9 replies to this topic

[ts33]

Hello everyone,

 

This site is awesome to learn from each other! I am new to BRC audit. Just have a question regarding BRC clauses. Does each single clause under a particular  section has to be addressed on a single program separately or they can be combined to describe them in one program? As a an example, section 3.4 INTERNAL AUDITS has 3.4.1 to 3.4.4, total 4 clauses. can the all be combined under one program to be compliant? Thanks to all sharing wisdom and knowledge.

 

 

Regards,

 

ts33

[DN_QAMGR]

Hi ts33, welcome.

 

You should use the forums and find resources others have shared. This website is great and managed by knowledgeable and experienced people from many industries. 

 

From my experience in BRC Packaging Audit, I do have parts of my prerequisite that answer multiple clauses. For instance, I combined my GMP & Monthly audits to one form. I added the clauses to ensure that I know what parts of the standard they support. 

 

http://www.ifsqn.com...facility-audit/

 

Good luck on your future BRC Audits and hopefully helped a bit. 

 

Have a good one. 

 

 

[mgourley]

The wonderful thing about BRC (and other GFSI approved schemes) is that it tells you what you have to do, not how you have to do it.

 

If you wish to include all of the requirements of 3.4 in one document/policy/procedure, you are certainly free to do so.

 

Let's say you choose to have a document/policy/procedure called "3.4 Internal Audits".

 

As long as you say what you are going to do to meet the standard in that document, that's perfectly fine. 

"Say what you do, do what you say and be able to prove it".

 

For 3.4 I have a document that discusses the internal audit of all the sections of the standard, and how that is accomplished.

The standard requires a schedule of internal audits "throughout the year", so I have a separate document that is the internal audit schedule.

The standard also requires that in addition to auditing the standard, you do inspections of the production areas at least monthly.

I have another document that describes what that means, who does them, what is required, what is done with the results of the inspections and how they are communicated.

 

Theoretically, you could put that all in one document, but in general practice, that would glaze over peoples eyes and they would never read or understand the entire document.

 

As long as you are addressing the standard where it says "there shall be a program" or "there shall be procedures"....and have the documentation to show that you are actually doing what you say you are doing, you are good to go.

 

There is no right way or wrong way to write procedures or policies under BRC. You just need to address the requirements, and have the documentation to back up what you say you do.

 

Marshall

[redfox]

Hello,

 

Auditors will just scrutinize your FS manual if it follows BRC standard. Given you adhere on what is written on the standard, auditors will review you procedure if you follow it, the monitoring form you presented if it is filled up correctly. Do not write on the procedure the things that you are not doing.

 

regards,redfox

[aab93]

Hello ts33,

 

For my facility I have done just what you are asking about; my predecessor had multiple policies and programs that, under BRC, could easily be combined. So lately what I have been doing is this - I open the BRC Standard to a particular clause and I ask myself point-by-point if my program covers that clause. Also, I note the BRC section/clause that the program pertains to so - in the audit setting - when the auditor is addressing a particular clause, I can pull the single document/program that I feel corresponds to that section. In addition, as part of my document control system, I have created a spreadsheet listing all of the clauses, and I hyperlinked the corresponding program/policy with that clause. This makes for a more organized setting. In my previous BRC audit my auditor referred to a section and I found myself asking him "regarding non-conforming product in clause X.YZ - are you referring to hold and release?" This happened quite often in my previous BRC audit and the auditor would only respond with "I don't know, you tell me." (This got very old very quickly). Therefore, going into my next BRC Audit when clause X.YZ comes up - I can confidently pull out my program and say "this is how our facility complies," as opposed to feeling unsure.

 

I hope this helps!

[bensmith007]

Hi ts33,

 

You can absolutely combine these- we have 2 SOPs for clause 3.4 talking about our audit program- both are pretty short at just over a page- looking at them now I'm thinking they should probably be combined. We then have other information such as audit training records to cover 3.4.2 and our GMP audits for 3.4.4, and a separate risk assessment to cover that last sentence of 3.4.4. Not every clause needs a written document or specific mention to comply.

 

Further to what Marshall and Angelicab said- it makes a lot of sense to have your food safety manual follow whichever audit standard you use to make the audit easier. Our FS manual starts with document BRC 1.1 which is a statement on management commitment and quality activities, and we carry on in this fashion all the way through to BRC 7.4- Protective Clothing. In audit when the auditor asks to see how you comply with a given clause, it is a very simple task to find the clause and everything is geared towards satisfying that BRC auditor.

 

I have been through several customer audits since we implemented BRC last year and it is generally fairly easy to find the BRC clause that covers whatever question they have- I will have the PDF version of the BRC standard open so I can hit control+F and search for key words to quickly find the relevant clause(s).

 

Ben

[Charles.C]

Some users like to layout their response to the multitude of Clauses in BRCX Food in orderly, eg One-to-One fashion, for reasons like their own / audit convenience.

Some users prefer to respond highly "non-linearly".

Some users go "in-between" the above.

 

Afaik the heirarchy of BRC don't care a jot which of the above methods are used although their auditors might prefer the first option to save time.

 

It's up to you.

[pHruit]

Afaik the heirarchy of BRC don't care a jot which of the above methods are used although their auditors might prefer the first option to save time.

 

This is very true, and there may be some merit to making it simple for yourself during BRC audit by having your FS manual directly linked to the BRC clauses, but it really isn't essential.

If you don't directly follow the clauses then it could be useful to have a simple table showing how your policies/procedures/records link to the respective BRC clauses - makes it easy to find stuff in audit (particularly if it's a relatively new manual and you're not totally familiar with it), and also doubles as a checklist you can use to make sure you've covered off all of the relevant clauses.

Can also use the same approach if you have one manual covering two or more standards - we do both BRC Food and BRC Agents & Brokers, with the FS manual linked to the BRC Food numbering and a table document linking to the Agents & Brokers standard (it's both shorter and numbered differently).

[ts33]

 You are all beautiful people who participate to share personal experiences and opinions!

 

Thanks,

 

ts33

[redfox]

Hello,

 

Im glad to say that our BRC certificate was already released after tedious CAR for minor NC of the clause 3.5.1.1 to 3.5.1.2. 

 

What the auditors requires us was to align all your steps in you procedure every line of the clauses. Everything must be mentioned or included in your procedure.

 

regards,

redfox