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BRC V8 Audit Non-Conformances (inc. Radiological)

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MaAra

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Posted 06 May 2019 - 12:30 PM

I was wondering if anyone that has already gone through the V8 BRC Audit would like to share their non- conformances so we all can learn what Auditors are looking for this time around ?

 

 



zanorias

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Posted 07 May 2019 - 12:57 PM

Hi MaAra,

 

I presume non-comps will be specific to the site being audited. In terms of what auditors will be looking for now as appose to V7, the following may be of interest:

 

BRC do a guide in the change to V8:

https://www.brcgsboo...=24&product=454

 

Campden do a briefing seminar for issue 8:

https://www.campdenb...ASAAEgIYHfD_BwE

My Technical Manager was sent on this and gave generally good feedback



zanorias

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Posted 09 May 2019 - 02:29 PM

Funnily enough, I can expand on my previous answer with actual experience. Guess who turned up on site yesterday morning!

 

Whilst the non-comps would have existed in issue 7, the audit itself was a little different. Every previous audit, it would follow the general linear process flow so start in low risk at de-box end. So you can imagine our surprise after rushing around low risk when the auditor walks into the LR changing room, then decides to do high risk first :yeahrite: I can see the reasoning, but I don't know whether this is something the auditor has always done, or there is some instruction to auditors from v8. In hindsight we should have anticipated this possibility - for any auditor - and not assumed.



MaAra

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Posted 09 May 2019 - 04:30 PM

Funnily enough, I can expand on my previous answer with actual experience. Guess who turned up on site yesterday morning!

 

Whilst the non-comps would have existed in issue 7, the audit itself was a little different. Every previous audit, it would follow the general linear process flow so start in low risk at de-box end. So you can imagine our surprise after rushing around low risk when the auditor walks into the LR changing room, then decides to do high risk first :yeahrite: I can see the reasoning, but I don't know whether this is something the auditor has always done, or there is some instruction to auditors from v8. In hindsight we should have anticipated this possibility - for any auditor - and not assumed.

Thank you for sharing your experience!

 

I can say that on previous years when I was working on a RTE production plant, the auditor always started on the high risk area and then moved to the low risk area for the plant observations.(Considering potential cross contamination). 

 

This year, I have gone through 2 BRC Audits for 2 plants that I oversee audits for. The Only Non-Compliance we received that had to do with V8 was the Radiological hazard not being considered in the hazard analysis on it's own. We had it in conjunction with the chemical hazards and we received a minor because of that. So now our Food Safety Plan has 4 hazards considered: Biological, Chemical, Radiological, Physical



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Posted 09 May 2019 - 05:21 PM

Thank you for sharing your experience!

 

I can say that on previous years when I was working on a RTE production plant, the auditor always started on the high risk area and then moved to the low risk area for the plant observations.(Considering potential cross contamination). 

 

This year, I have gone through 2 BRC Audits for 2 plants that I oversee audits for. The Only Non-Compliance we received that had to do with V8 was the Radiological hazard not being considered in the hazard analysis on it's own. We had it in conjunction with the chemical hazards and we received a minor because of that. So now our Food Safety Plan has 4 hazards considered: Biological, Chemical, Radiological, Physical

 

I have never been audited to BRC, but I daresay this was an auditor grasping at straws - trying to find SOMETHING? If that was your only non-comp, then I'd say you did a great job!



GMO

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Posted 05 June 2019 - 03:23 PM

This year, I have gone through 2 BRC Audits for 2 plants that I oversee audits for. The Only Non-Compliance we received that had to do with V8 was the Radiological hazard not being considered in the hazard analysis on it's own. We had it in conjunction with the chemical hazards and we received a minor because of that. So now our Food Safety Plan has 4 hazards considered: Biological, Chemical, Radiological, Physical

 

That's tough!  Especially as most plants now have Allergenic as well (which is normally more likely than radiological.)



Jim E.

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Posted 16 August 2019 - 08:49 PM

Just finished the good old BRC audit.  He did ask staff questions related to Food Safety Culture.  He has his own version of doing a mock trace that sort of sent us for a loop at first, took some time to grasp his vision.  He spent less time on the floor than usual and compared to previous auditors.  Overall it went well.

 

Now I am also looking for an answer, we were given a NC that we know cannot be corrected in the 28 day window, has anyone ever had to write a request for extension?  I am currently searching the forum for a possible answer but may post a new thread.



florarezai

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Posted 20 August 2019 - 05:55 PM

1. A Safety Data Sheet was not available for the sanitation chemical: FS CIP Cleaner.

2. METAL CONTROL (4.9.2-MC, 2018.09.05) states that "No blades are allowed to be left lying around production or warehouse area." On the first day
of this audit, a box cutter with exposed blade was found sitting on the machine frame. The box cutter was immediately placed in the proper
toolbox.



florarezai

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Posted 20 August 2019 - 06:01 PM

That's tough!  Especially as most plants now have Allergenic as well (which is normally more likely than radiological.)

This is exactly what I am looking for. Would you please share how you did radiological hazard analysis?



Charles.C

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Posted 21 August 2019 - 03:28 PM

I was wondering if anyone that has already gone through the V8 BRC Audit would like to share their non- conformances so we all can learn what Auditors are looking for this time around ?

 

BRC have actually issued previous compilations/analyses of their most "popular" NCs. IIRC there tended to be depressing similarities over the years although I daresay the VA addition will now be right up there unless the auditors have got bored in the absence of horsemeat-type disasters.


Kind Regards,

 

Charles.C


GMO

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Posted 23 August 2019 - 12:40 PM

This is exactly what I am looking for. Would you please share how you did radiological hazard analysis?

 

We got a non con as well.  Naively I trusted my team to do something I asked them to :angry2:

 

Anyway, when we looked into it properly, there are very few areas which are a risk.  Only really if you source fish from Japan, any kind of meat or vegetables from Ukraine and surrounding countries.  Apart from that the risks are miniscule.  It's worth considering if you have any crops grown near nuclear plants or old test areas to prove you've considered it and that's about it really.  Irradiated foods are not a risk (but that's what most people have considered on plans I've seen, wrongly. :doh: )



Charles.C

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Posted 23 August 2019 - 05:51 PM

We got a non con as well.  Naively I trusted my team to do something I asked them to :angry2:

 

Anyway, when we looked into it properly, there are very few areas which are a risk.  Only really if you source fish from Japan, any kind of meat or vegetables from Ukraine and surrounding countries.  Apart from that the risks are miniscule.  It's worth considering if you have any crops grown near nuclear plants or old test areas to prove you've considered it and that's about it really.  Irradiated foods are not a risk (but that's what most people have considered on plans I've seen, wrongly. :doh: )

 

Hi GMO,

 

Re-radiological,

 

I think the commercialisation/labelling of irradiated foods has always been a highly debated issue despite scientific claims that there are no significant safety issues, eg - .

 

https://en.wikipedia...ood_irradiation

 

However "radiological hazard"  for certain input raw materials could, I suppose, be a potentially contentious issue ( and maybe also depending on local Regulatory).

 

IIRC radiologically sensitive source locations in USA have been officially mapped/published. Elsewhere no idea, other than disaster-related presumably.

 

@florarezal, maybe have a look at this -

 

https://connectfood....od-safety-plan/

(Google has a few additional related links)


Kind Regards,

 

Charles.C


pHruit

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Posted 23 August 2019 - 06:13 PM

For the radiological hazards bit, I included a mention in our scope that we considered this along with micro, physical, chemical, allergens, aliens, stray aardvarks and all the other bits BRC has now crammed into the requirements there.

We also listed it as a hazard at the goods receipt stage at the start of the process flow, again primarily just to show it had been considered as required - we referenced a separate study I put together, and gave it the lowest probability score.

 

The more detailed study totalled around 3-4 sides of A4 on the various potential routes of radiological contamination - Nuclear accidents/testing (Chernobyl/Fukushima/Marshall Islands etc - we don't source anything from anywhere near any of these so no significant risk to us), a foray into nuclear physics considering the energy typical x-ray/e-beam sources and  of γ photons from 60Co and 137Cs and how these are insufficient to actually make anything radioactive, some notes on radon assessment of the site (south west UK), a summary of measurements with a Geiger-Muller counter etc. We did note that there is some evidence that irradiation can create chemical changes that may or may not be harmful, but that these are (a) a chemical hazard, not a radiological one, and (b) have been risk assessed by EFSA (and presumably by the FDA too) and are not presently considered significant for the categories of food and the specified energy limits currently approved.
We did note that it is possible to render food radioactive if one has access to higher energy sources, but asserted that the probability of an unscrupulous supplier diverting a shipment via CERN or similar was vanishingly small...

The auditor didn't even ask to look at it :roflmao:  

Broadly if you're not sourcing mushrooms from southern Belarus or similar then I very much got the impression that they just want to see that you've jumped through the hoops to meet the wording of the standard...

 

 

Incidentally as a heads-up on an unrelated topic, the interpretation guide makes a couple of mentions of "primary packaging" relating to the food-contact components. This is wrong. BRC know it's wrong but haven't bothered to tell anyone yet. The definition in the glossary of the standard itself is apparently "correct" (and helpfully in direct contradiction with a couple of notes in the IG, even though they reflect the view of pretty much everyone else in the industry), and it can lead to some truly farcical situations.



Charles.C

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Posted 24 August 2019 - 04:35 AM

For the radiological hazards bit, I included a mention in our scope that we considered this along with micro, physical, chemical, allergens, aliens, stray aardvarks and all the other bits BRC has now crammed into the requirements there.

We also listed it as a hazard at the goods receipt stage at the start of the process flow, again primarily just to show it had been considered as required - we referenced a separate study I put together, and gave it the lowest probability score.

 

The more detailed study totalled around 3-4 sides of A4 on the various potential routes of radiological contamination - Nuclear accidents/testing (Chernobyl/Fukushima/Marshall Islands etc - we don't source anything from anywhere near any of these so no significant risk to us), a foray into nuclear physics considering the energy typical x-ray/e-beam sources and  of γ photons from 60Co and 137Cs and how these are insufficient to actually make anything radioactive, some notes on radon assessment of the site (south west UK), a summary of measurements with a Geiger-Muller counter etc. We did note that there is some evidence that irradiation can create chemical changes that may or may not be harmful, but that these are (a) a chemical hazard, not a radiological one, and (b) have been risk assessed by EFSA (and presumably by the FDA too) and are not presently considered significant for the categories of food and the specified energy limits currently approved.
We did note that it is possible to render food radioactive if one has access to higher energy sources, but asserted that the probability of an unscrupulous supplier diverting a shipment via CERN or similar was vanishingly small...

The auditor didn't even ask to look at it :roflmao:  

Broadly if you're not sourcing mushrooms from southern Belarus or similar then I very much got the impression that they just want to see that you've jumped through the hoops to meet the wording of the standard...

 

 

Incidentally as a heads-up on an unrelated topic, the interpretation guide makes a couple of mentions of "primary packaging" relating to the food-contact components. This is wrong. BRC know it's wrong but haven't bothered to tell anyone yet. The definition in the glossary of the standard itself is apparently "correct" (and helpfully in direct contradiction with a couple of notes in the IG, even though they reflect the view of pretty much everyone else in the industry), and it can lead to some truly farcical situations.

                             Slightly OT

Hi pHruit,

 

Thanks for above.

 

Just as  comments - 

 

(1) Re (a) above - for haccp purposes, the USFDA appear to categorize all radiological hazards  within Chemical hazards. (And similarly Food allergens). Some "layouts"  in attachments below.  (Subjectivity reigns ! :smile: )

 

.Attached File  PCHF-Guidance-Chapter-3_01-17-2018-2.pdf   309.55KB   61 downloads

Attached File  Developing-a-Food-Safety-Plan-Under-FSMA.pdf   2.11MB   89 downloads

 

(2) Regarding red ^^^^, IIRC there is a summary here of BRC's viewpoint on their (debatable) interpretation of "primary packaging" -

 

https://www.ifsqn.co...ng/#entry136554

 

(3) Writing haccp plans in certain geographical locations must still be (radiologically) challenging, eg (2017) -

 

http://fsns.com/news...logical-hazards

 

again, JFI, some other "radiological" threads here -

 

https://www.ifsqn.co...ntrol-measures/

 

https://www.ifsqn.co...ology-in-haccp/

 

https://www.ifsqn.co...ogical-hazards/

 

PS - IMO, after the event, some auditors could perhaps be classified as "aliens" !


Kind Regards,

 

Charles.C


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JV.Legal.Alliance

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Posted 24 August 2019 - 09:15 AM

....Focus should be done on really radiological isotopes which may be present in water or soil (either from a naturally occurring source or resulting from a man-made disaster )  e.g. Technetium-99 for medical investigation , Iodine -131 for medical treatment or Cesium -137 + strontium-90 + Iodine -129 in the area of Nuclear Power Plant / damage to a nuclear facility from a natural disaster.  Such group of isotopes are really classified as radiological hazards.
 
....In addition, you should be aware of the condition of the water used for production and manufacture in your facilities. Radiological hazards can become incorporated into food through the use of water that contains the radionuclides during food production or manufacture. There are areas in many country where high concentrations of some radionuclides, such as radium-226, radium-228, and uranium, can be detected in well water. 
 
.....Element composition in food are C , H , O , N, Ca, K, Mg, P, S, Fe, Mn , Zn etc .  Exposure of food to ionizing radiation in the form of x-rays, gamma rays or electron beams , Radicidation or Radappertization can not cause the radioactive isotopes in Food. 
 
....Irradiated food are safe food in many country. Just label to declare the irradiated food status in compliance with labelling regulatory requirement in destination country is OK. Be aware that fraudulent labelling practice is one kind of food fraud issue. 
 
.....Anyway, if you are also aware of any potential hazards from irradiated material (for example, it is not permitted in the intended country of sale) then this may also be considered as a hazard.


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Posted 30 August 2019 - 09:30 AM

Hi All,

 

to close out our non con, I found this link which would be really useful as a reference to UK sites.

 

https://www.gov.uk/g...nt-rife-reports

 

Hope that helps!



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