3.6 Raw Material Specifications
Hi All,
I am a little bit stuck here. We deal in cold pressed canola oil. Recently in compliance to BRC V.6 on raw material specifications we carried out MRL tests on canola seeds that we press. One of the sample did not pass fully as it had higher traces of Lufenuron (0.04 aganist a recommended level of 0.02 under EU MRL levels. Codex MRL is silent on Lufenuron)
Our oil for sale both internationally (to a single client) and locally. However, the local requirements are based on Codex standards.
Upon carrying out the Finished product tests, the oil did comply to the required standards(local standards) and client standards.
I am a little bit worried by the fact that the raw material(canola seed) did not pass the MRL tests but the end product did pass the specifications.
on to my question?
1. Does BRC recommend a certian standard when ubdertaking an MRL test or is it upon the company to decide on the what they feel is the recommended level?
2. Does the fact that the finished product is safe for consumption make the MRL test results null and void?
Thanks in advance.
Audit in a weeks time. :(
Regards,
Waciru.
Hi Waciru,
1. Does BRC recommend a certian standard when ubdertaking an MRL test or is it upon the company to decide on the what they feel is the recommended level?
Despite the threads's Title, I assume you are referring to the finished product ?.
I suspect the exact details may depend on the actual case, ie the oil's destination.
Haven't checked for BRC but IMEX the usual (logical) global requirement is that the Regulatory requirement in the intended country of usage takes first priority.
In certain cases, such as EC, there is a possible further requirement due the EC's unilateral Standards and the initial country of arrival's local Regulations. And conceivably from an onward destination also although afai remember there is free movement within EC member countries.
Both your raw material and your finished product, should comply with legal requirements in the country of use/sale.
If your raw material does not comply, but the finished product will --> check your country legislation, if you may use this raw material.
In some cases you may, in some cases you may not. Make sure you have it documented, so you can always show to authorities and certification body where your decision was based on.
Hi Waciru,
Any further comments ?