5 replies to this topic

[Rosemary4]

Hi all,

We have just had our first BRC audit under v5 and received a minor ncr regarding the corrective actions for identified CCPs in the HACCP risk analysis. The actual statement is 'The corrective actions for the identified CCPs (CCP1 - bolts etc from tooling, CCP2 - paint flakes off machine components) failed to refer to the actual procedures to be followed regarding potentially contaminated product.'

I have rewritten our quality procedures to fit in with the Standard clauses. Product contamination control (4.9) where you would expect this section appears to focus on glass, brittle plastics, ceramics and similar materials control, sharps control, chemical and biological control.

Can anyone point me in the right direction for which clause covers the 2 CCPs please? We address them during the machine set up using the checklist which covers the CCPs but this wasn't sufficient.

[Simon]

Hi Rosemary, I don't think they should be CCP's and should be covered by prerequisite procedures.

By classifying the hazards as CCP's you have elevated them unnecessarily.

 

Regards,

Simon

[Rosemary4]

Thanks for the response Simon. We have always had them as CCPs. As you're in the same line I believe, how do you address them in pre requisite documents?

 

Is the BRC Standard really only concentrating on the contamination issues aforementioned?

[Simon]

On the two mentioned your preventive maintenance program should address the condition of both the buildings, infrastructure, machinery and equipment to prevent contamination and also then you need other operational procedures such as pre-op checks, line clearance, cleaning and engineering safe handover following maintenance etc.

 

Hope this helps.

 

Regards,

Simon

[Sharon (Dewsbury)]

I agree,

They are better to be pre reqs. but the NC reads to me as if you did not reference the control procedure in the HACCP risk assessment table. Is that correct?

Even pre reqs need to be reviewed and risk assessed so they may appear in the HACCP RA in the same way and the procedure which covers acquaintance etc should be referenced in that table .

e.g.

 

hazard                                    control

Flaky paint                              Maintenance procedure QP xyz

[GMO]

I agree with the other commentators that they are very likely to be PRPs.

 

But with respect to CCPs (or even PRP) corrective actions; I think it's useful to think of the past, present and future. 

 

The past is "what product has been impacted?" so if you have missing bolts or a metal detector failure say, you may want to put that product on hold and have some guidelines around what to do with it. 

 

The present is "what do we do now to prevent product becoming contaminated?"  So often it's as simple as "stop the line".

 

The future is considering all of the past and present including root cause analysis to decide how you got to where you are and what you're going to put in place to prevent it going forward. 

 

It seems to me that for your HACCP plan the non conformance related to a lack of clear action on what you'd do with potentially contaminated product but yes, definitely not a CCP.