Allergen Risk Assessment, BRC Section 5.3

Hi,

I am QAM for an egg only site who have had several BRC audits and have never been audited against allergens as we are single ingredient. (Aren't I lucky). However, we  recently went nut free due to a customer requirement. 

I have implemented the entire BRC v8 and we are due for our unannounced soon and I am still on the fence as to whether or not I should implement section 5.3 now. I have an allergen risk assessment which we/I have justified as low risk as we audit for presence of nuts daily and have controls in place like changing for lunch and hand washing etc for which we have no historical issues. 

I am petrified of our unannounced arriving and being told we should have 5.3 in place as we now declare nut free but I also do not want to implement if we dont need to. 

For example 5.3.3 : A documented risk assessment shall be carried out to identify routes of contamination and establish documented policies and procedures for handling raw materials and finished products to ensure cross contamination is avoided; take into consideration physical state of allergenic material etc........ We have no allergens on site to cross contaminate so I feel like it would be difficult to fully implement this section as we are not introducing we are just banning staff from having nuts for their lunch.

Any advice welcome. 

TIA.

IL

Hi IrishLass,

Yes, you are lucky!

I have no comparable, direct, experience to yr OP but, offhand,  it sounds like a query regarding the Scope of the Audit which IMEX is normally determined by consultation with the prospective auditing Company prior to an audit.

(eg can you exclude an "isolated"  Customer's specific request from the BRC Audit Scope ?)

BRC are now (theoretically) quite robust on the requirements for exclusions:

The exclusion of products produced at a site will only be acceptable where:

1) The excluded products can clearly be differentiated from products within scope, and

2) the products are produced in a physically segregated area of the factory.

As the OP's question relates to a site-wide requirement, it seems doubtful it would meet the requirements of (2)? (the emphasis on "and" is from the standard itself).

I would have thought there will be an expectation that the RA for 5.3.1 is in place irrespective of any claims, as even though you're a single-allergen site you'd still probably have to have the risk assessment to cover raw materials etc.

Do you therefore effectively have two different sets of responses to the requirements of section 5.3 - a "normal" one and a "nut free" one - and you're wondering which to put in front of the auditor on the day?