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Hygiene Policy - Storage & Distribution of ambient products

HygienePolicy Hygiene policy storage distribution ambient

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#1 dani2511

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Posted 01 June 2018 - 01:35 PM

Hi all,

 

I am currently in the process of reviewing our Hygiene Policy. We are currently working towards BRC Global Standard for Storage and Distribution.

 

All of our products are packaged at contract manufacturers and require ambient storage, so there is no physical handling of the food products outside of the primary or secondary packaging.

 

What would be the requirement regarding illness reporting/communicable diseases in this case? Would it be more lenient than the standard 48 hour from last symptom requirement? And smoking (what specifically would the BRC standard be wanting me to state in this section?)? And to what extent are these requirements extended to office only staff?

 

I am struggling with these two points particularly as all of my previous workplaces have been manufacturing plants and not simply warehouse and distribution.

 

I want to avoid being over the top in my approach as unfortunately the management of the company see BRC as a necessary evil, and to only do what is necessary to pass the audit.

 

Thanks all in advance.



#2 FSQA

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Posted 01 June 2018 - 03:37 PM

Dani2511,

 

BRC Issue, clause 8.2.3 states and is pretty clear:

Smoking (where permitted under law), eating and drinking shall only be permitted in designated areas and shall not be permitted in storage and product-handling areas.

 

Clause 8.2.1 states : reporting of Sickness, but does not indicate the time. IMO, i would advise to stick to the 48 hour rule.

 

So dont worry, you are not going over board....



#3 Gerard H.

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Posted 04 June 2018 - 02:21 PM

Dear Dani,

 

Why does the company management have such a policy, "to only do what is necessary to pass the audit."?

 

The risk of this kind of practice is having high customer complaint rates, leaving customers or even the loss of the certificate.

 

Kind regards,

 

Gerard Heerkens



#4 dani2511

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Posted 04 June 2018 - 02:30 PM

Hi Gerard,

 

The company has been operating without a quality management system to speak of since its inception. It is the pressures from the retailers that has pushed them towards BRC accreditation, but they do not want it to increase staff workload unnecessarily. Unfortunately there hasn't been anyone in a quality position in the past, and I have been brought in to 'tick the BRC box'. They are committed to that point and nothing beyond that, unfortunately. It isn't the first company I have worked in for which this has been in case, and I doubt it will be the last. I understand the implications, but I am a one man band and can only do what I can.

 

 

 

Dear Dani,

 

Why does the company management have such a policy, "to only do what is necessary to pass the audit."?

 

The risk of this kind of practice is having high customer complaint rates, leaving customers or even the loss of the certificate.

 

Kind regards,

 

Gerard Heerkens



#5 dani2511

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Posted 04 June 2018 - 02:38 PM

Hi FSQA,

 

Thank you for your reply. I know what the standard says, but in terms of its interpretation I am a little stuck. We have one designated area for smokers which is in the yard in which goods are received. We are unfortunately limited for space here, so I was more trying to find out if dedicated smoking areas need to be away from outdoor yard areas, or would this be ok given that we are space limited?

 

The 48 hour rule is what I would like to go for and what I would default to, but I do expect to be confronted by the management as our goods are all sealed. I am more trying to find out if there is an absolute recommendation for the time frame for the Storage and Distribution standard (as, as you so rightly said, it doesn't actually state it in the standard), from people's own experience. Unfortunately it is a challenge working with management who have never worked with a QMS before, let alone BRC.

 

Thanks.

D

 

Dani2511,

 

BRC Issue, clause 8.2.3 states and is pretty clear:

Smoking (where permitted under law), eating and drinking shall only be permitted in designated areas and shall not be permitted in storage and product-handling areas.

 

Clause 8.2.1 states : reporting of Sickness, but does not indicate the time. IMO, i would advise to stick to the 48 hour rule.

 

So dont worry, you are not going over board....



#6 Gerard H.

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Posted 04 June 2018 - 02:43 PM

Hi Dani,

 

Thank you for the explanation! I wish you all the good luck, and of course, I hope that you succeed to manage it.

 

It's good to build your quality system very closely around the BRC norm.

 

Kind regards,

 

Gerard



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#7 FSQA

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Posted 04 June 2018 - 08:30 PM

Dani,

 

We have one designated area for smokers which is in the yard in which goods are received. We are unfortunately limited for space here, so I was more trying to find out if dedicated smoking areas need to be away from outdoor yard areas, or would this be ok given that we are space limited?

It depends on the type of product you are handling and the access of smoke to the area where you are storing the product (organoleptic issues). This can vary of various product packaging materials (bags vs cans).

Besides cGMPs (hand washing and other issues) and other local regulatory requirements, IMO as long as you can show that smoke does not have access to the product holding areas, you should be fine.

 

The 48 hour rule is what I would like to go for and what I would default to, but I do expect to be confronted by the management as our goods are all sealed. I am more trying to find out if there is an absolute recommendation for the time frame for the Storage and Distribution standard (as, as you so rightly said, it doesn't actually state it in the standard), from people's own experience. 

I dont have any experience of the time frame for Illness reporting per BRC Storage & Distribution standard, however, you can advise your management about following cGMPs. I am not sure about regulations in your region however since FSMA , Holding of Human Food (Storage and Distribution/ Supply Chain/ Sanitary Transport) is given much more emphasis in US, as compared to the past. I am sure we have more experienced people here to comment/help on it further.

 

Unfortunately it is a challenge working with management who have never worked with a QMS before, let alone BRC.

This is a big downside, but on the contrary it can be a Big plus for you... as you are the only technical employee for QMS matters there now... I know it can be painful initially, but in the long run it helps you to learn lots.....

I would advise you to enlighten your management about various recalls, implications of avoiding Food Safety concerns deliberately and related stuff.....



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#8 Gerard H.

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Posted 05 June 2018 - 07:27 AM

Dear Dani,

 

You can consider the BRC norm as interpretation document.

 

Kind regards,

 

Gerard H.



#9 dazaaa03

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Posted 07 June 2018 - 08:12 AM

Hi Dani

 

i am / was in same position as you. i am a one man band who was given the task of putting BRC into my company. shift managers and warehouse was not interested in this one bit but after 3 months of me pilling them with non-conformance the corner has turned.

 

we are a storage and distribution company and all our products are boxed and sealed. our smoking area is the other side of the warehouse from the canteen / changing rooms. no food or drink is allowed in the warehouse and smoking is only permitted in the smoking area. we just passed our first BRC with a grade B and she only asked where our smoking area was and looked out our policy on smoking on site, to which she was happy with. 

 

i put in our return to work procedure any s /d its 48 hours which the employee is allowed to return to work which also she was more than happy with.

 

if you need any documents give me a shout 

 

thanks 

 

Darren 



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#10 dani2511

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Posted 08 June 2018 - 09:32 AM

Thank you everyone for your responses - they have been very helpful. My previous experience has been in Pharma GMP/GDP settings, so I have a tendency to err on the stricter side, but I do have to be cautious as I want people to adopt the procedures and processes (I have never compiled a QMS from scratch), so pragmatism is what I am aiming for!

 

I have also taken on TACCP and Business Continuity (these haven't been performed) so there is a lot of learning going on and I do feel stretched sometimes beyond my capabilities.

 

All for the learning, though!



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