12 replies to this topic

[moshes]

In BRC/IOP 7.42 (B) is is written:
"Employers provide facilities for adequate storage of food and drink, including that brought from home. Drinking of water from purpose-made dispensers and/or by using
only disposable conical cups may be allowed provided it is confined to a designated area away from equipment". How this should be interpretated ?
Does it mean using only conical cups with conical bottoms (to prevent usage of self standing cups near the equipment ?)
We in Israel do not have production of conical cups with conical bottoms.
The way drinking water issue near equipment was trated before version 2 of BRC/IOP, was using personal one way closed bottles with either mineral or tap water.
What should be now used instead if this conflicts with the new requirments ?
Comments please.

[Charles Chew]

only disposable conical cups

Hi Moshes,
I find this issue rather silly and as a matter of fact becos it is so clearly stated that only disposable conical cups can be used, flat bottom ones would be a direct violation................

This is when the standard can be so dangerous when compliant requirements are so clear and explicit that it brings along so other unknown or unexpected problems.............w/o discretional options extended.

IMO - If you are to follow the standard, you need to use conical bottom disposable cups (but I am not an expert in BRC-IOP) although I cannot resist giving my comments

Cheers
Charles Chew

[Simon]

Hi Moshes,

I agree with Charles. It's a requirement and there's no way round it.

Regards,
Simon

[pacepavicius]

The Standard also says "purpose made dispensers". I believe the whole issue here is about control and assessment of the risks of spillage onto the product. Some water dispensers are designed so that cups of any description are not required.

My point is that while the Standard is quite prescriptive, there is some room for interpretation especially if the evaluator can be satisfied that there is no risk.

Peter

[Simon]

Good point Peter.

[Bonno]

My point is that while the Standard is quite prescriptive, there is some room for interpretation especially if the evaluator can be satisfied that there is no risk.

I think that you have raised the point exactly. The opinion of the evaluator, together with their interpretation of the Standard is what will be the final answer.

Unfortunately the BRC standard is unlike any of the other standards that we work with at our site in that variation in interpretation is avoided at all costs. It has been written with all differing circumstances in mind - but this can never really be possible and in some cases compliance does not appear to make any sense at all.
While you are required to assess your risks and initiate controls were necessary/possible - should these assessments not identify a hazard, but the Standard requires controls, the Standard wins out and the controls will have to be implemented?

I have voiced my concerns regarding controls demanded where no risk is present, but in the end the Standard is recited and controls enacted.

[Simon]

I have voiced my concerns regarding controls demanded where no risk is present, but in the end the Standard is recited and controls enacted.

Hi Bonno,

Remember the Standard does afford you the opportunity of applying for an exemption (or is it exclusion?) from a requirement of the Standard. This should be justified by documented hazard analysis and submitted to your Auditor; you can then have a debate as to whether there is or isn't a risk. Ultimately the auditor will decide whether to accept or reject the exclsuion.

Regards,
Simon

[kerguilloten]

I find this issue rather silly and as a matter of fact becos it is so clearly stated that only disposable conical cups can be used, flat bottom ones would be a direct violation..

I agree with you Chew, I've heard this story from a plastic cups producer who had to choose between stopping production of non conical cups or being BRC/IoP certified...
Moreover, why conical and not spherical bottom, easier to thermoform ? Most of the conical cups (available at a reasonable price) are made of paper, another biolo-illogical choice.
When it's written "No cups close to production areas" and you give evidence that it's done, I consider that my HACCP is correctly monitored.
Let's have a toast with a cristal glass a champagne to congratulate Simon for this warm place for smile and reason

[Charles Chew]

No cups close to production areas" and you give evidence that it's done, I consider that my HACCP is correctly monitored.

Kerg - I cannot agree more with that statement. You have taken the appropriate "preventative action" to nullify the BRC Standard. Congratulations and that would be the perfect answer to any auditor's query.

It has been written with all differing circumstances in mind - but this can never really be possible and in some cases compliance does not appear to make any sense at all.

Bonno - If you look at the ISO 22000 prescriptions, the demand for compliance on some "redundant issues" is
no different from that required by BRC. So I would rather have the form there to fulfill the auditor's unpreditable mindset and through annual reviews, highlight the rediculous policy and to rub salt onto wounds, let it sink in for a couple of years (you decide when), revalidate the program and take it off as inappropriate in the light of the org's process environment where the HACCP Plan remains effective and current. End of the subject!

I have voiced my concerns regarding controls demanded where no risk is present, but in the end the Standard is recited and controls enacted.

Bonno - "Uncertainty is the root cause of discretional power" - I have resigned to this fact

Charles Chew

[Simon]

Let's have a toast with a cristal glass a champagne to congratulate Simon for this warm place for smile and reason

Cheers.
BTW Moshes, what are you going to do?

[Brian Fowler]

Cheers. BTW Moshes, what are you going to do?

Once upon a time I was an Engineer (some fifty years since). and had to practice mechanical drawings.I believe that a truncated cone is still a cone, albeit with a flat bottom.I think Peter P is absolutely right, let the evaluator use his ability

[okido]

In a food environment I can imagine the hazard from cups standing around above fillers etc.
In the plastic food packaging business this is something different, who can come up with an example that cylindrical cups are a potential hazard if you apply the rules below.

1. cylindrical cups are used in a confined area's shielded from production by glass and walls
2. it is not allowed to eat or drink in production area's

Goodluck Moshes.

No worries, Okido

[Simon]

In a food environment I can imagine the hazard from cups standing around above fillers etc.
In the plastic food packaging business this is something different, who can come up with an example that cylindrical cups are a potential hazard if you apply the rules below.

1. cylindrical cups are used in a confined area's shielded from production by glass and walls
2. it is not allowed to eat or drink in production area's

Goodluck Moshes.

No worries, Okido

Sounds good to me Okido.