BRC 3.5.1 raw material
When it talks about raw material, does it only mean ingredients here? Or packaging as well. The interpretation guide only seems to mention ingredients, but I want to be sure.
Thanks for all your help!
Just look the the clause itself:
3.6.1 Raw material and packaging specifications packaging specifications lot matched up with Raw Material lot
3.5.2.1 Acceptance of raw materials/Packaging
1) based on one or a combination of:
· visual inspection on receipt
· certificates of conformance – specific to each consignment
· certificates of analysis
· product sampling and testing.
Be concerned with anything that is in direct contact with the food and the "food" itself (ie- any ingredients)
-B
Ingredients, packaging, chemicals, lubricants, pesticides, hygiene goods etc etc. Not all are high risk, so a risk assessment will point your and yourresources and control efforts in the direction of certain ingredients and primary packaging as highlighted by baron.
george
OK, thanks. Off I go to risk assess...
When it talks about raw material, does it only mean ingredients here? Or packaging as well. The interpretation guide only seems to mention ingredients, but I want to be sure.
Thanks for all your help!
Not sure which guide you are looking at?
The BRC Global Standard for Food Safety Interpretation Guideline (Issue 6 June 2012) for clause 3.5.1 Management of suppliers of raw materials and packaging refers to 'all materials bought onto site to become part of final product (including packaging). The process will consider the potential risk the material represents in terms of safety, legality and quality.'
Ingredients are referred to specifically in this Guidance:
3.5.1.1 Raw material risk assessment
All proposed ingredients shall be subjected to a documented assessment of their inherent risk.....
Risk assessment should consider:
known hazards
use of ingredient (where added in process)
spread of ingredient
nature of the supplier
historical evidence
geographical origins
methods of manufacture
significance of ingredient to final product
customer or legislative requirements
etc.
Some of the other materials mentioned may or may not be considered a considered a risk. Aspects of assurance of purchases are also reflected in 3.6 Specifications Guidance.
Regards,
Tony
Hi Tony,
This is why I am confused. 3.5.1 mentions "all materials", but then 3.5.1.1 says "all proposed ingredients shall be subjected to a documented risk assessment".
We have a supplier approval program for "all materials", so do I only have to do risk assessments for "all proposed ingredients"?
Help! :helpplease:
In the systems I have set up and seen other companies doing, I have made the blanket statement generally amounting to "All material that has the potential to come into contact with food being processed at this facility will be Risk Assessment considered."
Depending on the complexity of suppliers and ingredients, I'd suggest starting out with all your suppliers 1st and then delve down into what they are supplying you. A food belting supplier would be low given that you obtain the certs from them that the belts are Food Grade certified. A supplier of ingredients such as black pepper or peanuts would have a higher risk and tighter criteria than, say, raw potatoes intending to be cooked/processed further.
If you have allot of suppliers, this is almost a full time job (that I have also seen procurement departments handle quite well)... but I have been seeing may "Supplier Quality Manager" positions being posted in the last 2 years.
Hope this gives you some ideas.
Cheers,
-Baron
In the systems I have set up and seen other companies doing, I have made the blanket statement generally amounting to "All material that has the potential to come into contact with food being processed at this facility will be Risk Assessment considered."
Depending on the complexity of suppliers and ingredients, I'd suggest starting out with all your suppliers 1st and then delve down into what they are supplying you. A food belting supplier would be low given that you obtain the certs from them that the belts are Food Grade certified. A supplier of ingredients such as black pepper or peanuts would have a higher risk and tighter criteria than, say, raw potatoes intending to be cooked/processed further.
If you have allot of suppliers, this is almost a full time job (that I have also seen procurement departments handle quite well)... but I have been seeing may "Supplier Quality Manager" positions being posted in the last 2 years.
Hope this gives you some ideas.
Cheers,
-Baron
Would it be more time-efficient to do groups of packaging (e.g. all cardboard trays) instead of each individual item or supplier? This way similar products purchased from different suppliers would be covered on one risk assessment. We have a (relatively) short list of raw materials.
Thanks.
Hi Tony,
This is why I am confused. 3.5.1 mentions "all materials", but then 3.5.1.1 says "all proposed ingredients shall be subjected to a documented risk assessment".
We have a supplier approval program for "all materials", so do I only have to do risk assessments for "all proposed ingredients"?
Help! :helpplease:
'all materials bought onto site to become part of final product (including packaging)' - there are certain to be many other materials, some of which are mentioned that are not part of final product.
Maybe it would be easier if you start off by categorising the materials you purchase like this (higher category = higher risk):
5 - Ingredients in final product that are not further processed
4 - Ingredients in final product that are further processed
3 - Food Contact Packaging
2 - Possible Food Contact Materials
1 - Secondary Packaging
0 - Other Materials no possible contact
Clearly category 3, 4 & 5 require risk assessment and identification of potential hazards particularly 4 & 5 which need to be assessed as per 3.5.1.1. Appropriate raw material tests for acceptance are then put in place clearly being likely to be more stringent for Category 5 maybe with a positive release of ingredient based on your own tests prior to use. Category 2 would be a combination of risk of contamination and risk from materials.
As an example of a rough guide for Supplier Approval and Monitoring you may decide in principle Category 0 & 1 you may buy based on a specification, Category 2 you audit every 3 years, Category 3 every 2 years, Category 4 every year and Category 5 every 6 months. These guidelines and incoming inspections would be adjusted based on your assessment.
Regards,
Tony
Dear WowQC,
It appears to me that a lot of the (3.5.1) confusion is not down to you. IMO, BRC have messed up their textual presentation in this new section of 3.5, particularly if compared to the related “Purchasing” segment of Ver.5. Or perhaps the possibility of a slight assist in the promotion of their interpretation guidelines was noted.
The meaning of “raw materials” within a HACCP context is hardly standardised and, IMO, BRC have used it “flexibly”.
To enhance the practical advice already given, this haccp-oriented interpretation may (hopefully) help.
raw materials.png 564.68KB 11 downloads
Rgds / Charles.C
Thanks Tony and Charles.C. I will group the raw materials and ingredients, and go from there. At least we have relatively few ingredients and packaging types!