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Exclusions from Scope

Started by , Apr 13 2017 05:54 PM
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5 Replies

Hi all,

 

I have been asked a question regarding exclusions from scope in BRC V7. Is there a percentage of production above which you cannot exclude? In the manual it states that:

 

 

The fulfilment of the certification criteria relies on clear commitment from the site management to adopt the best practice principles outlined within the Standard and to the development of a food safety culture within the business. It follows therefore that the exclusion of products from the scope of certification shall only be permitted by exception.
The BRC logo can only be used by sites that have no exclusions.
The exclusion of products produced at a site will only be acceptable where:
•the excluded products can be clearly differentiated from products within scope
AND
•the products are produced in a physically segregated area of the factory.
Where exclusions are requested these shall be agreed with the certification body in advance of the audit. Exclusions shall be clearly stated on the audit report and certificate and the justification recorded on the audit report.
The certification of products must include audit of the entire process from raw material to end-product dispatch. It is not possible to exclude either parts of the process undertaken at the site or parts of the Standard. Where exclusions are accepted, the auditor(s) shall assess any hazards presented by excluded areas or products (e.g. the introduction of allergens or foreign-body risks) and non-conformities may be raised relating to the excluded area where this poses a risk to the products within the audit scope.
 
I see no reference to a percentage of production but the question has been asked in previous years at audits. Any enlightenment here?
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How to document exclusions against high care and high risk requirements? What Exclusions are Allowed in ISO 22000?
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I'm not aware of any percentage.  From memory the main concern for BRC was if the product was produced in the same area as "in scope" products then you couldn't reasonably justify exclusion. 

Version six used to have other qualifiers, including the excluded product being "a minority" of the production. Removed from version 7, as it became challenging to define on site.

 

The current rules are simple, segregated and easily differentiated.

 

That being said, exclusions can be a challenge, for the site and auditor. Is there a specific reason to exclude some portion of what you do from being part of your BRC program?

 

John

From the discussions at the last version change to v7, it was clear from the discussion that exclusions should be genuine and very, very rare.  I can't honestly think of a justifiable reason why a foodstuff should ever be excluded.  Either you're going for BRC or you're not.  Anyone got any examples?

Our auditor said we had to exclude products we buy in and repack, as the BRC Standard is a manufacturing standard and doesn't cover these products.

A few years back we had another auditor who excluded them and the next year the auditor included them. 

 

seems to be a bit of difference of opinion!

Our auditor said we had to exclude products we buy in and repack, as the BRC Standard is a manufacturing standard and doesn't cover these products.

A few years back we had another auditor who excluded them and the next year the auditor included them. 

 

seems to be a bit of difference of opinion!

 

OT (?)

                 

Hi blue,

 

An Interesting interpretation of "manufacturing". I doubt that it's defendable unless perhaps merely an outer labelling activity of, say, cartons of canned goods.  Even so, still offers an opportunity for a BRC screw-up. :smile:

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How to document exclusions against high care and high risk requirements? What Exclusions are Allowed in ISO 22000?
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