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[okido]

According paragraph 3.1.1. of the BRC IoP standard a hazard analysis should be performed considering chemical, biological, foreign contamination, product integrity and legality and product defects.
As we come from a HACCP system were we started with many years ago we moved product integrity and product defects into our quality system.
We considered this as useful to create more awareness of food safety on a day to day basis when people work with quality standards.
During our certification audit a point was made that we not identified potential hazards with respect to product integrity. We only explained the broad potential hazards in our process descriptions. The details can be found in our quality standards, but are not identified as being a food safety related subjects.
After a lengthy discussion the Auditor accepted this.
I expect that we will have another discussion with the Auditor sooner or later on this subject.
So I would like to how other people are managing product integrity and legality?

No worries, Okido

[Simon]

Okido, I wonder do you print on the packaging you manufacture. Maybe food ingredients? If these were incorrect, missing or illegible then maybe it could be a food safety concern. Again if the packaging is printed can mixing of product occur in your process? Does your packaging provide a protective barrier to food, if so should it be undamaged, intact and hole free. Are these food safety issues? In packaging the line between food safety and quality are often blurred. The important point is you have carefully considered all of the issues that could affect food safety and where appropriate you have effective control measures in place. Is there a better place to carry out this risk assessment than the HACCP plan?



Simon