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BRC S&D Non-conformity enquiry

Section 4.4 Fabrication

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#1 Sarahr78

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Posted 11 January 2019 - 03:26 PM

Hi

 

I have a question following a recent BRC audit. We had a non-conformity raised against section 4.4 of the S&D standard as follows:

 

"During the site tour water was noted as dripping from the roof onto pallets of products within the return area"

 

The water was due to condensation. The temperatures had been relatively warm the previous day, then they plummeted over night but then rose quite rapidly causing condensation on the metal sanction of the roof.

I must state that the dripping of water was not due to the condition (holes etc) of the roof as this is a newly fitted roof within this area. 

 

My first question is why would the auditor site the non-conformance against a whole 4.4 and not a clause within 4.4? I have never experienced this in an audit before. 

 

My second question is has anyone else experienced something similar and how did you manage to resolve?

 

We are unable to store the stock anywhere else as this is its designated area and we simply have no room to put it anywhere else. All the goods are finished goods in tertiary packaging. 

 

We did as an interim measure cover the affected stock with plastic and cardboard shrouding until the dripping stopped, but how are we to determine when the weather will have the same effect again! 

 

Any help as ever much obliged

 

 



#2 FSQA

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Posted 11 January 2019 - 06:38 PM

Sarahr78,

 

The non-conformity issued was minor/major/critical?

 

 

My first question is why would the auditor site the non-conformance against a whole 4.4 and not a clause within 4.4? I have never experienced this in an audit before. 

 

IMO: If the ceiling was intact and in good condition (as you mentioned above), this should not have been a non-conformance, as the 4.4 mostly talks about facility fabrication and cleaning accessibility. However, this could fall under 4.1.1

Consideration shall be given to local activities and environment, which may have a potentially adverse impact, and measures shall be taken to prevent product contamination. Where measures have been put into place to protect the site from any potential contaminants, these shall be regularly reviewed to ensure they continue to be effective. (which is defined as XR-not applicable on the basis of risk in the standard, however despite product in tertiary packaging, it would be difficult to show that product is not affected : just my 2 cents).

 

My second question is has anyone else experienced something similar and how did you manage to resolve?

 

You need to contact your HVAC service provider, if you have one already in place. Couple of years ago, we had the same issue and we end up installing few small (automatic) coolers just to maintain the temperature of the area.

 

Hope it helps.


Edited by FSQA, 11 January 2019 - 06:39 PM.


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#3 Sarahr78

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Posted 14 January 2019 - 09:34 AM

Many thanks for your response

 

The non-conformance was logged as a minor. 

 

I agree with your comments that the non-conformance should not have been cited under section 4.4. I have already raised a query with our auditing house that the non-conformance has been logged under the whole of section 4.4 rather than a clause within 4.4.

 

We also had another non-conformance under section 7.4 for something else that doesn't make sense! There was a tray of personal belongings (which included a fluffy keyring, hand cream, lip balm and a foil covered chocolate bar) sitting on a re-packing line (only outer packaging is changed), granted its shouldn't have been there but I dont think is should have been cited under 7.4 either. 

 

 

I will pass on your comments reference contacting the HVAC, We may also contact the company who supplied and fitted the new roof as see if there's anything they can do

 

In the meantime I will wait to see what the auditors say about the citing of the two non-conformances.

 

Many thanks 



#4 Charles.C

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Posted 14 January 2019 - 10:16 AM

Hi Sarah,

 

I have no idea what a metal "sanction" is but one, cheap, "temporary" solution (depending perhaps on the area/configuration involved) is to install a (sloped) drip catch tray.

 

This method is commonly used IMEX where air conditioners have to be sited above product processing  tables and significant temperature differences exist.


Kind Regards,

 

Charles.C


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