Metal Control Policy to comply with BRC 4.9.2

Hello there!

Im working on our Metal Control Policy. i wouldl ove too see how are you guys attacking this clause?

maybe some examples would be appreciate it!


i have attached what im currently working on.

Hello there!

Im working on our Metal Control Policy. i wouldl ove too see how are you guys attacking this clause?
maybe some examples would be appreciate it!
i have attached what im currently working on.

Dear Frank88maurice,

A little more background info. might be helpful, eg

product ?
Process type, eg RTE food, whatever ?

Rgds / Charles.C

We Make Candy "Licorice"

Hello there!

Im working on our Metal Control Policy. i wouldl ove too see how are you guys attacking this clause?

maybe some examples would be appreciate it!


i have attached what im currently working on.

Hi Frank,

I had the new facility audit last week for BRC. Lead auditor was after staples, clips, pins, tools etc, but not just knives and ingredient control. I am in the process of writing a new metal control policy.

Hello there!

Im working on our Metal Control Policy. i wouldl ove too see how are you guys attacking this clause?

maybe some examples would be appreciate it!


i have attached what im currently working on.

Hi,
loosen nuts & bolts during cooking and extruding? ( probability?)

Dear frank88maurice,

Thks yr product clarification. Presumably RTE. Sort of lifts the sensitivity up one notch.

Strangely there are very few metal control policies posted here AFAIK. Presumably the overall policy is that appropriate control procedures are designed / validated / implemented such that no harmful metallic contamination will be "presented" to the final consumer. One would have thought that "risk assessment" might have had a place in there somewhere also.

In ISO-speak, the terminology "control policy" is rather ambiguous IMO in respect to overlap with "procedure". As frequently demonstrated here, one can split semantic hairs indefinitely but it's the procedures which ultimately produce the goods. i daresay yr content style works OK for BRC's purposes. Other posters have opinions ??

Its probably only a personal nit-pick but i would have included an intro. something like "items to be considered within the MCP are detailed in procedure ...." (or within the policy itself).

A more specific (and obvious) comment is that yr policy wording may not be fully compliant with para 4.9.2.1, eg "lost ....". This element may be included within the "Procedures" but I try to minimise opportunities for auditor nagging. Other people here may well go the other way.

As far as the details of yr unknown procedures go, the subject of knife control has previously generated a lot of headaches, pleas for advice on various issues on this forum, an extended discussion (inc. links to older threads) is here -

http://www.ifsqn.com...dpost__p__48618

Yr own relevance to the above-mentioned difficulties (if any) may well relate to yr specific candy process (?) and, if present, yr procedures for controlling (??).

[Not sure if referenced in above link (or its sublinks) but Simon posted a (then) compliant basic BRC knife policy / procedure / form (aka sharps) here a few years back within his comprehensive (then) set of "BRC hygiene procedures package". AFAIK the package is still available here for direct download if you are interested.]

Rgds / Charles.C

Dear frank88maurice,

My apologies but I had a partial rethink over yr OP after a little wandering around the net. Below are some more comments / proposed policy based on my comparison of interpretations in various documents. IMO there is no method which fits every situation (everybody?) so i only suggest below content as an alternative to yr structure.

I particularly liked the IT presentation in this link –

http://www.bizmanual...procedures.html

However this extract suggests that in the real world, considerable flexibility of format is acceptable depending on individual criteria, eg the expected degree of direct usability of the policy statement -

quality policy design.png   1.62MB   50 downloads

Accordingly my tentative summary, in very crude fashion, is that a "policy" seems to minimally (but maybe depending on situation) require some, or all, of –

1. A presence / style of an explanation / purpose / principle of the policy, (eg mission statement type policy in above link)
2. A presence of an intended target / receiver (eg employee rules type policy in above link)
3. A degree of overlap / cross-reference to a subsequent procedure (which will normally exist?).The degree is open to debate.

Regarding BRC6 itself and the OP's specific 4.9.2.1, the standard seems to demand a policy which includes chunks of (what IMO could equally be reserved for) any subsequent procedure. So be it.
BRC's glossary defines "procedure" but not "policy". Typical! But presumably also leaves the user’s options open.

My suggestion is -

Policy for Sharp Metal Instruments

Control procedures are implemented to minimise the risk of any harmful metallic contamination due sharp instruments being present in the end-product and reaching the final consumer.

Sources / risks of possible metal contamination and their appropriate preventative control are detailed in the haccp system. Specific items assessed include knives, cutting blades on equipment, needles and wires.

A record of inspection for damage and the investigation of any lost items is included.

Snap-off blade knives are not used.

Details of implementation of preventative control methods are given in procedures TSOP 001,etc and associated documents.

My comments on yr Policy –

Needs an introductory “purpose”.
IMO the majority of yr No.1 is really “procedure” although it could relate to an “employee’ type policy but that seems not very applicable in this case (?).
IMO yr no.2 is not strictly relevant to the “policy” as stated in the standard’s 4.9.2.1 (although it would be relevant to a global "metal contamination control policy").

Regardless, and particularly as per attachment above, I daresay you / some other users will substantially disagree my opinion. No problem at all.

Any alternative suggestions no doubt welcome to the OPoster.

Rgds / Charles.C

PS - it seems conventional to use future tense in policy statements. i occasionally found this rather clumsy so i considered it justifiable to avoid it as per earlier attachment.

Wow! I will def use all of this information to improve on my metal control policy, you all are very kind to share your opinios!