12 replies to this topic

[EuGeNe]

I was just wondering, guys, that if BRC Food Issue 5 have used too much of the "Risk Assessment" term. I was taught that i need to do a comprehensive hazard analysis for every "Risk Assessment" term i saw.

A few examples of risk assessments required:
Clause 4.2.4
Clause 4.8.1
Clause 4.8.6.2
Clause 7.3.2

Does anybody do it the same way i did, or is there another way around which im not aware of?

Regards,
Eugene

[Simon]

Any BRC food users willing to help Eugene?

[cazyncymru]

I was just wondering, guys, that if BRC Food Issue 5 have used too much of the "Risk Assessment" term. I was taught that i need to do a comprehensive hazard analysis for every "Risk Assessment" term i saw.

A few examples of risk assessments required:
Clause 4.2.4
Clause 4.8.1
Clause 4.8.6.2
Clause 7.3.2

Does anybody do it the same way i did, or is there another way around which im not aware of?

Regards,
Eugene

Hi Eugene

Right i'll see if i can help. i havent got a documented risk assessment as such, but i have in procedures corresponding to these clauses said that a risk assessment has been carried out hence all dry goods in production will be in lidded bins for example. in my purchasing new plant produre i have said that a risk assessment is carried out prior to purchase so that if needed we can make any alterations prior to fitting.

Clause 4.2.4 relates to security. Are all of your ingredients, packaging, chemicals etc in a secure area? if so, they need to be. i haven't done a risk assessment as such, as they are all locked away with access only by staff.

Clause 4.8.1 this is really a GMP. what i think it is saying is that you store ingredients etc in an environment that the potential for contamination has been assessed. eg keeping ingredients away from chemicals; keeping sugar in lidded bins in production areas etc.

clause 4.8.6.2 again a GMP really. its ensuring that where there is a possibility from contamination that conveyors etc are covered. if you use plastic, these need to be on your glass register.

Clause 7.3.2 Jewellry policy. do the same as i do, zero tolerance except for a plain metal band. this is in the induction booklet and i have had no problems with this.

as an aside, in the induction booklet i have said that no personal electronic equipment, including mobile phones can be taken into production areas.

hope this helps

caz x

[EuGeNe]

Thanks Simon & Caz.

Caz,
From my understanding, you did not have a documented Risk Analysis for all the "risk assessment" that was mentioned in the above. That was my main worry, seeing that the "based on risk assessment" statement will give the auditor a chance to penalise me if i didnt own a documented Risk Analysis. I did however have actions to cover those clauses.


Regards,
Eugene

Edited by EuGeNe, 16 July 2008 - 02:30 AM.

[Charles.C]

Dear Eugene,

As you say, it depends somewhat on yr interpretation of “risk assessment/analysis”.
I didn’t comment becoz not seen version5 (I presume) however yr original query is IMO totally valid. Brc likes to make people nervous by inserting the word “risk” in various places. Perhaps it’s an opportunity for the auditors to find a major or 2. Frequently IMEX the requirement (but not for HACCP) is a demonstration of “something” with a quantitative element, eg evidence of monitoring of (percentage) compliances to some "reasonable" self-defined standard and stated / appropriate corrective action where taken.
I had a similar problem with the equally magical words “should” and “shall” which are, I believe, quite closely regulated by ISO but not so much in the case of brc.
Having said the above, I should add that different auditors may not respond identically, perhaps depending on their current pass rates. Am I getting too cynical ? Surely not !

Rgds / Charles.C

[EuGeNe]

Hi Charles,

Well for the mean time im doing it without a proper documented risk assessment. I've observed that the requirements do not specifically mention that the risk assessment must be documented and kept. I'll see what my auditor says about it first.

The glossary in Appendix 7 does not define the terms "Hazard Analysis" and "Risk Assesment" anyway.

Haha :) Alright you can say im lazy.

Rgds,
Eugene

[Charles.C]

Dear Eugene,

I admire your cavalier approach

As you probably know, BRC offer a dwlable, quite detailed, comparison of what (I guess) they consider are notable differences between ver 4 and 5. (already referred in another thread).

Based on a quick look, none of the items in yr post seem to occur with respect to “risk assessment” aspects. Yr auditor will perhaps accept this as a negative release .

However 2 other items (exc HACCP) are mentioned in this context, namely clauses 5.2 and 4.11.
One of these has also been highlighted by another reviewer of the update –

• Handling Requirements for Specific Materials – Materials containing Allergens and Identity Preserved Materials (clause 5.2)A comprehensive update on the Handling Requirements for Specific Materials has been undertaken in light of current industry and consumer concerns.Now comprising 2 subsections – Materials containing Allergens and Identity Preserved Materials, requirements include all allergen containing materials handled on site shall be listed. Risk assessments are required to be carried out to identify and control routes of contamination and used to develop procedures for segregation, use of dedicated equipment and staff policies for allergen containing materials and Identity Preserved Materials. Labelling claims need to be fully validated

(UL is mine)

Hopefully of some catalytic interest.

Rgds / Charles.C

added - not wishing to disturb you un-necessarily but I also saw this comment on another forum -

The latest BRC std- Version 5- has more than just a policy required.
To meet the requirements to meet Section 4.8.4 BRC version 5 you need the
following:
- A (written) risk assessment to identify the potential for glass
contamination
- control measures in place to eliminate, reduce, minimize glass
contamination
- Documented (i.e. written) procedures for handling including
cleaning and replacement for not just glass but also: brittle and hard
plastics and ceramics.
- You need a written list of all glass, brittle and hard plastics
and ceramics on site including their location, number, type and condition
and how often you are going to check them.
- Documented procedures for glass breakage including quarantining
the products and production area, cleaning the area, changing clothes of
staff involved act as per 4.8.4.3
- Records of glass inspections and glass breakages.

(possibly not audited yet of course)

added (2) - one auditor's over-appraisal of ver 5 is here -

http://www.foodsafet...food_safety.pdf.

Seems to focus on 5.2 in the context of the present discussion (excepting HACCP again, IMO)

[EuGeNe]

Hi All!

I just had my BRC audited in the past two days. It was a grueling battle of wits... :P alrite, just kidding.

I'll just like to conclude my query on this post. Bear in mind this is in relation to my auditors perspective.

Fortunately, my auditor does not request to have written/documented risk assessment based on the casually mentioned "based on risk assessment" clauses. However, any clauses with "documented procedures... shall be implemented" must have the written/documented procedures (duh).

In such a case, let me take a glass control example;
"Clause 4.8.4.3 Based on risk assessment, documented procedures detailing the action to be taken in case of breakage of glass... shall be implemented and include the following..."

In this case, risk assessment is not documented, but a procedure must be available to document all the implemented steps.



I would admit that the safest way would be to have documented risk assessment, because if the clause says "based on risk assessment", the auditor could/can/is able to ask you "wheres the risk assessment that you based your procedures on?"

Right?

:P

Rgds,
Eugene

[Charles.C]

Dear Eugene,

Interesting comments, thank you. I take it you "passed"

To avoid some labour, would it be possible for you to inform which clauses ultimately did require you to offer the auditor a risk assessment (if any )

Rgds / Charles.C

[EuGeNe]

Hi Charles,

Passed, but with a B

Unfortunately, my auditor did not go through all the clauses with me. I did no extra risk assessments, other than those from BRC Clause 2 Food Safety Plan - HACCP.

There are certain clauses which may indicate a risk assessment is necessary. For example 5.2.1.3, 5.2.2.2 in which the statement used is different - "risk assessment shall be carried out..."

Rgds,
Eugene

[Simon]

I was always under the impression that every single clause had to be audited during a BRC audit?

Well done anyhow.

Regards,
Simon

[Charles.C]

Dear Eugene,

Unfortunately, my auditor did not go through all the clauses with me. I did no extra risk assessments, other than those from BRC Clause 2 Food Safety Plan - HACCP.

This sounds like a very user-friendly auditor, must have been a good lunch. Alternatively, maybe yr process has no complications like allergens. Either way, looks like the auditor is making his own prioritisation of the standard which is normal IMEX.

As Simon suggested, my typical experience has been to be confronted with someone waving an encyclopaedical list derived from the standard, auditor pencil at the ready. IMO this is mainly a bluff, most of the "must have" factors being "intuitively" pre-selected. (I use a similar approach when approving suppliers myself ).

Rgds / Charles.C

[EuGeNe]

I guess all these boils down to... Human nature

May i officially close this topic? Good day and good conversation, everyone! Thanks!