9 replies to this topic

[MsPloveyou]

Hello All, I am new to BRC and First time ever as an Quality Manager. Can someone help me out? What will I need to do an Risk assessment on in Version 8 BRC? Our company already have risk assessments for The process and CCP. If there anything else I would need to conduct an assessment on? Thanks in advance for your help.

[QALab1438]

Any clause in BRC that says "Based on risk" pretty much means you have to do a risk assessment for it or can prove why it is not a risk. We basically went clause by clause and wrote risk assessments every time they mention risk. Hope that helps!

[MsPloveyou]

Thanks that helps a lot. I will scan the book tonight at home and write down what needs to be done.

[pHruit]

I'd recommend reading the interpretation guidelines. There are lots of points in the standard where it is unequivocal on risk assessment being the required approach, but there are also other clauses where it's expected but not explicitly stated - these areas are much clearer in the interpretation guidelines.

[Charles.C]

I'd recommend reading the interpretation guidelines. There are lots of points in the standard where it is unequivocal on risk assessment being the required approach, but there are also other clauses where it's expected but not explicitly stated - these areas are much clearer in the interpretation guidelines.

 

Unfortunate inasmuch as, afaik, additional IG expectations are not auditorially mandatable.

 

The real problem IMO is that the Code is often (semantically) obscure/convoluted.

 

Hopefully the new (IG) arrangement may reduce the traditional confusion. Except presumably for newbies.

[pHruit]

The real problem IMO is that the Code is often (semantically) obscure/convoluted. 

I very much agree that this is the crux of the issue, Charles!

The dilemma when you're in the audit is that if you're not meeting the expectation as per the IGs then you'll potentially need to defend the alternative approach that you've used, as there is a reasonably high probability that auditor will view on the basis of "IG says risk assessment required, so why aren't you showing me a risk assessment?", at least IME.

There certainly are pragmatic and knowledgeable auditors out there for whom this is entirely acceptable, but there are definitely others for whom any (apparent) divergence from a very narrow interpretation of the standard/IG is more difficult to accept.

For those going into BRC for the first time I'd certainly recommend following the IG closely - there is enough stress already, without a potentially tortuous debate with auditors, possibly needing to get the CB involved if a contentious NC isn't actually a reflection of the standard etc. 

[Charles.C]

I very much agree that this is the crux of the issue, Charles!

The dilemma when you're in the audit is that if you're not meeting the expectation as per the IGs then you'll potentially need to defend the alternative approach that you've used, as there is a reasonably high probability that auditor will view on the basis of "IG says risk assessment required, so why aren't you showing me a risk assessment?", at least IME.

There certainly are pragmatic and knowledgeable auditors out there for whom this is entirely acceptable, but there are definitely others for whom any (apparent) divergence from a very narrow interpretation of the standard/IG is more difficult to accept.

For those going into BRC for the first time I'd certainly recommend following the IG closely - there is enough stress already, without a potentially tortuous debate with auditors, possibly needing to get the CB involved if a contentious NC isn't actually a reflection of the standard etc. 

 

I wonder how many newbies purchase the IG ?

 

I suspect for many, any request will be answered by a blend of  (a) That's what we pay you for ! and (b) It can't be that difficult, just put something together for an auditor !

 

I do agree that the IG has a lot of valuable experience/wisdom in it although, IIRC, I found it's (BRC7) comments on (IMO) one of the most difficult topics -raw material RA - unhelpful/ambiguous.

[pHruit]

I suspect for many, any request will be answered by a blend of  (a) That's what we pay you for ! and (b) It can't be that difficult, just put something together for an auditor !

I imagine almost every IFSQN member has heard these numerous times, but particularly so for those first venturing into certification.

It's slightly ironic that the IG is free once you've paid your certification fee, but that may not happen until the audit is imminent or potentially after 1st audit.

There have been a few modifications to the clause on raw material RA (3.5.1.1) with a few corresponding changes to the IG, but the overall tone is still fairly similar and thus likely to continue to cause a lot of confusion for those unlucky enough to be wading in to BRC for the first time.

[paulam1]

This is from version 7, but helps tremendously with what is required from RA standpoint.

Attached Files

•  BRC-Risk-Assessment.pptx   698.89KB   238 downloads

[Charles.C]

This is from version 7, but helps tremendously with what is required from RA standpoint.

Yes, thks. This Safefood360 file is indeed useful.and has been referenced here many times. It reflects BRC's curiously insatiable appetite for documented risk assessments. Thanks.