we had a BRC non conformance 4.2.1. "the company shall carry out risk assessment of raw materials to establish the likelihood of contamination by specific allergens, eg. peanut and other known allergens, or the likelihood of loss of identity-preserved status, eg. organic, and shall put in place control measures to ensure product safety and legality are maintained."
Can anyone advise on how to go about this? Or how to present it?
Dear Bibi,
Are you selling organic, allergen containing, allergen free (claim), GMO containing or products made of GMO, GMO-free or other IP products (e.g. halal)?
This requirement of the BRC (issue 4; 5.2.1 and 5.2.2 in issue 5) wants you to make a risk assessment and to set and implement procedures to maintain the organic, alergen free, gMO and other IP status.
For example: procedures to make sure GMO containing raw materials are not mixed up with GMO on containing materials. Procedures to make sure that there is no allergen-cross-contamination in your location or procedures to make sure organic raw materials end up in organic finished products.
If you are selling Organic products, you probably are certified to do so. To get that certificate you should have done a risk assessment, or sometjing like that. You can, refer to the certificate and/or show the documents, procedures, audits etc. you established to obtain the certificate.
For other IP products, you have to make sure that confusion, unintentional mixing up, cross contamination, wrong labelling, etc. is controlled by risk assessment. Identity preserved materials are also for customer requirements. If a retailer wants you to use products of a special grower, because that grower works according a
manual of that retailer, you should handle the products of that retailer as identity preserved. The retailer will be very angry with you if to be found out, that he did not get the products he espacially aske for. E.g. use of pesticides.
Adding the identification of allergens, GMO, etc., as GMO suggested, in the specifications, is something you should do as a start. That information should also be implemented in your operational systems. If one raw materrials contain allergens, and a similair raw materials does not contain allergens, you must make sure that the operators know this, know why this is imported and make sure they are using the correct raw material.
If you are only handling allergen materials and none of the other specific materials, you can include the risk assessment in your
HACCP-risk assessment, because this is also a food safety issue.
For your information: In the new BRC issue. The requirements regarding handling specific materials are expanded to 10, of which 8 specially refers to allergens.