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#1 Ildiko

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Posted 10 January 2019 - 09:20 PM

Hi All,

Could I please get your advice on the below.

We are a very small yoghurt manufacturing company with 15 employees.
I'm in the middle of BRC issue 8 implementation process.

Label verification will be my responsibility as one person technical within the company. There will be no extra resources provided from production therefore I will do start, middle end of checks.

Labels and sleeves applied on product off line. We have a lot of small orders is 50-60 yoghurt a per customer, 15-20 small customer orders a day. This means I would need to sign off at least 60 labels a day on top of doing rest of my work.

Anyone has any suggestion how could this be made more simple?

PS not sure if it is relevant but majority of product which gets labelled are outsourced to us. Labels and sleeves supplied to us by our customer, also the yoghurt pots and foils.

I assume this doesn't really matter as a manufacturer it is our responsibility to ensure we are compliant with relevant legislations and standards?

I appreciate any suggestion on this.

Thank you
Ildiko



#2 Charles.C

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Posted 11 January 2019 - 03:46 AM

Hi All,

Could I please get your advice on the below.

We are a very small yoghurt manufacturing company with 15 employees.
I'm in the middle of BRC issue 8 implementation process.

Label verification will be my responsibility as one person technical within the company. There will be no extra resources provided from production therefore I will do start, middle end of checks.

Labels and sleeves applied on product off line. We have a lot of small orders is 50-60 yoghurt a per customer, 15-20 small customer orders a day. This means I would need to sign off at least 60 labels a day on top of doing rest of my work.

Anyone has any suggestion how could this be made more simple?

PS not sure if it is relevant but majority of product which gets labelled are outsourced to us. Labels and sleeves supplied to us by our customer, also the yoghurt pots and foils.

I assume this doesn't really matter as a manufacturer it is our responsibility to ensure we are compliant with relevant legislations and standards?

I appreciate any suggestion on this.

Thank you
Ildiko

 

Hi ildiko,

 

It might depend on the complexity of the label (eg foreign language) but assuming the labels for each small order come from the same batch (?) and you are using an approved supplier (?) I suggest to reduce the sampling frequency. Simple maths.


Kind Regards,

 

Charles.C


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#3 012117

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Posted 11 January 2019 - 05:11 AM

Hi, Idliko.

 

May we the reason behind top middle bottom?

Also in between customer, How long is the allotted time between changeover?

Also between customer, are there labels that are the same? or everything is different?

Is the inspection between top middle bottom done while it is running? or not? If not, for the top middle bottom, how many is one bundle?

 

Based on the info above, i may reason out what sampling will it be, given tthat it is only 60 pcs per customer, top middle may not be neccesary. IF you are doing the prerequisites, it may be unlikely that label will change along that 60 pcs.

 

Also, the one in the line need to be trained and be responsible not to label product as it is. Given the low volume, the speed may be limited, thus it will give the operator more chance to inspect (I assume you are not the one doing the labelling).



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#4 Ildiko

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Posted 11 January 2019 - 11:07 AM

Hi Charles. C,

 

Thank you for your reply.

Only english on labels, no other foreign languages. Also we are using approved suppliers, and yes the labels all from the same batch. 

 

How can I justify to reduce sampling frequency if it says clearly start/middle/end of run ( BRC issue 8 under 6.2.3 ) needs checked.

 

I'm afraid to get an NCR since sampling frequency specified in the standard although the standard does not talk about smaller runs?

 

Many Thanks

Ildiko



#5 Charles.C

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Posted 11 January 2019 - 11:52 AM

Hi Charles. C,

 

Thank you for your reply.

Only english on labels, no other foreign languages. Also we are using approved suppliers, and yes the labels all from the same batch. 

 

How can I justify to reduce sampling frequency if it says clearly start/middle/end of run ( BRC issue 8 under 6.2.3 ) needs checked.

 

I'm afraid to get an NCR since sampling frequency specified in the standard although the standard does not talk about smaller runs?

 

Many Thanks

Ildiko

 

Hi lldiko

 

The detail comes a little late. :smile:

 

i think you have now answered yr own query?

.

Usually BRC give you an "out" by including a "risk-based" note in the text but seemingly not this time.

 

I suggest you check the BRC Interpretation Guidelines for any flexibility.

 

Or silently deputize an "assistant".


Kind Regards,

 

Charles.C


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#6 pHruit

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Posted 11 January 2019 - 02:13 PM

How can I justify to reduce sampling frequency if it says clearly start/middle/end of run ( BRC issue 8 under 6.2.3 ) needs checked.

 

I'm afraid to get an NCR since sampling frequency specified in the standard although the standard does not talk about smaller runs? 

 

It's a bit odd that this is one of the few points that BRC doesn't stipulate frequency based on risk assessment - there could be situations in which start/mid/end is probably less than would be ideal, in addition to those like yours where it's overkill.

I don't think you need to reduce it though - as 012117 noted, you can cleverly sidestep the issue by training a member of the production team (production supervisor) to do this as long as you properly document the training. If there are several people you can train then its even better, as you can then have a document check countersigned by another trained individual. This shouldn't really require any extra resource since you'll be the one putting in the time to do the training, and the operators will already be on the line looking at the product during production anyway.



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#7 Ildiko

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Posted 11 January 2019 - 05:48 PM

Thank you for all who replied, suggested solutions.

 

Charles. C, placed an order for the BRC Interpretation Guide :-)



#8 3560lynne

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Posted 11 January 2019 - 06:20 PM

We have a daily production list. Staff follow the list and fill out the paperwork with these instructions:
 
WORK INSTRUCTIONS PRIOR TO MOVING ONTO THE NEXT SCHEDULED LINE OF PRODUCT:
1. HAS ALL LEFTOVER PRODUCT FROM THE END OF THE LAST RUN BEEN REMOVED?
2. HAVE ALL LABELS FROM THE END OF THE LAST RUN BEEN USED?
3. HAS THE NEXT PRODUCT LINE BEEN CHECKED FOR CORRECT BOX AND LABEL?
4. IF YES TO THOSE 3 STEPS, INITIAL THE "LINE CLEAR" COLUMN FOR THAT ITEM
IF YOU ANSWER NO TO ANY OF THESE 3 QUESTIONS: REMOVE ANY LEFTOVER PRODUCT FROM THE LINE AND MAKE SURE YOU HAVE THE
CORRECT BOX AND LABEL FOR THE NEXT SCHEDULED PRODUCT RUN. WHEN YOU ARE CLEAR, INITIAL IN THE LINE CLEAR COLUMN.
 
Monitor's initials are required at the end of each run and a verification of the production line is signed off by another trained employee on the day's events. (they check product line box and label against the daily production list)


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#9 Charles.C

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Posted 11 January 2019 - 07:58 PM

This is the BRC8 requirement as per 6.2.3 -

 

6.2.3 Procedures shall be in place to ensure that all products are packed into the correct packaging and correctly labelled. These shall include checks:

•  at the start of packing
•  during the packing run
•  when changing batches of packaging materials
•  at the end of each production run.

The checks shall also include verification of any printing carried out at the packing stage including, as
appropriate:
•  date coding
•  batch coding
•  quantity indication
•  pricing information
•  bar coding
•  country of origin
•  allergen information.


Kind Regards,

 

Charles.C


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#10 Ildiko

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Posted 11 January 2019 - 08:12 PM

Much appreciated Charles, I updated the check sheets accordingly.

Regards
Ildiko






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