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BRC 5.5.2 Product Liners and bags shall be appropriately coloured

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Merry Chastine

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Posted 06 May 2017 - 01:27 AM

Hello!!!

 

Our internal audit just concluded, one of the non-conformities raised is the plastic material lining of one of our ingredients vacuum salt), it's transparent.  In BRC 5.5.2 the requirement states that "product liners and bags purchased by the company for use in direct contact with ingredients, or work in progress, shall be appropriately coloured and resistant to tearing to prevent accidental contamination".

 

Our supplier cannot provide a coloured packaging, with this we are planning to conduct again a risk assessment.  Other controls in our processing is the installation of sieve/filters in the kettles and conduct of visual inspection

 

I want to hear other suggestions on how to address the above mentioned non-conformity

 

Thank you very much,

Chastine



Charles.C

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Posted 06 May 2017 - 05:17 AM

Hello!!!

 

Our internal audit just concluded, one of the non-conformities raised is the plastic material lining of one of our ingredients vacuum salt), it's transparent.  In BRC 5.5.2 the requirement states that "product liners and bags purchased by the company for use in direct contact with ingredients, or work in progress, shall be appropriately coloured and resistant to tearing to prevent accidental contamination".

 

Our supplier cannot provide a coloured packaging, with this we are planning to conduct again a risk assessment.  Other controls in our processing is the installation of sieve/filters in the kettles and conduct of visual inspection

 

I want to hear other suggestions on how to address the above mentioned non-conformity

 

Thank you very much,

Chastine

 

Hi Chastine,

 

A couple of queries.

 

Does "transparent" = no markings of any kind ? (should be validatably food grade of course).

 

To be an ingredient in a  RTE finished product ?


Kind Regards,

 

Charles.C


Merry Chastine

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Posted 06 May 2017 - 05:21 AM

Hi Charles,

 

Yes no markings of any kind, it's a clear/transparent packaging.  The finished product is canned tuna.

 

Thanks,

Chastine



Charles.C

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Posted 06 May 2017 - 09:38 AM

Hi Charles,

 

Yes no markings of any kind, it's a clear/transparent packaging.  The finished product is canned tuna.

 

Thanks,

Chastine

 

That may have been the "initial" auditor problem. Lack of ingredient identity. My > 99% purity bags NaCl have always been clearly marked/logoed etc

 

BRC's clause reflects a common problem with raw materials/liners.  IMEX (seafood) auditors look for blue liners so as to show any contamination.

 

I guess the only way out is to change supplier or prove yr point (no physical hazard) by risk assessment.


Kind Regards,

 

Charles.C


KTD

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Posted 08 May 2017 - 12:16 PM

Merry -

 

The clause reads:

Product liners and bags purchased by the company for use in direct contact with ingredients, or work in process, shall be appropriately colored and resistant to tearing to prevent accidental contamination.

 

Your question appears to be about packaging of incoming ingredients. The clause does not appear to address packaging of incoming ingredients, just waht you use to contact your product. If that is the case, how is the nonconformance supportable against this specific clause?

 

KTD



beadle

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Posted 16 May 2017 - 03:40 PM

Hi,

 

I think that as you have said you have risk assessed the issue and are happy/ or not happy with the response.

 

From the risk assessment as Charles has mentioned you need to look at what kind of issues you have had with clear plastic (have you had any complaints/ validation of CCPs) if so you have answered the question of the NC so can be closed - or again move supplier.

 

BRC will be happy as long as they can see a risk assessment - to see you have thought about the issue.

 

Regards

 

Chris


Regards

 

Chris




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