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BRC 1.1.2, looking for examples of objectives for legality

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marc40

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Posted 14 February 2018 - 08:50 PM

Hello Everyone,

 

This is my first post, so if I break any protocols please forgive me. I have a question with regard to BRC Clause 1.1.2. I hope this is the correct area to pose such a question. Some background; I'm the Food Safety Coordinator at an almond processor. We are for further processing. They are simply sized and sorted at our facility. We usually ship in 50lb boxes or 2200 bags. They do not undergo a kill step at our facility. Anyway, back to my question. We have had a BRC pre-assessment (real audit is in 3 months). The auditor gave us a NC for not having an objective for legality (BRC 1.1.2). We have customer complaint, quality and food safety objectives though. I'm curious as to what such an objective would look like and how it would be measurable year over year? Any thought?

 

Also, this forum has been a tremendous help as I prepare for BRC. You are all great and thank you very much. 

 

 

Marc 



redfox

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Posted 15 February 2018 - 02:43 AM

Hello Marc40,

 

You are on the right track. This forum had help me a lot.

 

In your objective you to state that you abide all rules and regulations, guidelines on the country you are manufacturing and where you distribute/sell your product.

 

Subscribe to food safety magazine, blogs, trade associations and government agency for updates.

 

regards,

redfox



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Peaches

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Posted 15 February 2018 - 06:07 PM

We included initiated recalls with a goal of 0 in our KPI report (in addition to customer complaints, pre-op inspection 1st time pass results and zone inspection completion).  Part of the requirement is not only to have goals but also to report it.  We included the reporting function in our Meeting Policy as to how often the KPI's are reviewed and by who.  



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marc40

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Posted 15 February 2018 - 11:37 PM

Very cogent. Thanks so much to the both of you. 



TrevorLarson

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Posted 17 February 2018 - 07:53 PM

I don’t think it is the intention of the Standard that the objectives must be set for safety, legality and quality. These three terms are used throughout the Standard

Legality issues are covered under clause 1.1.6, the objective of which is to ensure that sites remain up to date and meet the latest legislation/codes of practice. Some auditors will maintain that this is a requirement and cannot be a company objective.

 

BRC requires that objectives be:

  • Measurable and time-framed (it would be difficult to meet these two requirements in terms of legality)
  • Other requirements are that they are specific, achievable and relevant

Customer complaints, non-conforming products, audit failures or audit non-conformities (internal and external audits), customer rejections or returns are objectives that are measurable.



Charles.C

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Posted 18 February 2018 - 03:03 PM

Hi marc,

 

In respect to the linkage to clause 1.1.6, see this thread (esp Post3)-

 

http://www.ifsqn.com...roduct-is-sold/

 

Don't know much about USA specifics (various Bodies/Federal-State etc eg FDA/USDA) but just as a generic-type example for FS/UK/EEC see -

 

https://www.food.gov...ulation/foodlaw

(eg see the first link, Pg L.31/10 (Section4) et seq)

 

For USA maybe -

https://www.ag.ndsu....ssingregulation

 

i suggest you have a look at yr Product Specification and consider which items are legal Safety/Quality requirements.

(I anticipate that Legal "Quality" Requirements are likely to be a bit of a minefield in USA due since "Adulteration" can overlapp FS/FQ)


Kind Regards,

 

Charles.C




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