Inclusion of Packaging VA in VA for Food Raw Materials, 5.4.2 ?
Hi All,
In view of some recent queries regarding any expected inclusion of a Packaging VA for BRC7 / 5.4.2, I thought it might be useful to seek auditee’s experiences on this topic.
Only 1 Question - appreciate your input.
Any additional, related, auditorial observations feel free to post.
PS - I reset the numbers to zero (ca. early June 2016) due the confirmation of BRC (Nov.2015) that Packaging VA not required ("score" was 11-9).
We covered packaging and its approval through the packaging section within BRC v7 scope and risk assessment. It was agreed the packaging WE have was limited and from major approved/well known suppliers and very unlikely to cause any issues.
We covered packaging and its approval through the packaging section within BRC v7 scope and risk assessment. It was agreed the packaging WE have was limited and from major approved/well known suppliers and very unlikely to cause any issues.
Hi JohnWheat,
Thks for input.
i deduce you mean that you did not submit a formal VAP to respond to 5.4.2 ?
Packaging is already covered in 3.5.1.1, 3.5.1.2, 3.5.2.1, 3.6.1 and 5.5.1.
I can't see any reason for including it in the VA in 5.4.2. especially when that clause states:
"A documented vulnerability assessment shall be carried out on all food raw materials or groups or raw materials to assess the potential risk of adulteration or substitution..."
Marshall
I have a question for people who did submit packaging VA:
Did you include secondary packaging as well or just primary or consumer packaging?
Thanks
We haven't been audited yet so no experience so far. Anyway we have decided to include packaging in our VA. Why? Although packaging is not expressly included in clause 5.4.2 (see above Marshall's post) IMO the auditor might request it based on clause 3.5.1.1: "The company shall undertake a documented risk assessment of each raw material or group of raw materials including packaging to... This should take into account the potential for: ...substitution or fraud..."
Hope it helps.
We haven't been audited yet so no experience so far. Anyway we have decided to include packaging in our VA. Why? Although packaging is not expressly included in clause 5.4.2 (see above Marshall's post) IMO the auditor might request it based on clause 3.5.1.1: "The company shall undertake a documented risk assessment of each raw material or group of raw materials including packaging to... This should take into account the potential for: ...substitution or fraud..."
Hope it helps.
Hi Pandu,
You possibly omitted a little more of the context ?
I guess it's ultimately up to BRC.
For example, here's another (consultant) opinion -
The raw material risk assessment must now include substitution or fraud of ingredients (this section covers packaging but substitution or fraud need only cover ingredients), but the vulnerability assessment conducted in section 5.4 can be used to cover this requirement. I’m not really sure why they didn’t include the requirements of 5.4 in this section, it makes it confusing splitting them up. (Clause 3.5.1.1)
vulnerability.pdf 543.99KB 605 downloads
And then there is the difference between "risk" assessment and "vulnerability" assessment.
Marshall
Agree, Charles. It's ultimately up to BRC, and I guess it will be some "volatibility" in audit interpretation for some time. That's why we decided to include packaging in our VA (not to say that packaging is also susceptible to fraud that may eventually pose a health risk).
Also agree with the second opinión ("it makes confusing splitting them up"). In my humble opinión that split (3.5.1.1 and 5.4.2) brings not only confusion but also contradiction since the former refers to raw materials including packaging and the latter to (only) food raw materials.
I ommited some parts of the context to make it shorter. The full text is as follows: "The company shall undertake a documented risk assessment of each raw material or group of raw materials including packaging to identify potential risks to product safety, legality and quality. This should take into account the potential for:
- allergen contamination
- foreign-body risks
- microbiological contamination
- chemical contamination
- substitution or fraud (see clause 5.4.2)
Consideration shall also..."
Hope it's more clear now that nothing is clear in this regard...
Hi Marshall,
I would say that the fact that our raw materials (packaging included) are vulnerable to fraud is definitely one of the risks mentioned in clause 3.5.1.1 (besides allergens, foreign-body, etc.)
Hi Pandu,
Well, afaik, the BRC Guidance is intended to exemplify the scope/details of the BRC's expected response to such issues.
Time will Tell.
Hi All,
A conclusion to the discussion in preceding posts and Title query has appeared in another thread -
http://www.ifsqn.com...g-manufacturer/
(Post 12)(thks AndyDiff)
The source of posted extract is BRC Global Standards Newsletter, November 2015.
Clarification Clause 3.5.1.1.png 17.97KB 13 downloads
Thank you, Charles. Just read it. BRC definitely settles the apparent contradiction between 3.5.1.1 and 5.4.2 in its newsletter of November. I guess it's time to remove the packaging from our vulnerability assessment...
If you've included it, why remove it? You've done the work after all. The question is, did you do the assessment for the purpose of passing BRC or because you want to protect your product? If the latter, then why would you not cover everything, all the risks? Even if all you've done is write a comment in the report to say your judgement is that packaging is not a risk.
I covered it in mine and I just got feedback from the BRC auditor that it was the best TACCP/VACCP assessment they had ever seen (a big thanks by the way to all the people who have posted here on the subject over the last year or so, your knowledge got us through it!)
If you've included it, why remove it? You've done the work after all. The question is, did you do the assessment for the purpose of passing BRC or because you want to protect your product? If the latter, then why would you not cover everything, all the risks? Even if all you've done is write a comment in the report to say your judgement is that packaging is not a risk.
I covered it in mine and I just got feedback from the BRC auditor that it was the best TACCP/VACCP assessment they had ever seen (a big thanks by the way to all the people who have posted here on the subject over the last year or so, your knowledge got us through it!)
Hi Kehlan,
TBH, yr 2nd paragraph implies to me that some BRC auditors in March 2016 (!) were still out-of-touch with the specific requirements of their own Standard. I do wonder which "box" was ticked.
I also find the feedback comment rather strange since TACCP/GFSI is a different topic as compared to GFSI/Vulnerability Assessment. Or perhaps the TACCP reference was with respect to BRC's request for "Food Defence".
It is unfortunate that BRC do not offer a definition for VA in the Glossary to minimise the confusion.
Youre probably right about auditors not knowing the requirements in this area.
As to the feedback comment, I treated the areas of threats and vulnerabilities as one large project. In my mind, the two are interconnected and I don't see how you can look at threats without looking at vulnerabilities as well... they are different but sill closely related. Food Defence, is actually probably, in my opinion, the best name for it. However you look at it though, and there are many different ways, the important thing is to protect both the product and the business.
Youre probably right about auditors not knowing the requirements in this area.
As to the feedback comment, I treated the areas of threats and vulnerabilities as one large project. In my mind, the two are interconnected and I don't see how you can look at threats without looking at vulnerabilities as well... they are different but sill closely related. Food Defence, is actually probably, in my opinion, the best name for it. However you look at it though, and there are many different ways, the important thing is to protect both the product and the business.
Hi Kehlan,
I totally agree that there is an amazing variety of terminological interpretations in this area.
Anyone is of course entitled to define their own terms and methods.
As previously noted, IMO it is unfortunate that VA was omitted from the BRC7 Glossary. Unlike Food Defence. .
BRC's Interpretation Guidance (IG) does define VA and its interpretation therein appears conceptually aligned to that proposed by GFSI. The latter's viewpoint is, i think, somewhat different to presentations such as in PAS96 / Campden. One feature of the IG's approach (and perhaps GFSI also) may be that the term "threat" appears in the introduction to VA but nowhere in its detailed evaluation.
Nonetheless, afaik the IG is not an auditable document so that other approaches are presumably also viable, and acceptable to BRC auditors (some are in fact mentioned in the IG). I can sympathise that this may generate some difficulties for auditors.
I have a question for people who did submit packaging VA:
Did you include secondary packaging as well or just primary or consumer packaging?
Thanks
only primary packaging.
Hi All,
A conclusion to the discussion in preceding posts and Title query has appeared in another thread -
http://www.ifsqn.com...g-manufacturer/
(Post 12)(thks AndyDiff)
The source of posted extract is BRC Global Standards Newsletter, November 2015.
Hi Charles,
I tried to search the newsletter containing the above statement of excluding packaging materials for VA but I can't find it.
Can you please share the whole file/announcement?
Thanks,
Lelou
Hi Charles,
I tried to search the newsletter containing the above statement of excluding packaging materials for VA but I can't find it.
Can you please share the whole file/announcement?
Thanks,
Lelou
BRC7-Vulnerability Assessment.pdf 284.52KB 208 downloads
(4th item down)
Thank you sooooooo much Charles. :thumbup:
The somewhat remarkable statistic as per 29/12/18 is that of the 12 replies recvd since BRC stated VA not required/thread counter reset to zero, 11 stated that VA for Packaging was carried out.
11 people are anti-polls ? :smile: