me

Thanks so much

BinhChau

 

Do you mean a self-audit or a 3rd party audit ?

 

PS - with respect to yr previous post, in theory the supplier could/should assist with the Vulnerability Assessment. In practice maybe not so simple.

[binhchau]

Do you mean a self-audit or a 3rd party audit ?

 

PS - with respect to yr previous post, in theory the supplier could/should assist with the Vulnerability Assessment. In practice maybe not so simple.

It is Self-audit because some suppliers had not BRC or GFSI but they are high risk.

[Charles.C]

It is Self-audit because some suppliers had not BRC or GFSI but they are high risk.

 

Hi Binhchau,

 

I have attached a file dated Jan,2016 which covers the, then, available routes for obtaining a BRC supplier audit.

 

For a self-audit, I daresay the necessary requirements would minimally  be those stated in clause 3.5.1.2. There may be further recommendations in the BRC Interpretation Guidelines. The specific details, afaik, are up to you.

 

 BRC7 Options for a 'supplier audit'.pdf   969.68KB   254 downloads

[binhchau]

Hi Binhchau,

 

I have attached a file dated Jan,2016 which covers the, then, available routes for obtaining a BRC supplier audit.

 

For a self-audit, I daresay the necessary requirements would minimally  be those stated in clause 3.5.1.2. There may be further recommendations in the BRC Interpretation Guidelines. The specific details, afaik, are up to you.

 

BRC7 Options for a 'supplier audit'.pdf

Thank very much

I will read carefully

[binhchau]

Thank very much

I will read carefully

Hi Charles!

As guideline of BRC 3.5.1.1

it should consider:

•             Known hazards associated with the ingredient provided or components of it (examples of hazards include …….. histamine in fish

•             Use of the ingredient

•             Spread of ingredient in the company/final products.

•             Nature of the supplier.

•             Historical evidence of the supplier and raw material.

•             Geographic origins (products from particular origins may carry a greater risk due to environmental conditions, because of more relaxed local legal requirements or a less developed food safety culture).

•             Methods of manufacture (e.g. if a site is using pineapple as an ingredient, the risk will depend on whether fresh or canned pineapple is used).

•             Significance of the ingredient to the final product

•             Customer or legislative requirements (e.g. suppliers may be specified by customers, but this does not negate the need for risk assessment).

•             The potential for fraudulent activity in the supply chain

 

 

Where can I find out information to assess above items? What's website?

Please help me

thanks

BinhChau

[Charles.C]

Hi binhchau,

 

For example, see the first five links here (and many other related threads) -

 

http://www.ifsqn.com...ty/#entry103069

[binhchau]

Hi binhchau,

 

For example, see the first five links here (and many other related threads) -

 

http://www.ifsqn.com...ty/#entry103069

Hi Charles!
Five link for 5.4.2, I need information for 3.5.1.1

Risk assessment with 05 point (allergen, foreign matter, microbiology, chemical, fraud), auditor of certification body said that it is not clear and enough.

[Charles.C]

Post 3 ?

[binhchau]

Post 3 ?

Overal risk assessment must be consider 05 point (allergen, foreign matter, microbiology, chemical, fraud)

[Charles.C]

Hi binhchau,

 

I meant - Please open the link/thread  in Post 3 and study the contents.

[binhchau]

Hi binhchau,

 

I meant - Please open the link/thread  in Post 3 and study the contents.

Yes, Charles but the base to risk assessemt as guideline of BRC is so difficut

For example, to consider "Geographic origins (products from particular origins may carry a greater risk due to environmental conditions, because of more relaxed local legal requirements or a less developed food safety culture)"

[Charles.C]

Yes, Charles but the base to risk assessemt as guideline of BRC is so difficut

For example, to consider "Geographic origins (products from particular origins may carry a greater risk due to environmental conditions, because of more relaxed local legal requirements or a less developed food safety culture)"

 

Hi binhchau,

 

Remember that the "Interpretation Guidelines" is not an auditable document. You are only required to respond to the contents of the BRC Standard itself. The exact format of your haccp plan / risk assessment is up to you (and Codex).

 

The intention of the Guidelines is to  assist/recommend  in your responding to the Standard. Some details may be directly  relevant to hazards for your product, some may not, eg the word "particular" in above quote and "should" in Post 13. Most haccp plans for a given product have some hazards in common but not necessarily all.

 

Nonetheless i agree that performing a hazard analysis is not always easy. It typically depends on factors such as those listed by BRC. And training / resources etc.

[binhchau]

Hi binhchau,

 

Remember that the "Interpretation Guidelines" is not an auditable document. You are only required to respond to the contents of the BRC Standard itself. The exact format of your haccp plan / risk assessment is up to you (and Codex).

 

The intention of the Guidelines is to  assist/recommend  in your responding to the Standard. Some details may be directly  relevant to hazards for your product, some may not, eg the word "particular" in above quote and "should" in Post 13. Most haccp plans for a given product have some hazards in common but not necessarily all.

 

Nonetheless i agree that performing a hazard analysis is not always easy. It typically depends on factors such as those listed by BRC. And training / resources etc.

Thanks so much!

If i implement risk assessment with 05 points (allergen, microbiology....) as BRC standard itself, it mean i met BRC, i do not comply "Interpretation Guidelines", right?

[Charles.C]

Thanks so much!

If i implement risk assessment with 05 points (allergen, microbiology....) as BRC standard itself, it mean i met BRC, i do not comply "Interpretation Guidelines", right?

 

Hi binhchau,

 

It is my opinion that you are only required to comply with the contents of the BRC7 Standard (including any subsequent revisions / statements issued by BRC, for example as published on their website / Participate Program ).

 

However, other opinions on this forum may vary from above, for example based on audit experiences. If you wish to be certain as to yr local situation (which according to BRC website should be the same Globally) can always check with BRC directly from their website or  ask the Company whom you are intending to use for yr Certification audit.

 

For a discussion on this topic, can see –

http://www.ifsqn.com...on-conformance/

 

PS – here is an extract from the “explanatory” text informing the availability of the Interpretation Guidelines for BRC6 Food Standard–

 

This Guideline will help food producers to obtain certification to Issue 6 of the Standard. The Guideline discusses the principles behind each of the requirements of the Standard clause by clause, assisting companies to effective implementation across all industry sectors.

[binhchau]

Hi Charles.C

For Vulnerability assessment, Vulnerability Rating = Likelihood Occurence x L. Detection

For Overall assessment, Risk rate = Probability x Severity

Can you help me to explain about 02 above formula.

Thanks very much

Ms Chau

[Charles.C]

Hi Charles.C

(a) For Vulnerability assessment, Vulnerability Rating = Likelihood Occurence x L. Detection

(b) For Overall assessment, Risk rate = Probability x Severity

Can you help me to explain about 02 above formula.

Thanks very much

Ms Chau

 

Hi binhchau,

 

Not sure what you mean by "02" ?

 

For (a) this formula is analogous to the use of  (Likelihood of Occurrence x Severity) in conventional risk matrices as used in haccp/hazard analysis.

For (b) "Overall Risk" estimates a Combined Risk. This is based on modelling techniques developed for risk combination.

[binhchau]

Hi binhchau,

 

Not sure what you mean by "02" ?

 

For (a) this formula is analogous to the use of  (Likelihood of Occurrence x Severity) in conventional risk matrices as used in haccp/hazard analysis.

For (b) "Overall Risk" estimates a Combined Risk. This is based on modelling techniques developed for risk combination.

Hi Charles.C

For (a) Likelihood of Occurrence x Detection

thanks