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Fishlady

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Posted 26 July 2018 - 09:48 PM

I am helping a small processing facility who was unsuccessful in their challenge to a BRC audit finding regarding positive air flow in a high risk environment, despite a thoroughly documented risk assessment noting physical barriers, air sampling data, and other measures put in place to prevent cross-contamination with the production in the adjacent raw production area.  Because the facility lost the appeal, their certificate has been withdrawn.

 

There are other facilities nearby who have received AA BRC ratings, even though they produce the same product with no physical barriers between raw and cooked product processing areas (never mind positive air flow).  It is likely that they were audited by a different auditor and probably by a different Certification Body.

 

My client is planning to challenge the Certification Body's determination by taking it to the BRC Compliance division.  Has anyone tried doing this?  If so, could you offer advice?

 

Thanks 



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Dr Vu

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Posted 27 July 2018 - 12:41 AM

To better advise you...What's the reason they specified for the rejection or loss of appeal?

 

Ps:bringing up others  who may/may not have controls may not help your process


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Charles.C

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Posted 27 July 2018 - 01:28 AM

I am helping a small processing facility who was unsuccessful in their challenge to a BRC audit finding regarding positive air flow in a high risk environment, despite a thoroughly documented risk assessment noting physical barriers, air sampling data, and other measures put in place to prevent cross-contamination with the production in the adjacent raw production area.  Because the facility lost the appeal, their certificate has been withdrawn.

 

There are other facilities nearby who have received AA BRC ratings, even though they produce the same product with no physical barriers between raw and cooked product processing areas (never mind positive air flow).  It is likely that they were audited by a different auditor and probably by a different Certification Body.

 

My client is planning to challenge the Certification Body's determination by taking it to the BRC Compliance division.  Has anyone tried doing this?  If so, could you offer advice?

 

Thanks 

 

Hi fishlady,

 

I daresay you are already well-aware of following (BRC6 Guideline) quote but JFI - 
 

 

3.4 Ventilation for High Risk Areas (clause 4.4.13)
High risk areas shall be supplied with sufficient changes of filtered air, the aim being to ensure air introduced does not contain micro-organisms of concern and not be the source of additional contamination (for example by the formation of airborne water droplets)

A risk assessment shall be completed which considers the following:

■   source of air (the air inlet needs to be located to minimise intake of contaminated air, e.g. located, as a minimum, upwind of potential contaminants such as dust and
chemical vapours)
■   frequency of air changes
■   specification of filter used – there is no absolute standard for the filters however, the grade required will depend on the source of the air and the time of exposure of high risk products/ingredients
■   frequency of replacement of filters.
■   the need to maintain positive pressure compared to adjacent areas particularly where there is an interface with low risk areas.

The effectiveness of the filter and system employed should be checked by the use of periodic sampling of air close to the outlet of the air ducts for microbiological quality.

 


Kind Regards,

 

Charles.C


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Fishlady

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Posted 27 July 2018 - 03:31 AM

Hi fishlady,

 

I daresay you are already well-aware of following (BRC6 Guideline) quote but JFI - 
 

Hi, Charles

 

Yes, but we thought that we had a good risk assessment to work around it. 

 

It seems, though, that the main problem here was poor communication.  We did not realize that the various people within the CB were not communicating with each other regarding this appeal, so it apparently fell through the cracks.  And because the process stretched beyond the allowed 28 days, the CB is now denying the certification- even though we had made numerous attempts to resolve it.  The facility is now getting quotes from HVAC contractors, but this is going to be very expensive and if others who are producing the same product are not required to do it, the facility feels that it puts them at a financial disadvantage. 



Charles.C

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Posted 27 July 2018 - 04:57 AM

Hi, Charles

 

Yes, but we thought that we had a good risk assessment to work around it. 

 

It seems, though, that the main problem here was poor communication.  We did not realize that the various people within the CB were not communicating with each other regarding this appeal, so it apparently fell through the cracks.  And because the process stretched beyond the allowed 28 days, the CB is now denying the certification- even though we had made numerous attempts to resolve it.  The facility is now getting quotes from HVAC contractors, but this is going to be very expensive and if others who are producing the same product are not required to do it, the facility feels that it puts them at a financial disadvantage. 

 

Hi Fishlady,

 

There are certainly examples of BRC flexibility on the forum, eg (2012) -

http://www.ifsqn.com...e-air-pressure/

 

However the current scenario seems to have elevated the requirement more to a routine necessity, eg (2016) -

http://www.ifsqn.com...high-risk-area/

 

If yr surrounding observations are correct, it may have triggered an internal discusson so that a tightening up has occurred and the facility you describe is an unlucky beneficiary.

 

It might be worth using any leverage accrueing from the "delay" you describe to seek a "stay of judgement".

 

I previously had an analogous but reverse experience over MDs. Everyone else had them for a similar process so a defensive risk assessment (2016 ) was sniffed at.  Luckily a glut of 2nd-hand MDs shortly occurred.


Kind Regards,

 

Charles.C


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pHruit

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Posted 27 July 2018 - 08:58 AM

Hi Fishlady,
I have experienced a problem with a delay caused by the CB affecting our certification status. Because the delay was with the CB and we could demonstrate that we'd taken all reasonable measures to avoid it, we insisted that they applied to BRC for special dispensation in the case, and whilst they were reticent at first we did convince them this was necessary and BRC did grant a concession.

Unfortunately certain CBs seem to be increasingly disorganised and we've had very similar experiences of poor communication creating various problems. Ideally you want to get some contact details for a relatively senior person at the CB and appeal to them with the facts of the case, and convince them to pick up with BRC regarding a special extension to the 28-day limit. If they won't assist then if nothing else this constitutes a further part of the evidence you're presenting to BRC as part of your case.

For the requirement itself, as Charles observes this could simply be a late realisation that the intent of the standard (which alas isn't always clear from the standard itself...) hasn't been followed, and the other facilities will have the same issue identified on their next audits.



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redfox

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Posted 28 July 2018 - 03:28 AM

Hello Fishlady,

 

BRC upheld the auditor's findings. BRC judged the appeal based on the evidence presented by the auditor. Auditing is subjective sometimes. It also depends on the expertise of the auditor. That's why you can't compare the findings of another auditor to other site to the finding of the auditor on your site though it seems very identical.  

 

Sometimes it also depend how you deal with them, which very small findings could be added to your minors. Because we have standard where to base his findings. But sometimes, it could be reconsider.

 

Our dealing with auditor is like in dealing with the hostage-taker:

 

Hostage-taker : Never say NO to the hostage taker. From the movie: The Negotiator, starred by Samuel Lee Jackson

Auditor: Never argue to the auditor

 

regards,

redfox



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Posted 28 July 2018 - 10:26 PM

Hi redfox,

 

IMO everything is Subjective.

 

i agree that any challenging should be in the context of the "Big Picture." But after all you are paying.

 

IIRC BRC's website states that their auditor findings should be Globally consistent and invites emailed comments if perceived otherwise. Admittedly there could be Local consequences later. :smile:


Kind Regards,

 

Charles.C


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SQFconsultant

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Posted 29 July 2018 - 01:55 PM

Have you considered filing with BRC directly and citing incompetence of the CB in this matter and if you have factural proof that others in the area have not had to comply with the positive air item that would be included as an aside on the other item. Prepare for blowback if you include the other facilities in your complaint.


All the Best,

 

All Rights Reserved,

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Glenn Oster.

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http://www.GCEMVI.XYZ

https://glennoster.website3.me/

 


Fishlady

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Posted 29 July 2018 - 04:09 PM

Have you considered filing with BRC directly and citing incompetence of the CB in this matter and if you have factural proof that others in the area have not had to comply with the positive air item that would be included as an aside on the other item. Prepare for blowback if you include the other facilities in your complaint.


We are proposing to BRC to install the positive airflow if they will then grant us the certification (don’t want to spend all that time and effort if they do not accept the scope of work as adequate). We are debating at what point to bring up the inconsistency in application of the standard, knowing there could very well be blowback.


redfox

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Posted 30 July 2018 - 04:43 AM

 Hello All,

 

It is known that BRC has suspended recently one BRC-accredited CB to audit for BRC standard. It may be one of cause that BRC auditors seem strict and very careful now on giving their findings.

 

We also have noticed that on last audit on June 2018. We have findings on this audit that had not been found by the auditor on the last three audits, the same CB and the same auditor. In our minds, we just justify it as the preparation of the auditor for the BRC8 standard, so he is so strict in doing his audit this year. 

 

Whatever is the reason, we as the audited site, must do whatever we could to comply the standard diligently. Just be nice to the auditor. They are also human. They can turn into an angel but can turn instantly to an evil.

 

 

regards,

redfox

 

 

 

regards,

redfox



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Posted 05 December 2019 - 03:32 PM

Hi fishlady,

 

I daresay you are already well-aware of following (BRC6 Guideline) quote but JFI - 
 

Hi Charles,

 

This is regarding the same problem but with Issue 8. Since we are using cooling machines in high risk area, they do only the re circulation of inside air. If air coolers do not bring outside air in to the production area, it does not have any filters. How this affect to the BRC requirement? 
Thank you in advance. 





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