2.2 Hazard and Risk Analysis

Could you give any example about the title below?

2.2.4 In-line testing or measuring equipment must be included on the flow diagram.  

I believe that is a reference to scales/sifters/magnets/metal detectors being included on the flow diagram as a step. 

Thermometers.  Weight checks (balances).  pH control. Timers (if processing time is critical).  Some of the items mentioned above are not testing or measuring activities.

In blown film you are talking about in-line bubble gauging and measuring. The temperature gauges on the extrusion lines don't constitute in-line testing and measuring equipment as the don't measure the product directly, and don't necessarily have a fixed setting for a particular product, the temperature being adjusted to fit the prevailing environmental conditions.

You have to verify that your product is measured and gauged correctly.

In your flow chart, in what step do you verify that your blow up ratio meets your gauge?

i.e. My packers inspect the product for size and gauge. 

My verification method is micrometer and a ruler.

I have certified NIST block for the micrometer and a NIST ruler to verify that my equipment is meeting a standard. 

The OP appears to be stated slightly out of context -

2.2.4

A flow diagram shall be prepared for each product, product group or process. This shall set out each
process step from the receipt of raw materials to dispatch to the customer. As a guide this shall include,
as relevant:
•  receipt and approval of artwork
•  receipt and preparation of raw materials such as additives, inks and adhesives
•  each manufacturing process step
•  in-line testing or measuring equipment
•  the use of rework and post-consumer recycled materials
•  any subcontracted processes
•  customer returns.
The accuracy of the process flow shall be validated by the hazard and risk analysis team.

 

Typical BRC nonsense semantics, how can a "guide"  be linked with a "shall" ?

In Post 5, I'm not too sure how you have a ruler "in-line" ?

It would perhaps be easier to comment if the OP posts his Product/Process flowchart/SCCPs/QCCPs/LCCPs ?.

BRC packaging  seems to have re-invented Codex Hazard analysis  - S/Q/L indeed !

Before dealing with this clause, you need also to read 5.6.2 which states that

"Hazard and Risk Analysis principles shall be used to determine the need for in-line product testing equipment to ensure product safety, quality and legality"

If, having done this, there is no need, then it obviously doesn't need to be in the flow diagram.

You will of course need to document your thoughts and justifications as this will be evaluated by the auditor. I tend to put things like this in a section of the Hazard Analysis folder called Supplementary Analyses which I keep for getting round some of the other BRC clauses

You don't say which sector you are in but other examples of in-line equipment are:

Camera systems on printed closures (eg metal jam jar lids) or printed cans

Flow meters/gravimetric monitoring of mixing ratios of multi component products such as catalyst glue systems for laminating films

Bar code readers for carton glue lines 

Missing label detectors for reels of self adhesive labels 

Hi Foodworker,

Nice to hear from you.

I suspect you are stating that for para. 2.2.4 / “in-line testing or measuring equipment”,  the “as relevant”  is equatable to para. 5.6.2 (somehow).

IMHO these semantic intricacies simply degrade the Standard’s usefulness  from a Safety  POV.  Convenient  for “due diligence” though.

Keep in mind also that BRC is strictly concerned with food safety.  If you have an in-line measuring system for gauge, does that truly affect food safety?  I cannot see a way that sending out film at an incorrect gauge of thickness could affect food safety in any way.

Keep in mind also that BRC is strictly concerned with food safety.  If you have an in-line measuring system for gauge, does that truly affect food safety?  I cannot see a way that sending out film at an incorrect gauge of thickness could affect food safety in any way.

Nwells1024,

BRC is about Safety, Quality and Legality. 

You are affecting the Quality and the Customer Requirements of the product.

Hi DN_QAMGR,

I agree but, as per their Title,  BRC do have a highly customised interpretation of "Safety", ie 

"The Global Standard for Food Safety" has been developed to specify the food safety, quality and operational criteria required to be in place within a food manufacturing organisation to fulfil obligations with regard to legal compliance and protection of the consumer.

 ( = due diligence perhaps)