6 replies to this topic

[GMO]

About to tear my hair out with a BRC auditor. 

 

We have a likely non conformance on 6.1.4 for a small fridge (approx. a few pallets) which stores hard cheese.

 

 

Where variation in processing conditions may occur within equipment critical to the safety or quality of

products, the processing characteristics shall be validated and verifi ed at a frequency based on risk

and performance of equipment (e.g. heat distribution in retorts, ovens and processing vessels;

temperature distribution in freezers and cold stores).

 

Now we have been asked how we validate that the automatic temperature monitoring is representative of the room.  The product held in there is not going to be dangerous if it's 1oC out of spec and the clause (I thought) was more aimed at very sensitive products, ovens where you can have cold spots, that kind of thing.

 

I tried to argue the toss on it and pointed out in the interpretation guideline it says

 

"Temperature distribution studies would not normally be necessary for small chill or cold stores where product is stored only for short periods".  This I would argue is the case with our chiller.  This is a small WIP store, sometimes the ingredient is in there for a few hours, sometimes a couple of days.

 

She pointedly said "I audit to the standard not the interpretation guideline"

 

So what is the interpretation guideline for?  She will raise it as a non conformance.  I will challenge it directly with BRC later (I think) but I wanted a sense check to see if people thought this was a reasonable request?  She was aghast when I said I didn't understand and said "everyone else does it".  The temperature probes we have are in worst case scenario locations (i.e. high up in the room) which she has accepted and product is only stored low down.

 

I just don't understand why this is a non conformance.  I tell you what it right ****s me off the variability of BRC auditors.  I could cry I'm so frustrated. 

[Kehlan]

the only thing I can think of is to argue that it is NOT critical to the safety and quality... and therefore not applicable.  If she says it IS critical, ask her to show you WHERE it says that part of your process is critical. Because if it doesn't its not set in stone.

 

Quite honestly, looks to me like she is searching for something to mark you down for... hopefully that's a good sign, since in my experience auditors don't like giving you a perfect score (on the basis that a perfect score with no non conformances implies you are perfect and can not improve and nobody is so perfect that they cant improve somewhere) - which means if youre doing everything right, the non conformances found will get sillier and sillier.  ~Good luck and hope it doesn't affect your final grade!

[GMO]

We managed to argue enough with her in the end that she didn't raise it but she got REALLY angry when we raised the interpretation guideline.  I suspect she didn't raise it as she knew I'd be appealing directly with BRC.

[QAGB]

About to tear my hair out with a BRC auditor. 

 

We have a likely non conformance on 6.1.4 for a small fridge (approx. a few pallets) which stores hard cheese.

 

 

Where variation in processing conditions may occur within equipment critical to the safety or quality of

products, the processing characteristics shall be validated and verifi ed at a frequency based on risk

and performance of equipment (e.g. heat distribution in retorts, ovens and processing vessels;

temperature distribution in freezers and cold stores).

 

Now we have been asked how we validate that the automatic temperature monitoring is representative of the room.  The product held in there is not going to be dangerous if it's 1oC out of spec and the clause (I thought) was more aimed at very sensitive products, ovens where you can have cold spots, that kind of thing.

 

I tried to argue the toss on it and pointed out in the interpretation guideline it says

 

"Temperature distribution studies would not normally be necessary for small chill or cold stores where product is stored only for short periods".  This I would argue is the case with our chiller.  This is a small WIP store, sometimes the ingredient is in there for a few hours, sometimes a couple of days.

 

She pointedly said "I audit to the standard not the interpretation guideline"

 

So what is the interpretation guideline for?  She will raise it as a non conformance.  I will challenge it directly with BRC later (I think) but I wanted a sense check to see if people thought this was a reasonable request?  She was aghast when I said I didn't understand and said "everyone else does it".  The temperature probes we have are in worst case scenario locations (i.e. high up in the room) which she has accepted and product is only stored low down.

 

I just don't understand why this is a non conformance.  I tell you what it right ****s me off the variability of BRC auditors.  I could cry I'm so frustrated. 

 

We managed to argue enough with her in the end that she didn't raise it but she got REALLY angry when we raised the interpretation guideline.  I suspect she didn't raise it as she knew I'd be appealing directly with BRC.

 

 

Hi GMO,

 

I'm glad to hear she didn't raise that as a non-conformance. I have never heard a BRC auditor state they don't audit to the interpretation guidelines. I understand she is auditing to the standard, but as far as I am concerned, the interpretation guidelines are part of the standard. That downright frightens me because the interpretation guidelines are to help you with the muddier areas of the standard. The standard in itself can be very vague, and I can't even begin to tell you how many times we've used the guidelines for further clarification as to what we need. If auditors aren't going to use the guidelines as part of the audit, there is no need to have the book at all. I doubt BRC would have sided with her audit practices, and I don't know why she would be so angry about a fair part of the standard.

 

I also agree with Kehlan; if your cool room is not critical for your product, there's no real need for all the extra temperature validation studies. We have a couple of cool rooms. We really only use them to help extend shelf life, but they aren't needed for our products. I've been asked for the temperature checks we perform in those rooms; but no validation studies were needed.

 

 

 

QAGB

[Charles.C]

Hi QAGB,

 

Sorry but i disagree with yr opinion as to the status of the Interpretation Guidelines.

 

I anticipate that somewhere in the BRC material (small-print?) there is a disclaimer similar to this one in the SQF Standard -

 

The guidance documents are available to assist the supplier, but are not auditable documents.  Where there is a divergence between the guidance document and the SQF Code, the SQF Code (English) prevails.

 

Similarly this is in the SQF Guidance document -

 

Guidance is intended to support the SQF Code, but does not replace it.  It is not an auditable document, nor is it definitive and applicable in every situation.  Suppliers, consultants, and auditors are required to understand the food safety (and quality, where applicable) risks in a given industry sector and are able to apply the SQF Code to effectively control those risks.

 

"Divergence"  presumably means whatever the SQF Board chooses it to, eg "interpretation".

Seeing as the SQF Guidance (IMO)  does  contain some definite "debatables" and is perhaps not always updated coincident with the Code itself (unlike perhaps for  BRC),  it's not surprising that such a  disclaimer exists.

 

Nonetheless in the present BRC case, even if the disclaimer does exist,  when  the text in the Guidelines appears directly contrary to audited experience there is obviously enhanced potential for leverage in the event of an appeal. Not to mention guarding the jewel in the Crown. I think GMO's analysis of that aspect was probably spot-on.

 

IMEX BRC auditors simply delight in requesting "validations" , perhaps  it's a side-effect of BRC's  addiction to "based on Risk Assessment". (Occasionally the latter can make sense, other times it's just a nuisance / PITA).

 

i'm not  familiar enough with the (product / Guideline / T / t)  to know whether 2 days would qualify as  a "short" period ( based on safety, quality, what ?) . Maybe the auditor didn't know what the text means either.

 

Offhand it sounds more like nit-picking, maybe related to Post 2. Or perhaps related to comments i have seen (somewhere) that there has been a BRC Policy change due a peceived excess of A's (or perhaps A+'s) ?

 

PS - @GMO - It's nice to see yr posts again.

[QAGB]

Hi QAGB,

 

Sorry but i disagree with yr opinion as to the status of the Interpretation Guidelines.

 

I anticipate that somewhere in the BRC material (small-print?) there is a disclaimer similar to this one in the SQF Standard -

 

 

Similarly this is in the SQF Guidance document -

 

 

"Divergence"  presumably means whatever the SQF Board chooses it to, eg "interpretation".

Seeing as the SQF Guidance (IMO)  does  contain some definite "debatables" and is perhaps not always updated coincident with the Code itself (unlike perhaps for  BRC),  it's not surprising that such a  disclaimer exists.

 

Nonetheless in the present BRC case, even if the disclaimer does exist,  when  the text in the Guidelines appears directly contrary to audited experience there is obviously enhanced potential for leverage in the event of an appeal. Not to mention guarding the jewel in the Crown. I think GMO's analysis of that aspect was probably spot-on.

 

IMEX BRC auditors simply delight in requesting "validations" , perhaps  it's a side-effect of BRC's  addiction to "based on Risk Assessment". (Occasionally the latter can make sense, other times it's just a nuisance / PITA).

 

i'm not  familiar enough with the (product / Guideline / T / t)  to know whether 2 days would qualify as  a "short" period ( based on safety, quality, what ?) . Maybe the auditor didn't know what the text means either.

 

Offhand it sounds more like nit-picking, maybe related to Post 2. Or perhaps related to comments i have seen (somewhere) that there has been a BRC Policy change due a peceived excess of A's (or perhaps A+'s) ?

 

PS - @GMO - It's nice to see yr posts again.

 

 

Hi Charles,

 

The front of the interpretation guideline book for issue 7 states "The BRC publishes information and expresses opinions in good faith, but accepts no liability for any error or omission in any such information or opinion, including any information or opinion contained in this publication". This doesn't have as concise a disclaimer as SQF (I don't see any such wording about it not being an auditable document); although, I don't see why there would be a 158 page document to accompany the standard if you cannot use it to argue valid points. I'd think an auditor should at least be open to using the interpretation guidelines as part of the assessment (within reason of course).

 

Well whatever the case may be, I'd still use the interpretation guide for justification, and I'm just glad GMO didn't get the non-conformance.

 

 

QAGB

[ViandGroup]

As a BRC auditor and ATP, the interpretation manual is the worst manual that BRC could have published.  Auditors do not purchase or look at the interpretation manual as the auditor audit to the BRC Standard (just as your auditor stated).  That being said, BRC looks at Food Safety, Food Legality and Food Quality in that order.  I'm am glad you were able to have her understand but in the future look at issues that affect FS, FL and FQ.  Again, the auditor will not accept the interpretation manual as a viable reason or example.