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Lelouch_rayne

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Posted 28 November 2016 - 04:29 AM

Hi guys,

 

 

I'm trying to make a risk assessment on protective clothing. In order to address the BRC version 7 requirement on clause 7.4 Protective Clothing: "The company is required to determine the procedures for application and use of protective clothing, based on a risk assessment".

 

I attached a template below, Is this already enough to satisfy the above requirement? Any suggestion guys?

 

 

 

Thanks.

Attached Files



Charles.C

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Posted 28 November 2016 - 07:53 AM

Hi guys,

 

 

I'm trying to make a risk assessment on protective clothing. In order to address the BRC version 7 requirement on clause 7.4 Protective Clothing: "The company is required to determine the procedures for application and use of protective clothing, based on a risk assessment".

 

I attached a template below, Is this already enough to satisfy the above requirement? Any suggestion guys?

 

 

 

Thanks.

 

Hi LLR,

 

I cannot see any direct mention of risk assessment in sec. 7.4 of BRC7 Food.

 

Pls clarify the source of yr quote.

 

7.4 PROTECTIVE CLOTHING: EMPLOYEES OR VISITORS TO PRODUCTION AREAS
Suitable site-issued protective clothing shall be worn by employees, contractors or visitors working in or entering production areas

.


Kind Regards,

 

Charles.C


Lelouch_rayne

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Posted 28 November 2016 - 08:35 AM

Hi Charles,

 

 

I've got it from their interpretation guideline. The standard did not directly mentioned it but upon reading the guideline, it mentioned to have a risk assessment which shall consider foreign body, microbiological and allergen risk as appropriate.



Charles.C

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Posted 28 November 2016 - 09:28 AM

Hi Charles,

 

 

I've got it from their interpretation guideline. The standard did not directly mentioned it but upon reading the guideline, it mentioned to have a risk assessment which shall consider foreign body, microbiological and allergen risk as appropriate.

 

Hi LLR,

 

The IG is not an auditable document.

 

It may depend on the context (eg food for NASA) but IMO BRC simply cannot resist pushing RAs down everybody's throat.

 

But it's yr choice of course. :smile:


Kind Regards,

 

Charles.C


redfox

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Posted 28 November 2016 - 10:38 AM

Hello rayne,

 

In BRC books there is risk assessment guide. You can copy it. Make it simple. It will work.

 

regards,

redfox



Charles.C

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Posted 28 November 2016 - 12:45 PM

Hi LLR,

 

As i understand, the quotation in yr OP is actually an IG for clause  7.4.1  ?

 

If so, it appears to me that the requirements of Clause 7.4.1 are literally spelled out, eg via Risk Zones, etc, in the clause itself. So I'm really not too sure what the suggested RA is for ?

 

Further aspects such as that the clothing must be suitable to prevent product "contamination" are also covered in subsequent clauses, eg 7.4.2.

 

Perhaps the RA is intended to rank different types of available "Protective" clothing with respect to specific perceived Contamination Risks, eg sleeved Jackets will presumably have a lower risk of upper sweat contamination as compared to T-shirts although risks to Personnel Heath (COSHA) may also require to be  factored in for, say, a bakery..?


Kind Regards,

 

Charles.C


Sheilag

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Posted 28 November 2016 - 04:28 PM

Hello rayne,

 

In BRC books there is risk assessment guide. You can copy it. Make it simple. It will work.

 

regards,

redfox

Would you elaborate on this in the statement?  What BRC books do you refer?



QAGB

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Posted 28 November 2016 - 05:41 PM

Hi LLR,

 

The IG is not an auditable document.

 

It may depend on the context (eg food for NASA) but IMO BRC simply cannot resist pushing RAs down everybody's throat.

 

But it's yr choice of course. :smile:

 

 

Yep. It's all about risk assessments with BRC. Even though as you stated the Interpretation Guidelines are not auditable, most BRC auditors will still ask for risk assessments for just about everything. It's usually better to play it safe especially if the auditor questions PPE specifically.

 

To Lelouch_Rayne,

 

You have a good document. I would also suggest adding maintenance, contractors, and visitors to the form. For example, can your maintenance people, contractors, and visitors pass through from zone to zone without changing uniforms or clothes? Should they be required to wear PPE when in higher risk areas? Do you provide special PPE for visitors that are improperly dressed?

 

QAGB



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Charles.C

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Posted 28 November 2016 - 06:59 PM

Hi QAGB,

 

Nice to hear from you.

 

You are clearly not an exponent of the "Show me where the Standard asks for that " approach pioneered in the ISO9000 documentation forums.. :smile:

 

If BRC were more selective with respect to explicitly asking for Risk Assessments/Risk-Based XYZ, I would perhaps be more inclined to respond to implicit suggestions.

 

From what i have seen, the IGs do contain a lot of useful recommendations but they also often appear designed to extract the absolute maximum of detail over every single  requirement. I believe this is motivated by the (UK) parallel objectives concerning Due Diligence.


Kind Regards,

 

Charles.C


QAGB

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Posted 28 November 2016 - 07:29 PM

Hi QAGB,

 

Nice to hear from you.

 

You are clearly not an exponent of the "Show me where the Standard asks for that " approach pioneered in the ISO9000 documentation forums.. :smile:

 

If BRC were more selective with respect to explicitly asking for Risk Assessments/Risk-Based XYZ, I would perhaps be more inclined to respond to implicit suggestions.

 

From what i have seen, the IGs do contain a lot of useful recommendations but they also often appear designed to extract the absolute maximum of detail over every single  requirement. I believe this is motivated by the (UK) parallel objectives concerning Due Diligence.

 

 

Hi Charles,

 

It's been a long while...I've been swamped with work (can't really complain about that).

 

I used to be one of the "show me folks", until I had to carry on massive debates about why we do this, and why we do that (gets old after a while). Usually handing a risk assessment over to an auditor will give them what they need; since the risk assessment already explains why we do what we do.

 

I've struggled with drawing the line between the BRC Standard and the Interpretation Guidelines (IGs), since it seems our auditors are inclined to ask questions that also relate to the IGs rather than just the standard itself. I also don't see the purpose of even having the IGs if we can't be audited to them (you know we've talked about this before  ;) ).

 

So in this instance -- hypothetically speaking, perhaps the auditor asks why their maintenance personnel wears the same clothes between zones. Instead of having to offer up all these explanations, the OP can just state they have completed a full risk assessment for PPE and determined that the risk is low (and then hand over the whole document for the auditor's review). Of course an auditor may ask more questions, but if the RA is detailed enough, most questions should be answered.

 

QAGB



Charles.C

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Posted 28 November 2016 - 08:54 PM

Hi QAGB,

 

Yes i do agree that combative audits can be a strain after a while. Especially when you know the auditor is right. ;)

 

Just for illustration, i hv attached one Consultant's "model' interpretation/responses to the requirements of clause 7.4.1.

The methodology employed is fairly self-evident. No doubt a variety of alternative approaches would be equally acceptable.

 

Attached File  clause 7.4.1.pdf   26.33KB   434 downloads

 

PS - I can recall one member who experienced that the Auditor refused to accept a recommendation included in the IG but not in the Standard !

 

PPS - The use of RA to handle potential "exceptions" in yr previous post is somewhat analogous to the attachment's RA.  On the other hand, an inordinate number of "RA justified" exceptions would probably undermine the "Rule" from an auditor's POV.


Kind Regards,

 

Charles.C


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redfox

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Posted 29 November 2016 - 02:39 AM

Hello Sheilag,

 

It is found in BRC6 Interpretation Guideline Appendix3;page 114.

 

 

regards,

redfox






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