BRC - 5 (Clause 2.2.2)

Hi everyone.

Our library of resources for our HACCP was criticised at a recent BRC-5 pre-assessment by the auditor under "Insufficient references." Clearly, each category of product and process will differ (ours is alcohols for food use), but I wondered if anyone maintains a 'core' list of essential HACCP-related references that have passed BRC-5 scrutiny and that they could kindly share?

Thank you.

ISO17025

Dear iso 17205,

Apologise that less familiar with ver5. Hv never seen this specific query here before Frankly, IMO, the new codicil 2.2.2 in v5 can mean almost anything, typical BRC !

Generally, IMEX, any refs involved relate primarily to (a) the chosen general implementation strategy for HACCP and (b) the validation of specific parts of the actual HACCP analysis. Also ©, BRC seem to hv newly included regulatory HACCP aspects (just to be helpful ) which I suppose may strongly depend on yr marketing scenario.
As per yr original comment, presume you are mainly referring to (a) which in BRC typically tends to be answered by Codex / fao links or alternative US ones (eg NACMCF) (or perhaps other geographical equivalents) depending on yr chosen methodology. I expect you are well aware of these already ??.

Perhaps you could be a little more specific in yr request or post the information you possess already to avoid un-necessary duplication ?

Rgds / Charles.C

Dear iso 17205,

Apologise that less familiar with ver5. Hv never seen this specific query here before Frankly, IMO, the new codicil 2.2.2 in v5 can mean almost anything, typical BRC !

Generally, IMEX, any refs involved relate primarily to (a) the chosen general implementation strategy for HACCP and (b) the validation of specific parts of the actual HACCP analysis. Also ©, BRC seem to hv newly included regulatory HACCP aspects (just to be helpful ) which I suppose may strongly depend on yr marketing scenario.
As per yr original comment, presume you are mainly referring to (a) which in BRC typically tends to be answered by Codex / fao links or alternative US ones (eg NACMCF) (or perhaps other geographical equivalents) depending on yr chosen methodology. I expect you are well aware of these already ??.

Perhaps you could be a little more specific in yr request or post the information you possess already to avoid un-necessary duplication ?

Rgds / Charles.C

Hi Charles,

Thanks again. As you say, typically BRC! Since we deal with wines, mention was made of new items that had cropped up involving reportedly heavy metal contents of eastern European wines - themselves not relevant to us, but indicative (our auditor suggested) that we were monitoring and using all data that affected our sector. OK, we can do that, but the dossier could be pretty large with so open a brief (and who's to say that our non-specialist auditor necessarily has the competence (to use an oft-cited BRC term ) to judge whether we have achieved the requirements of the standard?). That's why we kept it brief and simple, and included only the following in our HACCP cover (if you spot anything essential I've left out, I'll gratefully amend):

• Regulation (EC) No 178/2002 of The European Parliament of the Council of 28 January 2002 (laying down
  the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety).
• Regulation (EC) No 852/2004 (Article 5 of the regulation on the hygiene of foodstuffs requires food business operators to put in place, implement and maintain a permanent procedure based on Hazard Analysis and Critical Control Point (HACCP) principles).
• The Food Safety Act 1990 (and its amendments)
• The Food Hygiene (England) Regulations 2006.

• The Recommended International Code of Practice General Principles of Food Hygiene (CAC/RCP 1-1969 (Rev. 4 – 2003)). (CODEX).
• The BRC Global Standard for Food Safety (Revision 5).

And all other relevant legislation, sources and guidelines


Many thanks,

B/regards,

ISO.

Dear ISO17025,

Thks yr info.

As far as the one particular criticism you refer, this is typically catered for IMEX by a procedure to do a scheduled routine abstracts search or hv some other kind of, maybe external, authoritative input source. Never met yr precise complaint as long as the topic was included / summarised in some kind of an annual review within the "verification" step. Assuming "no significant change", no great depth of study entailed IMEX. (Contrariwise, obviously any major occurrence would need immediate documenting / action also.). However I can understand that an auditor might find no direct link (within a general haccp compiled list) to recognised wine data info. sources as being noteworthy (also see below).

Some general comments to yr links are -

1. Assuming you use decision tree method (I don’t), I guess the Codex reference should suffice. If you don’t use the d-tree method, need other risk assessment links for sure (pls clarify).
2. I presume the various general EU links you give adequately match the specific haccp / regulatory activities of yr product / market situation (eg retail/non-retail, export/non-export etc). I didn’t notice any obviously direct wine-related links but perhaps inside the general text ?. Pls clarify. In my case (seafood) further individual links would probably be required but this is up to your knowledge. This is possibly one part of the auditor's comment.

3. I didn’t see any specific links for validating CCPs ( usually a fundamental HACCP step, despite blurred over in codex 2003), or perhaps there are no CCPs for wine although that wud still require some validation ? For many people this is often the most complicated and lengthy part of the HACCP plan and by association the links list also. A visible lack would normally draw an auditor’s comment IMO. Maybe second part of auditor's comment.

And all other relevant legislation, sources and guidelines

4. Wasn’t quite sure what the above meant ? HACCP utilised information but not referenced in the HACCP manual, ie “anything”.? Maybe a third part of auditor's comment

Hope the above makes sense, particularly the general / specific comments. Actually (without it being my direct product knowledge base), yr links for general factors looked quite reasonable IMO but I'm less sure about the specifics. Any wine people here might also hv direct input but any comment probably needs more info., eg haccp details regarding CCPs etc. (eg metal detector validation etc, etc). I've not touched on any pre-requisite aspects since you seemed to hv had no problem in that area.

Rgds / Charles.C

Hi everyone.

Our library of resources for our HACCP was criticised at a recent BRC-5 pre-assessment by the auditor under "Insufficient references." Clearly, each category of product and process will differ (ours is alcohols for food use), but I wondered if anyone maintains a 'core' list of essential HACCP-related references that have passed BRC-5 scrutiny and that they could kindly share?

Thank you.

ISO17025

Hi ISO

in my HACCP, the "literature" i refer to is actually legislation /COP

Food Safety Act
Codex Alimentarius
Labelling Regs
Micro Regs
Animal By Products
Weights & Measures
Supermarket COP
HTST COP
Etc ETc

I have been asked to produce there pieces of legislation, so make sure you have a copy!