12 replies to this topic

[Miss Tammy]

I would like a definition of the terms High/Low care and High/Low risk.  We are a RTE bagel manufacturer, fresh and frozen.  We are BRC certified and I couldn't decide where to post!

 

Thanks!

[Madam A. D-tor]

The BRC standard issue 6 gives definition of high risk and high care in the glossary.

In appendix 2 of this standard, BRC provides a decision tree to find out for all your areas, if these are "enclosed products", "low risk", "high care" or "high risk". In appendix 2 also more information on zoning is given.

The BRC also provide a guidance document "understanding high risk and high care", june 2012. This is free for download on the www.brcglobalstandards.com.

[it_rains_inside]

Madam A. D-tor beat me to it, but I agree 100%.

BRC provides all the tools you need to determine zoning. Especially the decision tree, its a great resource. Some areas of your plant may be different based on the operation that is happening in each section. 

 

The real question is, how was BRC certification achieved without this knowledge?

Your risk level plays into many different areas of how the standard is achieved, as far as internal audit/ inspection frequency and gmps / uniforms, material handling, etc....

what were you considered at the last audit? How did the question come about?

[cazyncymru]

I'm with the girls on this...how the hell did you get passed the BRC??????

[Charles.C]

I would like a definition of the terms High/Low care and High/Low risk.  We are a RTE bagel manufacturer, fresh and frozen.  We are BRC certified and I couldn't decide where to post!

 

Thanks!

 

Dear Miss Tammy,

 

I assume you are referring to the Product rather than the Processing Area.

 

BRC 6/7 food give (I think identical) definitions in the standards' glossaries for high risk/high care products respectively.

(the definition for high care is, afaik, unique to BRC and, debatably, unvalidatable ).

 

BRC7 also (essentially) defines ambient high care products and low risk products within the body of the text (see Pg 97 for example).

 

The new decision tree for ambient products in BRC7 may be of interest to you.

 

Rgds / Charles.C

 

PS - i don't think "Low care" exists, perhaps not unsurprisingly ?

[Miss Tammy]

_{I understand your reaction as to how we were certified.  Let me clarify.  We have always been considered low risk in all areas of our facility.  We achieved BRC "A" ratings every year since 2011.  My questioned is the result of  frustration with a customer auditor who insisted that our packaging area is high risk/care.  I guess I wanted some validation from the experts that I am right!  It drives me crazy when auditors come in and try to pretend they know what they are talking about.} 

[cazyncymru]

Well if you use the BRC decision tree, and their guidelines, you are Low Risk

 

Ask your customer auditor to justify why they think you should be anything else.

 

Caz x

[fgjuadi]

It's easy to see how packaging could be a higher risk area; most of the time it is post CCP.   So I've always considered packaging or anything post CCP as a higher risk than the other areas of plant, because there's no control.  But that doesn't mean the risk is elevated enough to call it high or treat it like infant formula.   You could make the case that your PRP programs are strong enough to lower the risks post CCP?

[john.kukoly]

Miss Tammy, you had me concerned on the first question, thinking along the same lines as some others in wondering about the certification.

 

Then your second clarification brought it all back home. BRC has used terminology like high risk, high care, and others based on a specific definition. Unfortunately everyone in the industry uses the same set of terms, especially "high risk"  - each with their own definition. So having a customer want to label an area with different terminology happens. It sounds like you have everything right from that perspective, you may need to whip out the aforementioned decision tree and walk your customer through it. 

 

That being said, the label is not the important part, it is the question of what the label brings forward. If a customer wants to call it high risk in their language, what are their expectations for a high risk operation?

 

John

Edited by john.kukoly, 11 February 2015 - 04:29 PM.

[it_rains_inside]

_{I understand your reaction as to how we were certified.  Let me clarify.  We have always been considered low risk in all areas of our facility.  We achieved BRC "A" ratings every year since 2011.  My questioned is the result of  frustration with a customer auditor who insisted that our packaging area is high risk/care.  I guess I wanted some validation from the experts that I am right!  It drives me crazy when auditors come in and try to pretend they know what they are talking about.} 

 

Thank you for the clarification!! 

 

That being said, the label is not the important part, it is the question of what the label brings forward. If a customer wants to call it high risk in their language, what are their expectations for a high risk operation?

 

John

 

I hate to be combative, but I beg to differ.... The labeling of an area is important, especially to a BRC auditor. You start calling an area 'high-risk' or 'high-care' and they are going to start looking to see if your programs match the expectations for that type of process. As you said yourself....

 

BRC has used terminology like high risk, high care, and others based on a specific definition. 

 

To them that specific definition of an area or process comes with a very explicit set of expectations, and the standards do differ for the different areas of care.

 

I do agree, that walking this customer through the BRC decision tree is great idea, explaining to them why an area would be 'labeled' as it is. If they insist on calling it something else, 'high-care' for example - then extreme detail should be laid out that this is a customer decision, however according to BRC, it would still be considered low-risk, or whatever.

 

We had a similar situation during one of my past BRCs. (which is why I would approach this with caution) Our entire plant is considered low-risk. We pack aspetically (closed system) and our product is high-acid. We have an open product zone which we called 'high-risk' internally, because compared to other areas of the plant, it was the highest risk. When we started calling this area 'high-risk' the auditor quickly started singing a different song and starting inquiring about sections of the standard that are not applicable to us (ex: 4.8.4 & 4.8.5)

 

He warned that the terminology we were using could have raised some serious issues, so now we label as low-risk, zone 1 (open product) , low-risk, zone 2 (enclosed product), low-risk, zone 3 (auxiliary and warehouse), etc....

 

Hopefully this helps!

[Miss Tammy]

^{We were given a nonconformance for this.  In my CAR I stated "None" and cited BRC requirements as the reason.  Sometimes you just have to push back!   Thanks for your input.....}

[Charles.C]

Dear Miss tammy,

 

IMO post #7 says it all from the  auditee's POV..  I would suggest best implemented at the time of the audit > maximum push-back.

 

IMO BRC have more or less gone their own (zoning) way following the Chilled Foods original initiative. And now they don't know where to stop.

 

I'm waiting for them to designate the Production area for 1-day, ambient hot-dogs (no preservatives).

 

Rgds / Charles.C

[cazyncymru]

The problem with the BRC zoning as such is that once you change it for a customer, then it remains as such for all operations you do in there!

I have a customer who wants us to go from high care to high risk. I didn't refuse, just asked them for their justification as I would then have to make every operation high risk. They couldn't come back with a justification, but still tried to make us do it. I then quoted the BRC justification for their product ( which was low risk!)they then backed down and were satisfied with it bring high care. If they could guarantee 100% captivity for that line, I'd have made it any risk they asked, but we're probably talking less than 1% capacity. Sense prevailed! 

Cazx