5 replies to this topic

[MOOCHIE]

Hi I'm new to this forum but i must say i'm finding it very useful.
We had are BRC audit last week and i'm just trying to sort out the non conformances
My first question is how can you get marked down for putting a QCP as a CCP, over velus auditor or what!!

My main question is 'Records of the review of the HACCP study by the HACCP team are not available' properly sound thick here but how can i show evidence of this. I work in a very small factory usually its just me

Grateful for any help
BRC virgin
moochie

[GMO]

Hmm, a bit of overzealousness perhaps but identifying unnecessary CCPs can overcomplicate a HACCP plan and IMO lead to confusion and poor implementation on the shop floor. Also I suspect if they identified one point there were probably more which were debatable? Could be wrong...

Anyhoo. HACCP teams for one should be just that. If you have other people working with you, at least get one person involved in HACCP with you. This is really one of those things where two brains are genuinely better than one.

Thirdly, you need to review a HACCP plan at least annually and be able to prove it (or else why bother?) As you were unable to prove it to the auditor, don't go making up some records for the non conformance(!) All you can do I would suggest is hold a review meeting asap (ideally in the next week as you have a month I think to respond to the non cons) then write up the minutes and actions, forward that with a meeting plan over the next year with a meeting planned in for the next review and there you have not only the missing review but also the next one planned in. Think they'd accept that.

[Simon]

You need an agenda, data, records of review meeting and actions...and as GMO said you can't have a HACCP review meeting by yourself.

If you do something record it otherwise it has not been done...in the eyes of an auditor or in the worst case THE JUDGE!

[redchariot]

Thirdly, you need to review a HACCP plan at least annually and be able to prove it (or else why bother?) As you were unable to prove it to the auditor, don't go making up some records for the non conformance(!) All you can do I would suggest is hold a review meeting asap (ideally in the next week as you have a month I think to respond to the non cons) then write up the minutes and actions, forward that with a meeting plan over the next year with a meeting planned in for the next review and there you have not only the missing review but also the next one planned in. Think they'd accept that.

I would agree; if you don't have something in place for an audit, you will find it very difficult to "backdate" records when submitting info for closure of non-conformances. The better thing to do is show how you plan to prevent a recurrence and I think the above will be more than adequate in this instance.

Edited by redchariot, 09 December 2010 - 07:35 PM.

[Charles.C]

Dear moochie,

Hope you are still around.?

I suppose it depends on the meaning of "small factory" but assuming you represented the total submitted HACCP team, I think you escaped fairly lightly from the auditor's wrath. I guess you must have had an acceptably documented HACCP training record anyway.

Maybe you could consider renting an internet advisory group to be yr team. No problem to find I'm sure.

There are various statements in textbooks that one objective of the HACCP program is to minimise the total number of CCPs. This reflects back to the early HACCP days where almost every possible hazard generated a CCP > confusion. The use of prerequisites helped to markedly cut things down. A case of most is not always best. of course, the auditor might hv been wrong also.

Rgds / Charles.C

[Foodworker]

It would be interesting to see how the auditor worded the Non Conformance and to exactly which control it related. In most cases to get a NC for calling a QCP a CCP would be unreasonable and difficult to justify. Very often the precise decision about whether something is a CCP or any other form of control point is subjective and although the auditor may have his own opinion, you will have had much longer to do your own analyses. Every operation is different and what may be a CCP in one may not in another.

That said, it is not unknown for an auditor to raise a minor non-conformance in a way intended to help you. For instance if your plan was basically OK but there were some areas where you could improve by looking at it in a different way.

Provided the extra NC didn't affect your grade, I wouldn't worry too much about it and view it as a positive and review it again. Of course if you are still convinced after your review that you were right and the auditor was wrong you can state this with all of your justifications when you return your corrective actions. You always have the right of appeal.