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BRC Issue 7 - 4.2.3 - Security of external tanks, silos, pipes etc.

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garyandrews

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Posted 06 July 2015 - 09:16 PM

Hi Folks,

 

Just wondering if any member has experience of thoughts on BRC Issue 7. - Query on Security - Section 4.2.3 External Storage of tanks, silos and any intake pipes with an external opening shall be locked. To what degree would this apply to for example a small to medium sized Dairy processor? Padlock on milk silos and intake pipes?

 

Regards,

 

Gary



gfdoucette07

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Posted 06 July 2015 - 10:02 PM

We are a small drying facility and we have 2 intake ports and we have a loop welded to the pip and then lock the cap to the pipe so it can not be opened.  Also  anywhere where you have access to ladders those need to have locked access as well too.  There should be no way someone from the outside should be able to pump into, removed material from, or gain access to your facility without you allowing it.  Hope it helps a bit but aside from locks on outside connections, outside doors, and roof access you should be ok

 

G



mgourley

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Posted 07 July 2015 - 08:44 AM

Gary,

 

That's the beauty of BRC. The Standard says that those things "shall" be locked.

Doesn't say "how" they shall be locked, just that they need to be.

 

Marshall



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garyandrews

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Posted 07 July 2015 - 09:52 PM

G/Marshall.

 

Thank you for your response. I believe the FDA type approach in terms of TACCP & VACCP will becoming more common place now certainly in the UK & ROI. Will be interesting to see how it plays out.

 

Gary



RosieMolly

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Posted 08 July 2015 - 08:13 PM

Hi there,

We have external tanks (winery) where we have welded tabs onto each valve (at the bottom) and onto the top lids and we use combination padlocks on each opening. Works well, and the combinations are given out on a job order for the relevant tanks only. We set it up like this initially to protect our clients product.



Harminnie

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Posted 08 July 2015 - 09:14 PM

We are the smallest BRC company our auditor had ever audited and bottom line-if it can be opened -lock it.  We have a port about 15 feet in the air--locked it-after we got dinged on it.



kiwilass

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Posted 17 September 2015 - 07:08 AM

Hi interested in getting feedback on this topic in particular from Rosie Molly as I work in the same industry. How do you find locking tanks actually works on an operations vs compliance level given there are normally at least 3 entry points you need to consider per tank and if your site has external multiple tanks especially during vintage.



Paulion

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Posted 22 September 2015 - 03:07 AM

Hi all,

 

Interesting discussion around locking of tanks etc. What about the sample taps/valves?

From the wording of the standard it looks like items such as Keofitt valves (sample taps) will need locking off too.

Does anyone have any info around this?



BGAQA

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Posted 23 March 2020 - 06:28 AM

Hi everyone, I'm having trouble finding this section in Issue 8. Has the principle been brought forward?



pHruit

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Posted 23 March 2020 - 09:24 AM

Hi everyone, I'm having trouble finding this section in Issue 8. Has the principle been brought forward?

Yes, the general requirement is still in 4.2.3, but they've made the clause broader / more vague, and expanded on it via the Interpretation Guide - if you read 4.2.3 with the corresponding part of the IG it's still clear that this is expected.



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BGAQA

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Posted 23 March 2020 - 08:41 PM

Yes, the general requirement is still in 4.2.3, but they've made the clause broader / more vague, and expanded on it via the Interpretation Guide - if you read 4.2.3 with the corresponding part of the IG it's still clear that this is expected.

 Broader and more vague, just what a good code does over time.

 

I had suspected that 4.2.3 covered it, which actually gives us more flexibility in achieving the same goal by not specially stating use of a lock.

 

I am just starting our BRC compliance, what is the IG you speak of.  And thank you for responding to my post. 



pHruit

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Posted 24 March 2020 - 08:18 AM

 Broader and more vague, just what a good code does over time.

 

I had suspected that 4.2.3 covered it, which actually gives us more flexibility in achieving the same goal by not specially stating use of a lock.

 

I am just starting our BRC compliance, what is the IG you speak of.  And thank you for responding to my post. 

Sorry, IG = Interpretation Guide - see https://www.brcgsboo...line/c-24/p-459

 

If your site is already certified you will be able to access this for free via the BRCGS Participate platform: https://brcgsparticipate.com/signin



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BGAQA

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Posted 24 March 2020 - 09:22 PM

Sorry, IG = Interpretation Guide - see https://www.brcgsboo...line/c-24/p-459

 

If your site is already certified you will be able to access this for free via the BRCGS Participate platform: https://brcgsparticipate.com/signin

Thank you very much, just downloaded the IG, very helpful.

 

The team here has come up with 4 different ways for us to accomplish the goal ranging in cost from about $10K to $60K, so it's an important interpretation for us!





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