BRC V8 3.10.1 - Documentation & Action

Hi All,

Clause states " Actions appropriate to the seriousness and frequency of the problems identified shall be carried out promptly and effectively by appropriately trained staff". This I get, but does there needs to be a risk assessment put in place to determine the seriousness of the issue? How do I detail what type of response is required for each issue? Do I split into Food, Safety, Quality, Legality and how would I justify each response?

Many thanks

C

Hi Cabbie - the interpretation notes for this clause (BRC 8) state:

The company should ensure there is a clear process for customers (and potentially consumers too) to raise legitimate complaints about the products. This is usually via the contact information on product labels. Where products are supplied into food service or through intermediaries, every effort should be made to ensure that complaints raised are relayed to the complaints department of the site.
All complaints need to be captured to a specified location to ensure they are adequately assessed and investigated, and the results of this investigation recorded. A documented complaints procedure is therefore required and the inclusion of a standardised complaint form may be useful.
Complaints must be handled by appropriately trained staff to ensure that a proactive system identifies the severity, and therefore the significance, of any complaints received. Actions must be appropriate to the seriousness of the complaint. A rapid response would be required for serious issues (such as a glass complaint) or where a number of complaints are received, suggesting a widespread problem.
Investigation must be completed within a defined timeframe and feedback provided to the complainant wherever contact details are provided.

​BRC Seems very keen on risk assessments - so, when determining response time we do use a risk assessment (basic) to determine seriousness of the issue.  ie. did somebody get ill or was there potential for this and also how many complaints - ie. a "one off" or many complaints regarding one batch?. 

Allergen/serious foreign body, micro issue and/or multiple complaints would mean this is A grade,

Quality issues that would affect efficacy/quality ie. poor pack seal/clumping/extraneous vegetable matter would be B

Minor issues - eg. legible but feint date code, packaging out of registration, would be C

(examples would be dependant on your own product type & relative risk) 

I'm am not familiar with BRC, however, you may want to start with CCP's and work your way backwards from there

CCP's that are not met should have an immediate corrective action that is written into the monitoring program and if those steps are not followed written deviations should automatically occur.

You really don't need a risk assessment, but you should find the root cause........you cannot properly address the issue without that..........and knowing the root cause may help determine the severity

-so let's your finished goods are short weight (which is a big deal, but food safety is not impacted) all lots off the line with the issue should be produced and put on hold (corrective action), you spend time on the floor to figure out why and discover that employee A cannot reach the labeling machine, and when they reach for it, they are adding weight to the scale causing the check-weigher to allow the package to pass (when it's actually under weight) you have now found the root cause

Preventative measures are now required to ensure this doesn't happen again............so you put in a maintenance tickets to have the label machine moved and you verify package weights once this is complete and you increase monitoring for a week to make sure the preventative measure worked............you can know close your NCR

Hope this helps

I'd echo Lesley's comments regarding a basic "risk assessment" to categorise complaints - ours are broken down into food safety issue, significant food quality or multiple smaller quality issues, minor quality issue, other "annoyances" that may result in an NC from a customer but don't affect safety or quality. As part of your procedure you can then define how the different categories are addressed.

how does a risk assessment help to prevent the re-occurance?  I know BRC loves them (as I've learned on this forum), but maybe not the best tool

It's not (directly) about preventing recurrence in this context - it's about determining the severity of a complain issue and thus the type of response required.

got it!  thanks

We trend the complaints and review monthly and use root cause to deal with serious complaints. Have no documented risk assessment though, all complaints are logged and actioned immediately with time scales recorded.

good Friday,

i am new to the BRC Global standard policy, however i was tasked with compiling and creating an SOP for Clause No 3.10.1-3.10.3

We had a pre-assessment audit and we are missing an SOP/Data or any documentation for this Clause. 

i might be over thinking it but i am having a hard time getting started, Create an SOP- then track complaints and create a plan of action?

sorry as i type this i feel like i might be over thinking it.

I handle cargo claims, so this procedure is new to me.

any help is greatly appreciated

thanks

i might be over thinking it but i am having a hard time getting started, Create an SOP- then track complaints and create a plan of action?

Yep, this is pretty much it - you need a procedure/SOP that details how you handle complaints (potentially linked to whatever you're doing under section 3.7), a system to record what happens to each individual complaint, and some sort of overall summary/record so you can do your trend analysis.