19 replies to this topic

[Hazira]

Hi all, is there anyone here discontinue their HACCP audit after certified with BRC? 

My top management has decided to discontinue the HACCP this year.

Usually every year two internal audit and management review (one for HACCP and one for BRC)

is this means i can only do one time only?

 

[Mr. Incognito]

Hazira,

 

As per HACCP you have to review your entire HACCP program once a year to see if there should be any adjustment due to changes in climate -> Regulatory changes, new emerging industry information, etc. via your HACCP team.

 

An internal audit on HACCP should be an auditor looking over the records of your HACCP team's review to make sure it was done and done properly.

 

I don't use BRC but I've been in SQF and FFSC and both of them check over the HACCP system and look for evidence of the annual review.

 

I'm pretty sure you should still be doing your annual HACCP review.

 

http://www.ifsqn.com...tion-procedure/

[it_rains_inside]

Hello Hazira,

 

Mr. I is right on the money with this. You really can't "discontinue" HACCP because of certification, especially because it is one of the main pillars (and a fundamental) clause of the BRC Standard. 

 

See BRC Clause (Issue 7) 2.14.1 - The HACCP team shall*  review the HACCP plan and PRP's at least annually and prior to any changes which affect product safety. (*REMEMBER: Shall = MUST in BRC terminology) 

 

It should absolutely be included as part of the internal audit program to review documentation / record keeping to ensure that the HACCP controls (including controls managed by PRPs) are in place, maintained, and are sufficient. 

[Mr. Incognito]

Thanks rains I don't have the BRC standard so I couldn't quote it but I was pretty sure like SQF and FFSC that was a direct requirement. 

[Tony-C]

Hi Hazira,

 

Sorry quoted food then noticed you were referring to the packaging standard, a review should be carried out when there are changes that can affect food safety and at a minimum annually:

 

BRC IOP Issue 4

2 Hazard and Risk Management System

2.2.11    A review of the hazard and risk management system shall be carried out at least once per year and following any significant incidents or when any process changes.
The review shall include verification that the hazard and risk analysis plan is effective and may include a review of:
Complaints
Product failures
Recalls
Product withdrawals
Results of internal audits of prerequisite programmes
Results from external third-party auditors.

 

Regards,

 

Tony

[Charles.C]

Dear All,

 

i thought Hazira meant he/she was running 2 "standards", HACCP and BRC.

 

And not impossible in the wrong forum ?

 

Rgds / Charles.C

[Mr. Incognito]

If by "HACCP" Hazira meant an auditing body such as AIB then it would definitely be a different story however if Hazira is asking if they can forgo performing the HACCP annual review required of HACCP which is a basic building block of the food safety standards then no they can't forgo performing that annual review.

 

HACCP is not a food safety standard.  HACCP is a systematic approach for identifying and mitigating potential hazards in the food manufacturing arena which covers packaging, ingredients, and finished food products.  If any of those items have additional hazards present then the end product could become adulterated. 

 

So the question back to Hazira is do you mean you were planning on not continuing to perform required measures to keep your HACCP system updated or are you planning on stopping having another auditing body that focuses on HACCP come to your facility.

[Snookie]

I was wondering if Hazira, meant more a GMP or general third party audit but called it a HACCP audit.  I agree with everyone that HACCP has to audited yearly.

[Mr. Incognito]

That's what I asked last post.  If it's like an AIB inspection then yes they don't have to do it...

 

I'm not sure though because of the part they put in about internal auditors.

 

"Usually every year two internal audit and management review (one for HACCP and one for BRC)"

 

Now you only have to do one annual review as long as you are performing a review of HACCP and whatever BRC requires to be reviewed.  If it's all done then it's all done but without more information from the original poster there is really no way to give any further guidance.

[Charles.C]

HACCP is not a food safety standard. 

 

Actually, in common practice, it frequently is. It's maybe slightly nearer the truth than a  GFSI Certified Standard.

 

Just Business and Local Regulatory Options.

 

Rgds / Charles.C

 

PS - with a little more stretching, it can even be a FSMS Standard

[Snookie]

Hopefully we will have an answer but most likely they are sleeping as its one in the morning on Tuesday. 

[cazyncymru]

God I wish I was only doing 1 HACCP review a year!

I've probably had a HACCP meeting at least twice a month because of things that have cropped up (new kit, new ingredients, product recalls reported by FSA)

 

But as all of the others have said, and as I read it, yes you need to be carrying out a review of HACCP at least annually.

 

Caz x

[Charles.C]

Hopefully we will have an answer but most likely they are sleeping as its one in the morning on Tuesday. 

Dear Snookie,

 

Actually a little searching indicates -

 

Product is injection moulding of disposable plastic cutlery. Packaging ?? Food ?? (I presume it's packaging   )

AIB likely involved since long-term used.

"BRC" just certified.

 

Unsure if this more, or less, complicates the OP.

 

Rgds / Charles.C

[Hazira]

First of all thanks for all the replies, realy appreciate them.

what i meant is the top management decided not to renew our HACCP certification, because they think BRC certification already covers HACCP and QMS. My question is, do i need to perform HACCP Internal Audit and HACCP Management Review eventhough no longer renew the HACCP certification?

Usually my audit schedule is:

Feb: HACCP Internal Audit

March: HACCP Management Review

April/May: HACCP External Audit

Sept: BRC Internal Audit

Oct: BRC Management Review

Nov; BRC External Audit.

 

I'm sorry if my question is confusing...

[Hazira]

Mr. Charles C., 

Yes, i just certified with BRC IoP (Packaging & Packaging Material) last year,

before this we use AIB and SIRIM (Malaysian CB).

[Charles.C]

Dear Hazira,

 

below is similar to Post #5.

 

I have self-assessment tool  BRC packaging, ver 4,High risk/Low risk (released 17/2/2012,8/2/2012 respectively) (Hopefully the current versions) - sec.3.3.1 states -

 

Internal audits shall be planned and their scope and frequency shall be established in relation to the risks associated with the activity. Audits shall be scheduled so that all aspects of the Standard are audited at least annually

 

Seems to answer yr query as YES ?

 

And similarly sec.1.4.1 -
 

 

The review process shall be undertaken at appropriate planned intervals, as a minimum annually.

 

 

 

And most (probably all) FSMS Standards have a similar requirement. (AIB no idea though).

 

Pls revert if i have answered the wrong question.

 

Rgds / Charles.C

[Mr. Incognito]

Charles,

 

5.25.1.9:  The facility conducts a review of the HACCP program annually or as changes (e.g. products or process) occur:

•                 Records are available
•                 Records are kept one year or two times the shelf life of the products, whichever is longer or as defined by regulator requirement.

 

This is listed a critical requirement of AIB.  I don't know what the version or year of this standard I'm looking at is but it can't be too old. (just checked online and it's the same as the current version if they have versions)

 

Hazira,

 

So long as you are continuing to completely satisfy taking care of your HACCP plan including performing the annual review by your HACCP team (having a HACCP team is the first of the 12 steps of HACCP)  you don't NEED to continue having AIB audit your facility.  However, some places choose to continue having AIB come yearly because they look at a very narrow "area" and look at it thoroughly.  Our Corporate level food safety team has decided to continue having AIB audit us for that reason.

 

I don't know what SIRIM is so I can't really comment on that.

 

So the long and the short of my message:

 

AIB is a self contained auditing body.  AIB does not directly influence BRC at all.  You don't have to be AIB certified to be BRC certified.  You can drop AIB and continue properly with BRC.

 

Please ask if you have any more questions.

Edited by Mr. Incognito, 17 February 2015 - 12:42 PM.

[Charles.C]

Dear Mr.Inc,

 

Well-explained. Thks.

 

I guess this is SIRIM -

 

http://www.sirim.my/

 

Rgds / Charles.C

[Mr. Incognito]

Ah good call Charles.  So it's basically the government regulatory and research division.

[Tony-C]

Charles,

 

5.25.1.9:  The facility conducts a review of the HACCP program annually or as changes (e.g. products or process) occur:

•                 Records are available
•                 Records are kept one year or two times the shelf life of the products, whichever is longer or as defined by regulator requirement.

This is listed a critical requirement of AIB.  I don't know what the version or year of this standard I'm looking at is but it can't be too old. (just checked online and it's the same as the current version if they have versions)

 

So the long and the short of my message:

 

AIB is a self contained auditing body.  AIB does not directly influence BRC at all.  You don't have to be AIB certified to be BRC certified.  You can drop AIB and continue properly with BRC.

 

 

That is 2013 and the latest available. Since AIB is not a GFSI benchmarked standard and BRC is the decision to drop AIB makes sense (unless it is a customer requirement). A while ago I had a customer that wanted it in addition to existing certifications (BRC Food, Organic, Bureau Veritas, Ethics etc.),  think it was for a 'diet brand' owned by a US company.

 

First of all thanks for all the replies, realy appreciate them.

My question is, do i need to perform HACCP Internal Audit and HACCP Management Review eventhough no longer renew the HACCP certification?

Usually my audit schedule is:

Feb: HACCP Internal Audit

March: HACCP Management Review

April/May: HACCP External Audit

Sept: BRC Internal Audit

Oct: BRC Management Review

Nov; BRC External Audit.

 

I'm sorry if my question is confusing...

 

For BRC the requirements are a review of the hazard and risk management system to be carried out at least once per year and following any significant incidents or when any process changes and internal audits scheduled so that all aspects of the Standard are audited at least annually.