Dear D-D,
Well, from other reported experiences, it appears that some people have found it auditorily un-necessary to even maintain a documented risk analysis. (Note that such a requirement does not routinely appear in all individual cases in the standard). Furthermore, from the list posted by Tony, approx 27 items are risk – analysis related (!), a substantial amount of work. For such reasons, it seems practical to perhaps include a lower, generic paragraph headed, for example, “verification” to each documented risk analysis stating something like – the above implemented actions / procedures / risk bases will be re-examined for correctness in case of any related instances of loss of control, changed conditions or, at a minimum, on a yearly basis. This is analogous to methodology used for the HACCP program. This allows use of a condensed “verification” document listing risk analyses vs audit check date.
Might be easier to do an Excel based version allowing several BRC clauses to be put together, or perhaps using individual sheets. Question of Word / Excel expertise ?.
Interested to hear other people's approaches / experiences
Rgds / Charles.C
added -
After little more musing, a few additional thoughts –
the reverse thought process I mentioned can perhaps be summarised –
1. controlling what primary type of hazard ? > safety / legality / quality? > specific?, eg BPC, weight, OLQ > Hazard Column.
2. hazard most likely caused by what activity ? > data / conceptual > Activity column (this approach is clearly pre-selective but so-what? It's undeniably a risk assesssment ).
Referring Tony's BRC "want" list, I guess the majority of items are "top level" safety wise and their risk-related aspects / explicitly-implicitly associated inspection frequencies will probably hv already been considered within existing programs.
Some are seemingly less incident-prone, eg jewelry, wood. De-emphasise ?
The comments regarding verification will clearly require some x-referencing to related procedures which probably already exist.
Other RA routes are obviously possible, eg specifically delineating the risk-assessment aspect within the actual appearance of the item in one's manuals and then compiling a master document with x-references. I encountered a similar quandary with "Validation" for HACCP but ultimately chose to append a specific chapter to the HACCP program. Question of preferences again.
NB - OLQ = organoleptic quality