5 replies to this topic

[Bre]

Hello Everyone,

 

I am new to all this. It's great to see all the differnet topics of discussion. Our Company, is currently seeking BRC certification and I had a question regarding clause 6.1.5. It seems to me that this clause is overlapping with 3.8.1. specifically, " the deviation of the processs from specifications". I cover this in section 3.8.1 in our Product Hold Policy. Should I just reference the product hold policy; and come up with a procedure for, in the event of an equipment failure?  What does everyone think? Clauses are referenced below...

 

Thanks, 

Breann  

 

6.1.5 Clause: In the case of equipment failure or deviation of the process from specification, procedures shall be in place to establish the safety status and quality of the product to determine the action to be taken.

 

Clause 3.8.1: There shall be documented procedures for managing non-conforming products which include:

• the requirement for staff to identify and report potentially nonconforming

product

• clear identification of non-conforming product, e.g. direct labelling or the

use of IT systems

• secure storage to prevent accidental release, e.g. isolation areas

• referral to the brand owner where required

• defined responsibilities for decision making on the use or disposal of

products appropriate to the issue, e.g. destruction, reworking,

downgrading to an alternative label or acceptance by concession

• records of the decision on the use or disposal of the product

• records of destruction where product is destroyed for food safety

reasons.

[mgourley]

I think you would be safe referencing the product hold policy. However, that policy needs to state, in someway, what you do when there is a "unknown" reason for putting product on hold.

I'm dealing with this myself at this time. How do you write a procedure for a "what if?" situation? I'm thinking it all comes down to semantics. If your procedure states " If, for any reason, product is out of specification.... (insert hold criteria here). that should be sufficient.

 

Comments from those more in the know?

 

Marshall

Edited by mgourley, 29 May 2013 - 07:41 PM.

[Bre]

Thanks Marshall,

 

I was kinda of thinking the same thing.... BRC has all of these what if scenerios, and it can get a bit overwhelming at times...

[KTD]

My program has essentially the wording Marshall suggests...

[SVO]

Ours is the same and it complies with the standard and intent. Just make sure that your corrective action with the corresponding forms are documented.

[Bre]

Thanks everyone for your help.