16 replies to this topic

[Dairy]

Hi all

Just wondering if anyone has had their BRC Audit against Version 6 standard yet and if so did you find it much different?

Thanks!


Dairy

[GMO]

Yes and No. To be honest for all of the chat about 50% of the time being on the shop floor, I didn't find that it was possible. For example, one of the things they need to check is the pest control contractor's training records, how can you check that on the shop floor?

I have heard rumours of some auditors checking documents "in a production office" to get around it. That's cheating in my view. Our auditor was a bit more open and honest about it but it's something to be wary of if your auditor is being audited.

Our auditor had two checklists; one for the GMP (factory) part, one for the records part. He hadn't done many issue 6 audits yet so we found he went through the GMP one including the paperwork he couldn't check in the factory and then ended up revisiting the same areas on the other checklist. I'm sure once he got more organised, it would work better.

That all said, I think auditors are spending more time in the factory even if it's not 50% and it's becoming more common to get factory non conformances rather than paperwork / system ones. I got a "heads up" from a supplier just before the audit to get more in depth root cause analysis in place for complaints (I did the same for internal non conforming product too) so we put in a "5 Why's" section onto these forms. I get the feeling a lot of people had been caught out on this because our auditor was really impressed at this approach.

I had a chat with someone from Campden after our audit and this is what they said:

Root Cause is catching a few people out.


Auditors are now being guided to spend 50% of the audit time in the factory, and feedback suggests that some are struggling with this.



This focus on factory time perhaps explains some of the statistics for non-conformances, in that only 2 of the top 10 are “new” clauses, but a significant number are environmental.



The figures are not routinely published, but the top 10 NC’s makes interesting reading:

10. Production zones (High Care / High Risk) 4.3.1

9. Equipment 4.6.1

8. Chemical controls 4.9.1.1

7. Doors 4.4.9

6. HACCP process flow 2.5.1

5. Metal detection test procedures 3.10.3.5

4. Walls 4.4.1

3. Glass register 4.9.3.2

2. Document control 3.2.1

1. Documented cleaning schedules 4.11



In addition to this, some significant trends are emerging in terms of:

Supplier approval / risk assessments of suppliers

Management of suppliers of services

Security risk assessments

Water distribution plans

Pest control surveys – verification

[shea quay]

Our auditor spent a lot of time speaking to staff. Never underestimate the ability of your staff to completely forget everything you ever trained them in. According to our warehouse man, calcium propionate is an allergen. My advice would be to drill staff daily until the audit about HACCP, allergens and chem/phys controls, and if possible, lock up your less intelligent employees in a freezer until after the audit. Oh dear God, that reminds me.....

[bibi]

Our auditor spent a lot of time speaking to staff. Never underestimate the ability of your staff to completely forget everything you ever trained them in. According to our warehouse man, calcium propionate is an allergen. My advice would be to drill staff daily until the audit about HACCP, allergens and chem/phys controls, and if possible, lock up your less intelligent employees in a freezer until after the audit. Oh dear God, that reminds me.....

Oh dear I am feeling your problem
how will be the case if you have no English speaker in some area of your process.
the translator? how confident are you with him/her on audit day?
BIBI

[shea quay]

If I was auditing BRC I would be uncomfortable with a translator to be honest. Who is to say the translator isn't the only guy who is trained in the factory? He could be just asking random questions and then reporting back the "correct" answers (does this show how much I've thought about this? - I think it's a fantastic idea myself!).

[Kamwenji Njuma]

Hi All,

I have been audit on the new version and i will concur with GMO that the auditor spent over 50 per cent of the audit period on the production floor rather than on records.He also did staff interviews and it was shocking to find that even after regular trainings the staff wont understand quality objectives which is a new requirements.So you need to be extra careful on trainings and ensure ALL staff are well conversant with the processes and not just a clique of trained staff.Also hygiene and fabrication is very critical as well as supplier approval.All in all it is a good start if you have all the procedures required and you have revised your manual.

Regards

Kamwenji Njuma

[Strider]

Hi,

We've had our version 6 audit, and the auditor only spent 35% of the audit time in the factory, and we had no NCs related to the changes from version 5.

Overall not much changed for us at all.




Happy auditing

[GMO]

Sounds like there are some wide variations in how it's being audited. Let's hope they're ironed out by next year. Our auditor spent shockingly little time talking to shop floor staff. In fact, I saw auditors auditing against version 4 who spent more time talking to the operators.

I'll make sure I am auditing against people as much as possible so they're used to it come next year in case we have a different auditor. I'm starting to think we were pretty lucky!

[Dairy]

Thanks to all for you replies. We've had our audit and it was not markedly different to last years. When I knew we were doing ok towards end of day 2 I asked her how generally companies are responding to rev 6 she commented that she has been suprised that so few seem to have even read the changes. The things that are catching people out are:

Not having root cause analysis covered in complaints, non-conformances etc.
Not having root cause analysis done on previous years BRC observations - she said we were the first company that she visited that had it done!
Not having addressed all the CIP requirements which are substantially new - this is catching alot out she said.
Not having addressed all the supplier approval additional requirements
Issues related to allergen control - This is not an issue for us thankfully


During the audit the additional things she asked for vs. Rev 5 were Validation docs for our CCP's; Risk Assessement on Raw Materials, Packaging, Chemicals; Validation of CIP processes, Shelf Life assessments; All supplier approval related information

As a tip, if you have not had your supplier questionnaires (and boy is this a tedious process) etc. back from all suppliers have a NC/Deviation raised to cover the use on a technically "unapproved supplier" and a Risk Assessment done for each supplier that is missing info. Also make sure your procedure covers such "exceptions"

We got 3 minor NC's but there were a couple of additional things that she just recommended we correct such as - Magnets need to be verified at defined intervals WRT strength - I totally missed this when going through the BRC changes - we have a new one which came certified but didn't have a Cal in system for periodic verification. Also, water layout drawing - we had one but forgot to add the sampling points to it! Sounds obvious, I know!

She also said that there is not physical possible way that an auditor can spend 50% of their time on the floor in her opinion as all docs are generally in office areas etc.

Thats it for another year! Hope this helps!

[GMO]

Not having root cause analysis done on previous years BRC observations - she said we were the first company that she visited that had it done!

In an odd way we would have been ok on this but it wasn't intentional. I've put root cause into all of our audit documents and I also audited all of the previous year's non conformances as part of the senior management commitment but I'd not deliberately gone out to do root cause analysis of the previous year's non conformities.

Interestingly though, the clause regarding this does not ask for root cause analysis but that the root cause is addressed to prevent recurrence.

Anyway, I've already done root cause analysis on this year's non conformances in my response. It's taking a painfully long time to hear if my responses have been ok though.

[edz]

Hi all

Just wondering if anyone has had their BRC Audit against Version 6 standard yet and if so did you find it much different?

Thanks!


Dairy

[edz]

Yes, just the past few days, my 11th on the trot!

It all depends on the auditor you get really.

[D-D]

Our auditor spent a lot of time speaking to staff. Never underestimate the ability of your staff to completely forget everything you ever trained them in. According to our warehouse man, calcium propionate is an allergen. My advice would be to drill staff daily until the audit about HACCP, allergens and chem/phys controls, and if possible, lock up your less intelligent employees in a freezer until after the audit. Oh dear God, that reminds me.....

If I was auditing BRC I would be uncomfortable with a translator to be honest. Who is to say the translator isn't the only guy who is trained in the factory? He could be just asking random questions and then reporting back the "correct" answers (does this show how much I've thought about this? - I think it's a fantastic idea myself!).

These really are very funny; thanks for the laughs shea quay!

[Kay Begum]

Would anyone kindly tell me how many days your auditor took for the Version 6 audit? Thank you!

[Kay Begum]

Yes funny indeed, but clever too!

[KTD]

Dear Kay Begum -
The length of your BRC audit is tied to the size of your facility. I do not have my BRC Standard handy (I ask for forgiveness), but it seems there is a section that details audit time versus facility size. Make sure you are clear when signing upf or your audit to specify actual square footage in use - my company purchased a closed facilty where we are currently only utilizing 10% of the footprint...initial audit was set for 3 days based on size until the auditor arrived and recommended 2 days, based on current operations. Signficant difference in time and audit costs!

One of my facilities as been audited to v6 so far - have another due in 2 weeks. Auditor did spend more time on the processing floor than during previous audits, but nowhere near 50%. Only noticable change versus v5 was more discussion on Root Cause Analysis - like GMO, we started using the '5 Whys' analysis procedure some time back.

In the future, if I indicate that I am job hunting, someone please remind me not to go to work for Shea Quay. Although I have a stocky build and am rather well insulated, not sure that I want to spend significant time in the freezer...

Edited by KTD, 27 October 2012 - 03:19 AM.

[infoiqc]

Would anyone kindly tell me how many days your auditor took for the Version 6 audit? Thank you!

BRC has produced a guideline for calculating length of the audit. It is available at:
http://www.brcglobal...bid=178&mid=595

Typical audit length is 2 days.

Gail
infoiqc