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Potential BRC non conformance on allergens


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GMO

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Posted 07 March 2012 - 07:44 AM

On one level, I agree with our auditor. This is the situation.

A product which is not allergen containing had been opened, resealed and boxed up. This box was then put on top of a pallet containing allergens (in thermoformed, fully sealed, gas flushed containers inside an outer carton) in the chiller.

Our auditor thinks this is a non conformance. Now on one hand I agree, I would prefer for the non allergenic product to be stored on a separate pallet but I can't honestly see what the cross contamination risk is. It has to work its way through four layers of packaging! Also as we are a small manufacturer, we often get mixed pallets delivered from agents so it would be a farce if we then have to split these apart.



shayaree

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Posted 07 March 2012 - 12:32 PM

I agree with you...there is very low probability of mix-up.
If at all it has to be a non conformance, it should be a minor one, because of its very low liklihood.



D-D

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Posted 08 March 2012 - 09:12 AM

Maybe you could you rack your chiller to store them on different shelves...? You could then label the shelves for allergen locations (at ground level so nothing can drop down onto things below it - I know, unlikely in sealed boxes but...). Might give you more room for storage too but watch out for sufficient air circulation.



GMO

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Posted 08 March 2012 - 10:43 AM

Racking - nice idea but no space!

We accepted it in the end and I would have agreed if it had been open but it wasn't. Still, we did ok.



isabelle campbell

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Posted 08 March 2012 - 01:04 PM

On one level, I agree with our auditor. This is the situation.

A product which is not allergen containing had been opened, resealed and boxed up. This box was then put on top of a pallet containing allergens (in thermoformed, fully sealed, gas flushed containers inside an outer carton) in the chiller.

Our auditor thinks this is a non conformance. Now on one hand I agree, I would prefer for the non allergenic product to be stored on a separate pallet but I can't honestly see what the cross contamination risk is. It has to work its way through four layers of packaging! Also as we are a small manufacturer, we often get mixed pallets delivered from agents so it would be a farce if we then have to split these apart.



I see your point. Considering that BRC edition 6 is intent based and the intent of allergen control is risk assessment of contamination along the process line, I'd have to agree that at the point where everything is thoroughly packaged, where is the risk?
My plant works with seasonings. It is often the case that mixed varieties of seasoning come from one supplier all on one pallet with no regard for allergen content. As long as everything is in uncompromised packaging I don't see the risk. In an ideal world, I'd love to have a warehouse large enough to separate allergen from non allergen, but that's not always the case.


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KTD

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Posted 08 March 2012 - 10:36 PM

Could get a little outrageous...
What about upstream storage and handling?
My plants often get small quantities by expedited delivery trucks. What did the package sit on/under/beside.

Would a documented risk assessment have alleviated the issue?



GMO

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Posted 09 March 2012 - 11:01 AM

Could get a little outrageous...
What about upstream storage and handling?
My plants often get small quantities by expedited delivery trucks. What did the package sit on/under/beside.

Would a documented risk assessment have alleviated the issue?



There was a documented risk assessment. That wasn't accepted. I agree we could have argued out of it and both a contact at Campden (on BRC standards) and David Brackston himself implied it was a bit stringent. I agree it wasn't best practice but I don't agree it was a non conformance. Anyway, with only 4 minors, I'll get over it :thumbup:


D-D

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Posted 09 March 2012 - 11:24 AM

A more lenient approach would have been to say it wasn't right, you would agree, move it at the time to solve it, make a note, all done.

I know what you mean though. We also had 4 minors and if there had been more I would have argued a couple of them as they related to things that were "subject to risk assessment". Our risk assessment considered these issues and concluded there was no risk to the product but it wasn't the conclusion the auditor wanted. In the long run they were probably something we would be better sorting and as it was our first ever audit so we were delighted! So like you, I just accepted them.



GMO

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Posted 09 March 2012 - 11:29 AM

A more lenient approach would have been to say it wasn't right, you would agree, move it at the time to solve it, make a note, all done.

I know what you mean though. We also had 4 minors and if there had been more I would have argued a couple of them as they related to things that were "subject to risk assessment". Our risk assessment considered these issues and concluded there was no risk to the product but it wasn't the conclusion the auditor wanted. In the long run they were probably something we would be better sorting and as it was our first ever audit so we were delighted! So like you, I just accepted them.



Totally. If we'd had 11 minors I would have argued tooth and nail! I also figured whatever we do we will now want to maintain a similar or fewer number of minors next year. Seeing as there were two where I thought the auditor had been overboard, if I'd argued it back to 2 minors, I would have set myself a tough task!


KTD

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Posted 09 March 2012 - 02:28 PM

A little off topic, but I have seen multiple posts recently with references to what the 'auditor wanted'. Since the auditor is to function as a neutral judge, is it not his/her responsiblity to evaluate the info/data/analysis presented and, if no serious errors are apparent, accept the conclusions derived from such?






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