26 replies to this topic

[cazyncymru]

Dear All,

In the quest for perfection we are trying to achieve the BRC/IoP Standard, but in the next six months we will hopefully be moving to a new site. We have all the HACCP now in place and are currently starting to work on sections 4 to 7 in the standard. Would people advise to apply all procedures and policies to both sites, the site we are currently working in or the new site. I ask this as we can write the poilcies so they will be applicable to both sites, but as the new site is currently under construction it is difficult to put it into practice!

Looking forward to your responses

Pete

Peter
I recently audited a packaging supplier using our own in house audit based on BRC/IOP.

To be honest i was aghast at the fact that the site had obtained Grade B against BRC/IOP yet they had very few procedures or documented work instruction!!!

This means that i now have to audit all of our suppliers.

I think that you have to be very careful in the company that you select to carry out your audits as there are obviously varying standards from company to company!

Caz x

PS for a small fee, id happily carry out a preliminary audit for you!!

[Simon]

Oh dear.

Only certification bodies that are accredited to EN45011 (ISO/IEC Guide 65) with the appropriate scope can carry out evaluations against the BRC/IoP Global Standard Food Packaging and issue certificates.

In other words the Certification Bodies are all working to 'exactly' the same script and are Accredited (audited) themselves to ensure the requirements of the BRC/IoP Global Standard Food Packaging are applied consistently throughout the world.

Never mind the Certification Bodies; it looks as though the BRC are struggling to achieve the required consistency amongst Accreditation Bodies.

See this from the BRC website on which Accreditation Bodies they recognise:

"Those Certification Bodies companies who have been, or are being accredited by a national Accreditation Body against specific BRC scopes who have provided demonstrable evidence of working to criteria accepted by the BRC, and demonstrate equivalence of process to the BRC home Accreditation Body UKAS."

These are the countries who's Accreditation Bodies the BRC currently recognise.

http://www.brc.org.u...es_section1.htm

Caz I'm assuming that the company you audited was in the UK and therefore the certification body is UKAS accredited. In which case an even bigger 'OH DEAR' is in order.

Who was the Certification Body? And what sort of things were missing from the suppliers system?

Regards,
Simon

[MartLgn]

I am sure that those of us who undergo BRC/IOP audits are well aware that for all the accreditaion requirements of the certification bodies and UKAS approval that it is impossible to remove the human element, the opinion of the individual from the auditing process. Although the BRC/IOP standard is fairly prescriptive there is also a huge amount of leeway in some of the clauses for an auditor to consider what does and does not meet the requiements.

One feature of the standard is that inspite of the requirement for internal auditing there is no real driver for continuous improvement so after a couple of audits once the frequency becomes annual it can be a case of ticking the boxes, thanks for lunch and see you in 12 months. I am not sure that it is necessarily the fault of individual auditors,after all an experienced auditor visting the same plant for the 5th time should be able to tell failry quickly if things are in order , perhaps the fault lies in the scope and structure of the standard.

[Simon]

I recently audited a packaging supplier using our own in house audit based on BRC/IOP.

To be honest i was aghast at the fact that the site had obtained Grade B against BRC/IOP yet they had very few procedures or documented work instruction!!!

Of course the human element causes some variance in interpretation however, I don't think it's wise for us to second guess Caz's findings. If Caz can post details of the gaps identified we can look at them in context of the requirements of the standard.

Regards,
Simon

[cazyncymru]

Of course the human element causes some variance in interpretation however, I don't think it's wise for us to second guess Caz's findings. If Caz can post details of the gaps identified we can look at them in context of the requirements of the standard.

Regards,
Simon

Gladly Simon

The Auditing Company is approved under UKAS...so here's the first OH Dear!

I obviously can't give too much away, but here are some of the finer points.

Section 3
The only person on site who had done any formal HACCP training was the Technical Manager. In fact he was the only member of the HACCP team!! The Last time HACCP had been reviewed was in Feb 2005.

3.1.1 A formal hazard analysis had been conducted for physical contaminations, but only in part! They had carried this out for potential glass contamination but omitted to include such items as metal swarf's and engineering debis, which was concerning as there were a number of in place knives in their equipment. no analysis was carried out for micro contamination or chemical contamination. The analysis was last reviewed in 2004!

3.5 Monitoring of critical process steps should be included in internal audits. However, they did not carry out internal audits!

4.3.1 Records - no internal auditing, no hand back records from production, no cleaning schedules, no control of sharps.

4.4.3 Work instructions had ammendments that were not dated, countersigned or communicated to supervisor.

4.6.1 No Incident reporting procedure / documentation.

4.9 no internal audits!

4.10 complaints were trended but no investigations/ close out.

4.13.4 external labs accreditation had been withrawn, but continued to be used.

5.4.5 no planned maintenance programme

5.4.11 no hand back procedure, no one could tell me if knives were checked for metal fragments after being sharpened. was just assumed that they were free from contamination.

5.5.9 No record or schedule for cleaning.

6.1.8 no control of sharps although broken blades were disposed of in a sharps container. no documented incident report.

7.3.4 Hand washing only at one entrance. rest of entrances covered by alcohol gel!

7.7.4 Controlled laundry. staff couldnt agree what PPE they'd been issued. But they all agreed that they took it home to wash!!

7.8.2 Half the staff had not done any formal basic hygiene training, and those that had, were done more than 3 years ago.


I could go on and on. As a company we are concerned that this company has BRC/IOP accreditation, and we're now formulatinfg a plan for auditing all of our packaging suppliers. Our first point of reference is to audit everyone who used this UKAS accredited company.

Id be interested to hear what packaging companies and CB's experiences are.

[Charles.C]

Dear Cazyncymru,

Generous and fascinating data and it's certainly true that this reads like an audit horror story but from here on be assured that the QA departments of any company which you come to audit will surely tremble if they see Cazy…. on the audit schedule.
I think Codex does not necessarily prohibit a one-man HACCP team though it's obviously very debatable logic.
Engineering debris - Phew!
Work instructions not countersigned - Hmm.
(should add that I have only been involved BRC food so will cheerfully retract if the above are specified in BRC IOP but I rather got the impression you were aiming straight for the jugular here).

Rgds / Charles.C

[Gaskit]

Dear Cazyncymru,

Generous and fascinating data and it's certainly true that this reads like an audit horror story but from here on be assured that the QA departments of any company which you come to audit will surely tremble if they see Cazy…. on the audit schedule.
I think Codex does not necessarily prohibit a one-man HACCP team though it's obviously very debatable logic.
Engineering debris - Phew!
Work instructions not countersigned - Hmm.
(should add that I have only been involved BRC food so will cheerfully retract if the above are specified in BRC IOP but I rather got the impression you were aiming straight for the jugular here).

Rgds / Charles.C

Dea Cazy,

After reading the above, all bar 2 should have attracted a non conformance of varying degrees and they should NOT (in my opininon) have been granted BRC / IoP certification, indeed the auditor should be "hung out to dry".

Do yourself a favour mate, de-list them and find some other company to supply you.

Kind regards,

Steve

[cazyncymru]

Thank you for your feed back......it's good to know that i haven't over reacted!

I too come from Food BRC, and expected the same standards

obviously not!!

i'll keep you posted!

c x

[Simon]

Deary, deary me. Hello Caz my dear.

It is rather a shopping list of NCR's, are they category A or B? It really is disappointing and bad for the standard and all of us involved with it. It's very important issues like this are raised and passed on to the relevant interested parties; in this case UKAS. I will point them to this thread, but don't worry Caz you don't have to name names if you do not want to.

At the end of the day we do not want the BRC Packaging Standard to become sullied by a rogue Certification Body or two, it's much more important than that and it would be a diservice to the people who have worked so very hard developing and implementing the standard in good faith. The last thing we want to see is customers returning to their own SQA programmes. We have to restore your faith Caz.

If your customer needs help clearing up 7.8.2 you know I can help.

Thanks for the heads up Caz.

Regards,
Simon

[MartLgn]

I could go on and on. As a company we are concerned that this company has BRC/IOP accreditation, and we're now formulatinfg a plan for auditing all of our packaging suppliers. Our first point of reference is to audit everyone who used this UKAS accredited company.

Id be interested to hear what packaging companies and CB's experiences are.

I must have been off when you audited our plant Caz !

Thats quite a list !! I must admit that in the past we have achieved Cat B certification with a couple of the omissions listed down to the interpretation of the auditor, based on this experience and with my devils advocate horns on I would say the following clauses at which your auditee was lacking would be open to interpretation......

Section 3: The standard does not prescribe formal HACCP training for anybody and mentions only 'the company' rather than individuals or a team.

4.9: Pushing it a bit but the standard does not define an internal audit, something less formal than usual may be acceptable to certain auditors.

7.3.4: Dependant on the flow of people around the building an auditor may take a broad view on what constitutes the entrance to a production area.

7.7.4: This is really pushing it but the standard does not prescribe what controlled laundry means, the fact that 7.73 refers to self care for Cat A suggests that home laundering is not acceptable for Cat B but does not say what is.

7.8.2 : There is no mention of a specific period of time for refresher training , leaving the definition of 'appropriate' to the discretion of the auditor.

Now there is no doubt that the majority of the points you raised during your audit are copper bottom Non Conformances but the points I have picked out above
may be ripe for discussion with a suitably amenable auditor after a hearty lunch.

I too come from Food BRC, and expected the same standards

You and dozens of other customers !! The standard promotes the use of 'appropriate' controls and what is appropriate for a chilled food facility is never going to be appropriate for a can factory or a papermill, all that hosing down would play havoc with the cardboard for a start

[cazyncymru]

I must have been off when you audited our plant Caz !

LOL As if you'd take a day off if i were visiting!! You'd spend the whole time trying to distract me as only you know how!!

Thats quite a list !! I must admit that in the past we have achieved Cat B certification with a couple of the omissions listed down to the interpretation of the auditor, based on this experience and with my devils advocate horns on I would say the following clauses at which your auditee was lacking would be open to interpretation......

This company too have category B, and as im in receipt of the standard, i know what they should be aiming for

Section 3: The standard does not prescribe formal HACCP training for anybody and mentions only 'the company' rather than individuals or a team.

MMMM don't know of many places who would entrust the interpretation of HACCP to 1 person.

4.9: Pushing it a bit but the standard does not define an internal audit, something less formal than usual may be acceptable to certain auditors.

I agree, but these people didn't even do an INFORMAL internal audit. How would you audit or prove that you've carried out these audits??

7.3.4: Dependant on the flow of people around the building an auditor may take a broad view on what constitutes the entrance to a production area.

So why bother having a hand wash station on one entrance, but not on the others if all entrances led to the same place (2 of these entrances were from the canteen / toilets area)?

7.7.4: This is really pushing it but the standard does not prescribe what controlled laundry means, the fact that 7.73 refers to self care for Cat A suggests that home laundering is not acceptable for Cat B but does not say what is.

As i said, Category B.....no home laundering!

7.8.2 : There is no mention of a specific period of time for refresher training , leaving the definition of 'appropriate' to the discretion of the auditor.

True, but majority of staff had NO training and no one had been trained in 4 years!

Now there is no doubt that the majority of the points you raised during your audit are copper bottom Non Conformances but the points I have picked out above
may be ripe for discussion with a suitably amenable auditor after a hearty lunch.

i can be bought, but would take more than lunch!!

You and dozens of other customers !! The standard promotes the use of 'appropriate' controls and what is appropriate for a chilled food facility is never going to be appropriate for a can factory or a papermill, all that hosing down would play havoc with the cardboard for a start

I agree, and it was a dry area, but there still should be cleaning schedules, even if its "Brush the floor at end of day"

If your customer needs help clearing up 7.8.2 you know I can help.

Thanks for the heads up Caz.

Regards,
Simon

Sorry Simon, was thinking of tendering for the work myself!!

[Charles.C]

Dear Simon,

Although not so long as yet, I think this thread surely warrants a few stars, some really useful practical comments on BRC in my opinion (not including my own).


Rgds Charles.C

[Simon]

Sorry Simon, was thinking of tendering for the work myself!!

Of course, but you'll still be needing some booklets won't you?

Although not so long as yet, I think this thread surely warrants a few stars, some really useful practical comments on BRC in my opinion (not including my own).

You are too modest Charles; I've added five stars, but you don't have to ask, you are free to sprinkle stars on any thread you choose. The 'Rating' button is underneath the 'New Topic' button up there (can't find an up arrow).

Back on topic, are we saying Caz may have been a little over zealous with the NCR forms?

Regards,
Simon

[MartLgn]

Back on topic, are we saying Caz may have been a little over zealous with the NCR forms?

Is there room for a littl'n behind that sofa Simon? Because I would say that Caz may have been a little harsh with the NC's

[Gaskit]

Is there room for a littl'n behind that sofa Simon? Because I would say that Caz may have been a little harsh with the NC's

I would probably have been a quite a bit more distructive

Did you check the location of pest bait boxes against the plan and were they effectively numbered, spec for baits etc etc.

Ha ha, but that is just me
Best regards,

Steve

[MartLgn]

Im still feeling unusually charitable so here goes again with the case for the defence ....

Thats quite a list !! I must admit that in the past we have achieved Cat B certification with a couple of the omissions listed down to the interpretation of the auditor, based on this experience and with my devils advocate horns on I would say the following clauses at which your auditee was lacking would be open to interpretation...... This company too have category B, and as im in receipt of the standard, i know what they should be aiming for

There's no doubting that the BRC/IOP auditor in question missed some huge NC's at this supplier, perhaps a change of career for you Caz ?

Section 3: The standard does not prescribe formal HACCP training for anybody and mentions only 'the company' rather than individuals or a team. MMMM don't know of many places who would entrust the interpretation of HACCP to 1 person.

It is a bit unusual to have a one man HACCP team but not expressly forbidden in the standard, indeed section 3 makes no mention of HACCP but requires a Hazard Analysis conducted to accepted principles, I think the commitee that wrote the standard were mindful of the issues involved for packaging suppliers in applying HACCP to certain packaging processes.

4.9: Pushing it a bit but the standard does not define an internal audit, something less formal than usual may be acceptable to certain auditors. I agree, but these people didn't even do an INFORMAL internal audit. How would you audit or prove that you've carried out these audits??

Some auditors will accept the review of customer visit reports as a form of internal audit... no honestly they will.

7.3.4: Dependant on the flow of people around the building an auditor may take a broad view on what constitutes the entrance to a production area. So why bother having a hand wash station on one entrance, but not on the others if all entrances led to the same place (2 of these entrances were from the canteen / toilets area)?

This depends on the route the auditor was shown during their visit, if he or she was shown only the desired entrance to production areas then they may not be aware of the alternatives.

7.7.4: This is really pushing it but the standard does not prescribe what controlled laundry means, the fact that 7.73 refers to self care for Cat A suggests that home laundering is not acceptable for Cat B but does not say what is. As i said, Category B.....no home laundering!

no real excuses here, its probably a case of don't ask don't tell.


Caz
I still think that your expectations of what certification to the standard brings about are maybe coloured by your experience of BRC food standard. There is no doubt that the auditor who gave a favourable evaluation of your supplier missed some NC's that would be visible on Google Earth, this is not to say that they conduct all their audits in such a manner but I am sure many auditees out there have had audits when they cannot believe they have got away with something.

As Simon has already said it would be terrible to those in the Packaging industry who work so hard to implement the BRC/IOP standard in good faith if a few auditors or even a certification body were to devalue their hard work by giving away undeserved certifications.

[cazyncymru]

I would probably have been a quite a bit more distructive

Did you check the location of pest bait boxes against the plan and were they effectively numbered, spec for baits etc etc.

Ha ha, but that is just me
Best regards,

Steve

Steve i did...i even checked to see if the bait boxes were signed inside

Are you saying i wasn't picky enough??? and Martin says im too picky!!!

I might have to ask one of you lovely men to go throught the BRC/IOP standard personally with me, all pointers gratefully received as i don't normally get to audit suppliers.


Mart...i'm sure that this company was not the norm... maybe they've become complacent over the years as they've had the same auditor time after time, who probably think its a nice cushy day for him!

[MartLgn]

after a couple of audits once the frequency becomes annual it can be a case of ticking the boxes, thanks for lunch and see you in 12 months. I am not sure that it is necessarily the fault of individual auditors,after all an experienced auditor visting the same plant for the 5th time should be able to tell failry quickly if things are in order , perhaps the fault lies in the scope and structure of the standard.

Caz.

Im ahead of you there ! It would seem based on your findings with your supplier that familiarity far from breeding contempt leads to a very easy time for some auditees. Perhaps the audit protocol should be re-written to require a different auditor after 2 years ? There may be a need for more auditors so Caz if you want any grounding in Packaging Technology as well as the standard Im sure we can help

[Simon]

I split this topic from here:
http://www.saferpak....?showtopic=5378

At the point where it went I think #2.

Feel free to carry on guys...

Regards,
Simon

[MartLgn]

I split this topic from here:
http://www.saferpak....?showtopic=5378

At the point where it went I think #2.

Feel free to carry on guys...

Regards,
Simon

Apologies for straying Simon, you should try and have a face to face conversation with me, Im even worse Hope this doesn't detract from what is after all a very concerning point that Caz has raised.

[Charles.C]

Dear All,

Was attracted back by the off-topic notes, my forte also, not that the thread has become less interesting, far from it!

Does the BRC Packaging also have the requirement that BRC Food took from ISO concerning the need for 'continuous improvement'. This seems to be employed as the lever in my experience to prevent repeat passes of similar situations, sometimes over- zealously in my (auditee's) opinion.

Also the earlier question regarding ‘Is Caz being too demanding', seems to me the current score is 2-2 (auditors v ?), soon have enough for a poll or is that the kiss-of death for the thread ?? (Hmm, vampires + auditors, sounds promising )


Rgds / Charles.C

[MartLgn]

Does the BRC Packaging also have the requirement that BRC Food took from ISO concerning the need for 'continuous improvement'. This seems to be employed as the lever in my experience to prevent repeat passes of similar situations, sometimes over- zealously in my (auditee's) opinion.

Charles.

There is certainly no equivalent of section 8.5 of ISO 9001:2000 which explicitly requires continuous improvement measures.

The introduction of the BRC/IOP standard mentions that one of the aims is to 'continuously review and improve standards and supporting processes' .
However unless I have missed it there is no further mention of improvement in any of the auditable clauses, section 4.9 which covers internal audits and management review mentions only corrective action as does 4.10 covering complaints procedure.

On the face of it Charles IMO at least, an auditor can only ensure that the expressed requirements of the standards are met on the day of the audit and so long as this is the case the systems can be the same year after year until the standard is changed.

[Simon]

Due to popular demand I've added a poll.

[Gaskit]

Dear Caz,

No mate, i think you were spot on with your audit findings.

Although I agree that some auditors do get a little complacent when auditing the same place year in / year out, did you let the company know in good time that you were going to audit? If so and they couldn't be bothered (as it looks) de-list and go to someone who can be bothered giving you the service.

Regards,

Steve

[cazyncymru]

Dear All,

Also the earlier question regarding ‘Is Caz being too demanding', seems to me the current score is 2-2 (auditors v ?), soon have enough for a poll or is that the kiss-of death for the thread ?? (Hmm, vampires + auditors, sounds promising )
Rgds / Charles.C

No tongues ok Charles!!!!