4.9.2 Knife Control
This came up in our BRC audit as well as a corporate internal audit based on BRC about the control of utensils and cutting knives.
Both standards say "sharp metal implements" and the internal goes farther and says "small metal utensils".
However, both auditors insist that it means ALL utensils in the production room need to be signed in and out.
This for us would include slicing blades and safety cutting knives (for pallet wrap) which is easy enough (we have a program in place), but the sheer amount of other utensils is to put it plainly, is not feasible to be tracked that way. I'm talking upwards of a 100 tools daily (cake decorating).
Would a risk assessment showing the likelihood of any of these items ending up in the product and not being detected by the metal detector that we have be enough to show the auditors that we do have controls in place for those things?
Or anyone with similar fights about this?
What about making "kits" that would contain a certain amount of tools for the type of project. Something like a toolbox where you have a hammer, screwdriver, wrench, etc. At the end of the day the kit would be checked in and verified that all items were returned.
Hi Urban Explorer,
I would have asked the auditor to show me the appropriate clause.
4.9.2 METAL CONTROL
BRC FOOD CLAUSE REQUIREMENTS
4.9.2.1 There shall be a documented policy for the control of the use of sharp metal implements including knives, cutting blades on equipment, needles and wires. This shall include a record of inspection for damage and the investigation of any lost items. Snap-of-blade knives shall not be used.
BRC stipulates these items because they are high risk and from your post you have this covered.
You are thinking along the right lines in carrying out a risk assessment for the other items. I would suggest that they are on something like a weekly check/inspection rather then signed in/out and checked every time if the risk is low. You should also include in your procedure that any issues that put product at risk are to be immediately reported.
Kind regards,
Tony
Hi Urban Explorer,
I would have asked the auditor to show me the appropriate clause.
4.9.2 METAL CONTROL
BRC FOOD CLAUSE REQUIREMENTS
4.9.2.1 There shall be a documented policy for the control of the use of sharp metal implements including knives, cutting blades on equipment, needles and wires. This shall include a record of inspection for damage and the investigation of any lost items. Snap-of-blade knives shall not be used.
BRC stipulates these items because they are high risk and from your post you have this covered.
You are thinking along the right lines in carrying out a risk assessment for the other items. I would suggest that they are on something like a weekly check/inspection rather then signed in/out and checked every time if the risk is low. You should also include in your procedure that any issues that put product at risk are to be immediately reported.
Kind regards,
Tony
Hi Tony-C,
I absolutely agree with your post. We're BRC Certified, and I've never had an auditor ask about utensil reconciliation other than knives and sharps. I've never even had 2nd party auditors ask about regular utensil reconciliation.
We keep a master list of blades and we inspect them, and we also do sharps inspections monthly to make sure any glass or brittle plastics haven't been broken around the plant.
Maintenance is responsible for doing their tool reconciliation similar to what nd01ken describes above, and auditors will ask about that.
QAGB
Good points made by all. As an additional compliance tool you can run all of your tools and parts through your metal detector once annually to verify that they would set the detector off. your preoperations inspections should catch any damage to those parts that might have shed pieces of metal so you are covered there. Sounds like someone is writing in an interpretation of the requirement that is completely off base.