Non-Conformity Prerequisite Validation evaluation BRC 6 - Clause 2.7.3

Hi Everyone,
We had a BRC Audit in the begining of Feb, and went well. Out of all the non-conformities, I am not able to understand one of them.
It says " the records of inspections, audits and documentation reviewed to validate the program are not stated and a record is not available. Please send the record of the information reviewed by the Director of Risk Management that was used to validate that the prerequisite programs are controlling hazards."
The Auditor was show the records of all prerequisite programs - Sanitation & hygiene, Pestcontrol, Storage & transportation etc.
My question is what kind of document should I show to auditors to satisfy the above non-conformity. Please give ideas and thoughts.
Thanks

Sounds to me that they are wanting the information you reviewed to determine the pre-req programs would work...did you look at reserach, do tests to confirm, etc. That is my guess. If I have questions, I always call the auditor back and ask them to re-explain.

Thanks for the reply. As of now I was able to close the non-conformity by demonstrating that one of the HACCP meeting reviewed the pre-requiste program and found satifcatory to be controlling the the associated hazards.

Sounds to me that they are wanting the information you reviewed to determine the pre-req programs would work...did you look at reserach, do tests to confirm, etc. That is my guess. If I have questions, I always call the auditor back and ask them to re-explain.

Thanks for the reply. As of now I was able to close the non-conformity by demonstrating that one of the HACCP meeting reviewed the pre-requiste program and found satifcatory to be controlling the the associated hazards.

I think you have to be more in depth than that. I'd work through each prerequisite in turn and review validation for each. So, for example, for cleaning, I would expect that you'd conducted some trials to confirm the cleaning methods could work. I'd also expect you'd chosen suitable chemicals at suitable concentrations.

I could be wrong but that's how I've approached it.

I think this non-conformance is looking for the documented reviews conducted by you on PRP's to state or list the actual records reviewed as part of the PRP review process. In other words when you conducted the review of PRP's various records were viewed by you and used to support your conclusions. The specific records including reference, date etc should have been noted in your report and copies of these records attached to your report.

I suppose it is designed to ensure that the review was actually conducted and not just generally documented in a PRP review report.

I hope this makes sense.

George

Dear Saurabh,

Without wishing to start a semantic OT, it seems to me that the OP's original words "records...reviewed....validated" are better categorised as "verification". Additionally, IMO, the Non-Conformance in OP, is asking for a "root cause" in contrast to yr, IMO, "corrective action" (in practice, may depend on the actual audit history).

Whatever, I agree the typical choice of response(s) is in previous 2 posts.

Rgds / Charles.C

added - of course, if you had no presentable, documented support for "validation" for any of the program, the original comment was perhaps unavoidable.

Dear Saurabh,

Without wishing to start a semantic OT, it seems to me that the OP's original words "records...reviewed....validated" are better categorised as "verification". Additionally, IMO, the Non-Conformance in OP, is asking for a "root cause" in contrast to yr, IMO, "corrective action" (in practice, may depend on the actual audit history).

Whatever, I agree the typical choice of response(s) is in previous 2 posts.

Rgds / Charles.C

added - of course, if you had no presentable, documented support for "validation" for any of the program, the original comment was perhaps unavoidable.

I agree Charles. This is more about validation than verification and essentially the auditor appears to be looking for defined evidence of the PRP review in the company's review reports. From my experience this is typical for BRC audits.

I agree, having re read that, it seems to be that the auditor was asking for a review of the verification. The standard actually now asks for validation.

Just be wary though, if the auditor has misused a term, some auditing companies have different staff signing off on the corrective action than the auditor so they may want a different corrective action than the auditor did! It might be worth asking for clarification.

Thanks a lot to all of you for your valuable inputs. I will integrate all the ideas mentioned and create a procedure which would be able to correct the issue and address the root cause.