BRC V7 5.4.5 Clause explanation please?
so..............
New Clause 5.4.5 “ Where claims are made about methods of production (e.g. organic, halal, kosher) the site shall maintain the necessary certification status in order to make such a claim”
We are looking at obtaining kosher status for a specific category of products produced at our site, however we have other departments which produce other products which we do not need to be kosher currently.
The Rabi has said we can either certify the site or certify the products / lines.
This is my issue, the interpretation is also not clear to me on this. Q= Do i need to maintain SITE certification of kosher to be compliant, Or would i still be CLAUSE compliant if the products on the lines were kosher certified specifically.
i mean it says "maintain the necessary certification status" what ever that means.
You only need to ensure that the particular products and their associated ingredients are certified as "Identity Preserved". You will need to segregate both ingredients and end products to do this. It's not really different from producing, say, Sicilian Lemon cakes where the lemon juice etc and the cakes need to be kept separate form other ingredients and products.
right so as long as the products produced and raw materials used are kosher certified i will remain compliant?
Where i have raw materials / product that is not kosher, i am still compliant providing that a) the materials are segregated and b) where those non-kosher are used on the production lines in question, the process is controlled in compliance to kosher. such as ocasionaly NPD may run a trial that uses ingredient A which is not kosher.
The site it self does not need to be certified to allow certification of a particular product?
As I understand it, you follow a similar set of rules as Organic, which are explained on the Soil Association website. If you have a Kosher line, it's probably easier. Your Rabbi will be able to give you more detail.
I'm sure someone else can fill in more detail here.
Hi David,
No direct involvement on this topic but it would seem to me to be predictable that the environment etc will inevitably be relevant also.
My limited experience with such issues encountered aspects such as purity, frequency of wash water used, etc,etc
= SITE ?
From the interpretation Guide:
"Where a site wishes to make claims relating to specific production methods, such as organic, Halal or
Kosher, the site is responsible for maintaining the appropriate certification to the standard(s).
While the accuracy of the production methods relating to these third-party certification standards will
not be assessed during a BRC audit, the auditor will require evidence that the appropriate certification
is in place, for example by reviewing the certificate or an online database of certificated sites."
Hi david,
FWIW, here is a proposed response by a software, etc organisation -
5.4.5 - Where claims are made about the methods of production, for example Organic, Halal, the site shall maintain the necessary certification status in order to make such a claim.
Compliance Tips
The XYZ module will manage all assurance or testing processes for you.
The XYZ Supplier Approval Management system automatically tracks the expiry of all Organic, Halal, Kosher & other certificates and chases suppliers for updated certificates ensuring you are always audit ready 24/7.
Well in most part our site is kosher, i have only 1 material left to find information for. however the lines in question should have no issue as the material is NPD related only.
Interesting software comment, because obviously programmed by an human inherintly the source of 99.9% computer related issues lol.
and by that info we would still be ok kosher wise, so great news for me atleast.
Hi David,
No direct involvement on this topic but it would seem to me to be predictable that the environment etc will inevitably be relevant also.
My limited experience with such issues encountered aspects such as purity, frequency of wash water used, etc,etc
= SITE ?
None of that is relevant to kosher, except for a need for there to be no insect parts or dirt in the food. Otherwise, food safety is not important for kosher.
You can't use materials in wash water that are derived from meat if your product is dairy or pareve. But, again, that's not a food safety issue, it is only important in the context of being kosher.
They answer to a higher authority, just ask the rabbi who will perform the inspection.
The BRC standard requires that the site have the certificates on file and schedule the proper inspections to maintain the certification, just like organic. But the entire site does not have to be kosher.
Martha
Do they taste good Martha?
In my experience of Kosher certification for food packaging. The Rabbi was only interested in seeing specifications of the raw materials, inks etc. used in the items for the particular customer. He also wanted to know about cleaning chemicals used in the process. Basically to make sure they did not contain animal fats etc. So the annual visit consisted of him collecting updated specifications, having a ten minute walk around the plant and giving us a bill for £1,000 and in return we got a kosher certificate. It was about as (un)rigorous an audit as one could get...but at least the almighty and Rabbis bank manager were both happy. :thumbup:
David you need to ask the Rabbi.
Regards,
Simon
Do they taste good Martha?
They are some of the best hotdogs around. And that was an excellent advertising campaign. I could not resist.
Our products could be used to make materials for Passover, and some lines are made with wheat straw as the source of cellulose. Our Rabbi was pleased that we have the gluten free data that shows that nothing from the wheat grain could be in the products. That way, it cannot rise, and is kosher for Passover.
Those are the sort of concerns that they have.
The BRC is only interested in knowing that the site gets the certifications to back up any claims, that the proper records are kept, and that you take the steps to preserve the material's special identity.
Martha