10 replies to this topic

[carolinedougan]

Hello
I am new to this forum and am just wanting a little advice. We are a small frozen food packer in the UK that is working towards gaining BRC accreditation.

I am wondering how in depth the glass/plastic audits need to be. I think we are going over board by auditing everything within the open product area on a daily basis. This includes air gauges on the side of machines, calculators etc. I think instead we should only be checking items that are a direct risk i.e anything directly above the line. Everything else should be on a monthly basis. Please correct me if I am wrong.

Anyway my main question is this - do we need to go so far as checking items in my office which is out of the open product area and then a couple of metres down a corridor. In this area PPE is not worn however it is obviously required in the packing hall which should prevent personal clothing from contaminating the product.

Many thanks in advance.

[Charles.C]

Hi Caroline,

 

Welcome to the World of FS Standards ! And to this Forum !

 

You omitted the nature of yr business which can be risk-relevant (eg RTE ) but regardless  glass/brittle plastic hazards are definitely not regarded as a small thing by BRC. Or other GFSI based FS Standards.

 

You can gauge some idea of BRC’s interest by the scope of section 4.9.3  in their FS Standard. BRC are also particularly “famous”  for their demand for  “risk-based (RB)” procedures, eg clause 4.3.9.2. Yr queries need to be addressed / justified from this POV as per yr detailed flow layout /process. The initial frequency of inspection is typically selected as  over-conservative and then adjusted  based on results (SOPs for making such ajustments exist on this Forum as well as user-friendly approaches to the Risk aspect)  . BRC downloadable guidelines to the Standard's clauses also exist albeit not for free.

 

These 3 threads may give some idea of  BRC expectations/audit experiences. There are many others if you care to scan/search the BRC and other FS Standard's sub-forums.

 

http://www.ifsqn.com...es-from-audits/

 

http://www.ifsqn.com...lass-inventory/

 

http://www.ifsqn.com...astic-register/

[Tony-C]

Hi Caroline,

 

 

 

I think this is quite well explained in the GLOBAL STANDARD FOOD SAFETY ISSUE 7 INTERPRETATION GUIDELINE:

 

4.9.3.2 Interpretation Documented handling procedures

Procedures for handling glass and similar materials (other than packaging which is covered in 4.9.4) need to be documented to ensure that the risks of product contamination are managed.

The documentation must include:

• A list or register of items, detailing their location, number, type and condition. When creating the list, it is important to be realistic; the objective is to remove brittle items where possible and create a list of items for inspection which present a real risk of breakage and contamination of products (i.e. those that are in open product areas or where risk assessment shows there is a genuine risk to product). (The list could also detail the frequency with which the items must be checked.)

• Recorded, routine inspections to verify the condition of these items. 

Inspections must be carried out at a specified frequency based on risk assessment; some areas may be checked more frequently than others due to their potential to form a foreign-body hazard in the product. (For example, a factory identifies part of the production line which has plastic laminated line covers that may chip or break. The condition of this section of the line is specifically checked on a daily basis prior to production, because it is above open food and any breakage or damage is likely to result in a foreign-body issue. 

The same factory has a brittle plastic dial cover on a control panel on the exterior of a piece of equipment not close to open product. This is checked only monthly, as a break and subsequent foreign-body issue is unlikely.) A record of the inspection must be maintained even when there is no change in the condition of the inspected items.

• The systems that allow cleaning or replacement in such a manner as to minimise potential risk to products (e.g. replacing bulbs in fly-killing devices).

 

Kind regards,

 

Tony

[redfox]

Hello Caroline,

 

Glass monitor must be done daily open product area or enclosed product area. Risk assessment must also be presented to auditors during audit. 

 

regards,

redfox

[Big Wally]

Hello Caroline,

 

We are SQF but the guidelines are similar. We do a daily check on glass items located on production machines. We have a rather large glass register of all glass, ceramic or brittle plastic item located on the manufacturing floor, including shipping and receiving. Finally we do a monthly check on all glass, ceramic or brittle plastic items. Perhaps this is overkill but thus far has served us well.

 

Best of luck!

 

Big Wally

[carolinedougan]

Hello

 

Sorry for the delayed response to you all - rather knee deep in BRC at the moment.

 

Thank you for your input. I think as mentioned above as long as all of my decisions are based on a documented risk assessment I should be okay. I guess I just wanted assurance that we only need to audit glass/plastic on the machines on a daily basis and everything else can be on a monthly basis, which as per Tony's post this is what BRC say. 

 

I just seem to second guess everything I am doing which means everything takes twice as long and I go around in circles.

 

Thank you again.

[Charles.C]

Hi Caroline,

 

The frequencies are intended to be risk-based. low risk = relatively infrequent, etc There is no exact standard.

 

Also remember that the BRC Guidelines are not auditable. They are intended to act as an assistance (Guideline) to yr decision-making process, not a specific requirement. It is probably "safe" to assume that the Guidelines offer a conservative response to the clauses in the Standard. For example, IMO, depending on the situation, it could be perfectly acceptable to do windows weekly.

[Tony-C]

Hi Caroline,

 

Also remember that the BRC Guidelines are not auditable. They are intended to act as an assistance (Guideline) to yr decision-making process, not a specific requirement. It is probably "safe" to assume that the Guidelines offer a conservative response to the clauses in the Standard. For example, IMO, depending on the situation, it could be perfectly acceptable to do windows weekly.

 

If I received a non conformance from an auditor which contradicted the BRC Guidelines then I would almost certainly appeal to the certification body. The Guideline 'helps in the understanding of each requirement of the Standard and identifies methods of compliance. Examples are given to explain the type of documents, procedures and level of detail that would be required by a certification auditor.'

 

Kind regards,

 

Tony

[* Steve]

Hi,

 

As long as the auditor can see that you have risk assessed it properly it should be fine.

 

As a guidance: any glass items checked weekly. Any brittle materials above open product checked weekly. Items away from open product and below knee height checked monthly. 

[Tony-C]

Hi,

 

As long as the auditor can see that you have risk assessed it properly it should be fine.

 

As a guidance: any glass items checked weekly. Any brittle materials above open product checked weekly. Items away from open product and below knee height checked monthly. 

 

You are correct Steve in that a risk assessment is required but your guidance is not what BRC would expect to see.

 

For example a week goes by and you find the brittle material above open product is broken. What do you do then? You should be recalling a weeks production.

 

See post 3 regarding BRC guidance:

For example, a factory identifies part of the production line which has plastic laminated line covers that may chip or break. The condition of this section of the line is specifically checked on a daily basis prior to production, because it is above open food and any breakage or damage is likely to result in a foreign-body issue.

 

I prefer to see any critical items like this replaced or checked daily before the start and after the production run.

 

Kind regards,

 

Tony

[Charles.C]

Hi Tony,

 

Just noticed Post 8.

 

Based on the years of Posts on this Forum i would suggest there is sufficient accumulated "evidence" that BRC might consider reviewing the text as quoted.

 

Specifically "would"  should >>>> "could". ('might" seemed a bit too blunt).