13.5 in S&D Contract Packing, frequency of QC checks

Hi all

Section 13.5 in S&D states that there should be documented procedures in place to ensure products are packed into the correct packaging and correctly labelled. Within the clause its says these checks should be completed at the start of the packing run, during the packing run, when changing batches or packaging materials and at the end of each packing run.

My arguments is that if a repacking line covers several days that a QC check should be completed at the beginning of each new day regardless of how far along the work is, this is to ensure things have not been tampered with overnight etc. 

is anyone else of the same opinion??

As always your comments and opinions are very much appreciated 

I agree with you. For repacking activities spanning quite such a long time period, a great number of checks probably makes sense.

Note that the standard requires start/during/end (and any change in batch of packaging materials) as a minimum only - as it's BRC, the Interpretation Guide does of course state that the actual frequency should be determined by risk assessment.

Start/during/end of each shift seems not unreasonable, but you know your process so will be best placed to consider what can go wrong, and how likely it is. If you're genuinely packing a single batch of product into a single batch of packaging across multiple days then I imagine an auditor would expect to see a higher frequency - basic start/middle/end could work out to less than once a day.

If the batch size is very large and you are having to change to new reels of labels etc then that would also be an obvious point at which to check.