Jump to content

  • Quick Navigation
Photo

Brc Vers 4 Audit

Share this

  • You cannot start a new topic
  • Please log in to reply
9 replies to this topic
- - - - -

ISO17025

    Grade - Active

  • IFSQN Active
  • 8 posts
  • 0 thanks
0
Neutral

  • United Kingdom
    United Kingdom

Posted 29 April 2008 - 09:36 PM

Hi.

We've recently undergone our BRC audit. We got a Grade A, with four minor n/c. We're a bit stumped, however, as to why we picked up a 2.9.1 (Does not meet the scope of the standard) in respect of laboratory operations. We have a non-accredited site laboratory for the testing of basic chemical parameters (no micro) in respect of wines and vinegars, which are sold as food ingredients (not retail). We contract out validation cross-checks with UKAS-accredited labs twice yearly (this has been with a single accredited lab, admittedly).
Our audits in respect of lab testing have all been satisfactory over the past 3 years - with the same auditor (but a different company TM). This year we're suddenly not in compliance. We comply with the requirements under 5.5.2.4 in the BRC Vers 5. standard (I'm not sure what the ref. is for Vers 4, which we seem to be missing. I should add, of course, that we were audited against 4)), but have been picked up a n/c against 5.5.2.3 (compliance with ISO17025, in relation to analyses that are critical to product safety or legality). It's the latter that I believe is the problem. We test free Sulphur Dioxide by a simple titration with a pre-mixed iodine-based solution supplied by an accredited lab. The total (combined SO2) of a wine is legally controlled by EU limits, whilst the free SO2 (which we test for) is simply the uncombined sulphur that has not been bound up with oxygen. The free SO2 is usually a third or half of the total SO2, which itself is usually around half the legal max in the wines we handle. We monitor the free SO2, but do not adjust it. We are therefore in no danger of exceeding the prescribed free SO2 limits for the products we supply, and our test results demonstrate this.
We are not a high risk operation, and the testing requirements (alcohol,acidity,pH) that describe our products are basic, and so far below the necessity for ISO17025 or UKAS accreditation that this course of action will be overkill.
I'm therefore interested to know whether anyone has faced a similar situation, and might be able to recommend a strategy for responding to this n/c? Many thanks.


Edited by ISO17025, 29 April 2008 - 09:44 PM.


Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 20,542 posts
  • 5662 thanks
1,544
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 30 April 2008 - 05:00 AM

Dear ISO17025,

Welcome to the forum :welcome:

Not a wine expert (bar fondness for Chianti [is that a wine?]) but can start the ball rolling.
Would hv expected the reason for the NC to hv been explained during the audit ?

I don't hv ver5 but Ver4 also refers to the “undertaking of analyses critical to product safety / legality”. “Critical” is a nice, flexible terminology.

SO2 is both a health related / legally controlled parameter. Correct ?
Is it a CCP in yr HACCP plan ?
If any YES’s to the above, I can see where the NC might hv originated.

It is my understanding (via micro. analysis etc), that you are not obliged to hv 17025 certification but must be able to demonstrate an equivalent level of laboratory competence, eg having a course attended/qualified operative, documentation, calibration controls etc. “Overkill” is a common reaction, it all depends on the exact situation of course however I agree that the ISO standard is not exactly “lightweight”.

Any wine producers here ?

Rgds / Charles.C


Kind Regards,

 

Charles.C


ISO17025

    Grade - Active

  • IFSQN Active
  • 8 posts
  • 0 thanks
0
Neutral

  • United Kingdom
    United Kingdom

Posted 01 May 2008 - 11:11 PM

Thanks Charles.

On reflection, I think it revolved around the verification of our results, in particular the SO2, one of the mandatory allergens.
Mention was also made however about the audit process for our non-accredited lab, in particular about whether we could tick all the boxes to ensure compliance with the principles of ISO17025 (as it happened, we believed we could). We're addressing the n/c by incorporating an internal audit plan against our verification methods (independent UKAS-accredited labs in a limited (affordable) ring) for the legal and safety parameters (SO2 and pH) of our products. Hopefully this will satisfy and clear the n/c. The frustrating feature of this audit, though, is that the same auditor approved this area last year with an acknowledgement that the lab methods and existing verification scheme was in compliance with ISO17025. There have patently been no changes to our procedures in a year, and now we have a n/c! Ho-hum, that's the way it is, I guess.

Thanks again for your comments. By the way, yes, Chianti is an Italian red wine, best servied with a red meat dish or mature cheese (or raw liver, if you happen to share Hannibal Lecter's penchant).


Edited by ISO17025, 01 May 2008 - 11:14 PM.


Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 20,542 posts
  • 5662 thanks
1,544
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 02 May 2008 - 01:25 AM

Dear ISO17025,

We're addressing the n/c by incorporating an internal audit plan against our verification methods (independent UKAS-accredited labs in a limited (affordable) ring) for the legal and safety parameters


Terminology speaking, this looks more like a validation procedure as referred in yr original post and which seemed already very adequately accounted for from my own experience.?

It is possible that the auditor simply realised he had been previously in error (perhaps a customary product sampling was discontinued in latest audit :smile: ) and/or this was his enforcement of the “continuous improvement” section (auditor's results are validated too of course). I always harassed auditors over what “kind” of corrective action might be appropriate for every NC, after all you are presumably paying for their evaluation. After an overall result like yours, I would have thought the auditor should be only too happy to make hints for maintaining the symbiotic relationship.

Thks yr Chianti information (a discovery from factory luncheons in Italy :thumbup: ).

Rgds / Charles.C

Kind Regards,

 

Charles.C


Simon

    IFSQN...it's My Life

  • IFSQN Admin
  • 12,826 posts
  • 1363 thanks
880
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Location:Manchester
  • Interests:Married to Michelle, Father of three boys (Oliver, Jacob and Louis). I enjoy cycling, walking and travelling, watching sport, especially football and Manchester United. Oh and I love food and beer and wine.

Posted 06 May 2008 - 10:25 AM

If have never been a third party auditor and have no special reason to support them however I can see some obvious reasons for their apparent inconsitencies. Just a few:

- The huge amount of work there is to get through during a BRC audit
- Increased weighting caused by the latest ‘hot topic’, food recalls, media reports (scares), retailers edits, sharing audit stories with peer auditors. Could be concious or subconcious.
- The information audit trail just happened to lead to the finding / thinking / digging deeper
- The auditors own learning curve
- We all change over time
- How the auditor feels that day
- Inadequate refreshments
- They like to find some nonconformities (usually four or five). Perfection is a personal insult to their professional capability
- Traffic congestion
- Lack of sex :helpplease:

I could go on, but my want for silliness tends to cast a cloud over the one or two good points I make.

Anyway it sounds like you have a robust system in place. I can say this without first hand experience because it’s quite obvious you care about the 1 NC – you have the vital ingredient – Commitment!

:welcome:

Regards,
Simon


Get FREE bitesize education with IFSQN webinar recordings.
 
Download this handy excel for desktop access to over 180 Food Safety Friday's webinar recordings.
https://www.ifsqn.com/fsf/Free%20Food%20Safety%20Videos.xlsx

 
Check out IFSQN’s extensive library of FREE food safety videos
https://www.ifsqn.com/food_safety_videos.html


cazyncymru

    Grade - FIFSQN

  • Banned
  • 1,604 posts
  • 341 thanks
130
Excellent

  • Earth
    Earth
  • Gender:Male

Posted 09 May 2008 - 08:05 PM

Simon

you should forget reading BRC Issue 5, and just read a few of the supermarkets COP!

Makes BRC 5 look like a Mills & Boon Novel!



Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 20,542 posts
  • 5662 thanks
1,544
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 10 May 2008 - 05:51 AM

Dear Cazx,

Makes BRC 5 look like a Mills & Boon Novel!


Very illustrative comparison :thumbup: -

Of course, Mills and Boon come in various flavours -

Core product in the Mills & Boon brand portfolio are the eleven series which are published every month. These are (from [1]):

Modern : Focus on being glamorous and 'sophisticated' passionate romance. Titles feature intense relationships, often very sexual, often reflecting shared feelings, desires and dreams within the couple.

Romance: Warm and emotional novels that focus on capturing the feeling of falling in love.

Blaze: Very sexual. Featuring couples in contemporary romantic relationships as they embark on sexual adventures and fantasy journeys.

By Request: Revived romantic novels published previously but now unavailable. One volume is available per month.

Medical: Contemporary romances set against the background of the medical profession.

Historical: Romance set in a specific historical time and place, for example 1920s New York.

Desire 2-in-1: Daring provocative and sensual love stories.

Special Edition: Compelling romances packed with emotion, tackling sensitive issues while embracing the romantic ideal that love can conquer all.

Superromance: Realistic, passionate, contemporary novels that are longer and more involved.

Intrigue: Romance suspense at its best: Danger, deception and desire.

Spotlight: Two bestselling novels in one volume by favourite authors, back by popular demand! Featuring novels from Silhouette series favourites, Special Edition, Sensation and Desire.

( http://en.wikipedia....ki/Mills_&_Boon

I'm guessing "Intrigue" is the nearest match ? I suppose 3/3 rather depends on the auditor ?

Rgds / Charles.C

Kind Regards,

 

Charles.C


Simon

    IFSQN...it's My Life

  • IFSQN Admin
  • 12,826 posts
  • 1363 thanks
880
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Location:Manchester
  • Interests:Married to Michelle, Father of three boys (Oliver, Jacob and Louis). I enjoy cycling, walking and travelling, watching sport, especially football and Manchester United. Oh and I love food and beer and wine.

Posted 12 May 2008 - 07:54 AM

Simon

you should forget reading BRC Issue 5, and just read a few of the supermarkets COP!

Makes BRC 5 look like a Mills & Boon Novel!

Why have they got COP's if they are signed up to the BRC?

Get FREE bitesize education with IFSQN webinar recordings.
 
Download this handy excel for desktop access to over 180 Food Safety Friday's webinar recordings.
https://www.ifsqn.com/fsf/Free%20Food%20Safety%20Videos.xlsx

 
Check out IFSQN’s extensive library of FREE food safety videos
https://www.ifsqn.com/food_safety_videos.html


cazyncymru

    Grade - FIFSQN

  • Banned
  • 1,604 posts
  • 341 thanks
130
Excellent

  • Earth
    Earth
  • Gender:Male

Posted 12 May 2008 - 03:52 PM

Why indeed Simon.......a question i've asked myself on more than one occassion in the last few months!



GMO

    Grade - FIFSQN

  • IFSQN Fellow
  • 2,792 posts
  • 721 thanks
225
Excellent

  • United Kingdom
    United Kingdom

Posted 15 May 2008 - 06:47 AM

Oh it's just because they like to think they lead the way. The odd thing is a lot of the members of the BRC are the supermarkets that are putting in their own COPs!

Having your own COP though does allow them to indulge in their paranoia (bless 'Whistleblower'. I wonder if they know how much that programme shook up the supermarkets?)





Share this

0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users