7 replies to this topic

[Shyguy77]

To be in complaince with BRC v.6 standard 3.2 & 3.2.1 we have all of our Production, Quality, Maintenance and some HR & Accounting forms on a registry & controlled. Just wondering if i should try and persuade management to include the safety forms as well or if its just not needed at this time.




Thank you.

[Ames]

What I was told by multiple auditors is any document, form, program, etc. used in the plant by anyone needs to be controlled. You could gamble that it's unlikely any safety documents or programs will have to be looked at by the auditors, but if you can get it done, you just might as well to not only be uniform but also to cover your butt.

[Chris @ Safefood 360°]

Hi jpredmore.

The BRC standard clause 3.2: The company shall operate an effective document control system to ensure that only the correct versions of documents, including recording forms, are available and in use.


Notice that they do not state only food safety or production related records. To AMES' point, if you decide to forego controlling certain documents that are in use at your facility because the chances are good that the auditor isn't going to ask to see them, then it boils down to exaclty what he referred to and that is a gamble. During the plant tour of your facility, the auditor has observational access to all of your relevant "in use" documents. Should he happen upon a safety-related document that you chose not include in your document control program, chances are better than good that you'll get hit with a dreaded non-conformance.

When guiding your facility towards BRC (or other GFSI) certification, it often involves a huge change in culture. You may have heard the terms "quantum leap" and "paradigm shift" knocked around a few times and thought they are overused terms....IMEX they're not as it often takes sweeping organizational changes to effect real progress as you move towards, or continue certification effots. That having been said, the thought of having to update even more forms and include them in your document control registry (and program) may seem to be another growing pain you'd like to avoid, but it already sounds as if you have your program pretty well instituted. At this point, it's only a matter of finishing touches. Good luck with your efforts, and good luck on your next BRC audit!

-CD

[Foodworker]

Its unlikely that an auditor will get too concerned about documents which are not directly associated with clauses within the Standard, but as we all know, auditors will be auditors!

It does however, raise an additional train of thought.

A business is a combination of various activities -commercial, promotional, ethical, health & safety, food safety and many others. It is not just a BRC business.

The BRC should be a reflection of what you do, and within what you do, you should meet the individual requirements of the Standard.

Therefore, procedures, practices and controls that are applicable to the BRC may also be applicable to other activities. This is particularly true of Health & Safety. Risk assessments, training, maintenance, document control etc are all equally relevant to both the BRC and Health & Safety, so why look upon them as separate requirements.

A more holistic approach to business, using the BRC as a framework if necessary, will be of greater value in the long term.

[Tony-C]

Hi jpredmore.

The BRC standard clause 3.2: The company shall operate an effective document control system to ensure that only the correct versions of documents, including recording forms, are available and in use.

Notice that they do not state only food safety or production related records. To AMES' point, if you decide to forego controlling certain documents that are in use at your facility because the chances are good that the auditor isn't going to ask to see them, then it boils down to exaclty what he referred to and that is a gamble. During the plant tour of your facility, the auditor has observational access to all of your relevant "in use" documents. Should he happen upon a safety-related document that you chose not include in your document control program, chances are better than good that you'll get hit with a dreaded non-conformance.

-CD

3.1 The company's processes and procedures to meet the requirements of this Standard shall be documented to allow consistent application, facilitate training, and support due diligence in the production of a safe product.

I have been working with BRC since the 90's and I have never seen a non-conformance raised for the control of a document outside the scope of the standard. The chances of getting a non-conformance are minimal and any case if I got a non-conformance from an over zealous auditor I would appeal.

[D-D]

I agree with Tony. BRC is about food safety and if you go beyond and control every document in use outside the scope of that you will be there forever. It would be good practice, yes, but where would you draw the line?

[Tony-C]

To be in complaince with BRC v.6 standard 3.2 & 3.2.1 we have all of our Production, Quality, Maintenance and some HR & Accounting forms on a registry & controlled. Just wondering if i should try and persuade management to include the safety forms as well or if its just not needed at this time.




Thank you.

Hi jpredmore,

As foodworker has indicated 'Its unlikely that an auditor will get too concerned about documents which are not directly associated with clauses within the Standard'

It seems like it would not be too much work to add safety documents and although I know it is a focus to comply with the standard and achieve certification my view is that 'safety at work' is just as important. So despite the fact it is highly unlikely to generate a genuine non-conformance during an audit it is something that management would normally consider important.

Regards,

Tony

[Charles.C]

Dear All,

Slightly OT but i saw an "opportunity". (Apologies for disturbing the flow of an interesting thread).

I retreat from entering a discussion on the world of “scope” but I would like to add a cautionary note regarding “control”’ of documents.

I do not like to reflect on the amount of time I spent oscillating over how to first handle this issue at a time when individual PCs were less common and red stamps were the vogue (in some places they still are). In general, i daresay the problem is now vastly diminished but I suspect many factories are still stuck with relying on the printed word.

Yes, documentation control is a crucial issue and people using outdated documents can cause both havoc and health risks.

But the whole issue of “documentation” plagued ISO 9001 in the past so that my suggestion is to make sure that if you are not an online, PC- dominated process operation, select a non soul-destroying solution, eg add simple auto-statements on bottom of documents to painlessly cover one’s back then make sure that the beautiful plastic-encased scripts hanging all over the production floor really are the right versions.

One could extend the horror story to discuss the notorious “approval” sheet for new procedures, etc and the “revisions tracking form”. If you have a dedicated team to fulfil this function, well and good, if flying solo can be a real pain IMO. Once again, the requirements do have valid reasons so again the only option IMEX is to minimise the time involved. Topic for another day I guess.

> back to main topic.

Rgds / Charles.C