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Could I have your thoughts on this statement Pre-BRC first time audit


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#1 Dancla27

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Posted 27 November 2019 - 10:42 AM

Hello All,

 

Long time lurker, first time posting. 

 

We're heading toward our inaugural BRC Food audit. We are currently polishing things up, yet are stuck at a fundamental point. Do we need to sieve or not?

 

Please have a look at the reasoning we are considering for NOT sieving.

 

We repack a range of dry powdered ingredients at our warehouse, we repack 25kg drum down to smaller amounts (not blending just simple repack). 
This repack process is carried out in a clean room where we are careful about contamination risks (no pen tops, jewellery) These are checked and audited (no jewellery, no glass, no loose metal).
The materials come in sealed drums from a range of GFSI / Non-GFSI  suppliers, most of which would metal detect or sieve product before packing into sealed drums that arrive with us.
We deal with up to 50 items a day and manufacturing report that sieving can take up to 20 mins per product to sieve, so this is proving to be impractical. We are not currently metal detecting.
All of our customers are B to B customers so all materials sold are for further processing and in most cases will undergo further sieving/metal detection before going to end user.
If we were not repacking, most of our other products come in sealed drums from factory through our warehouses to customer - There is no expectation that we would be sieving these so we feel as long as we take enough care in repacking process we do not need to sieve. 
During the repacking process we visually inspect products for foreign bodies.
We feel if we that sieving products increases the risk of product cross - contamination and foreign body contamination from the sieves themselves.
 
All input gratefully received. 
 
Many thanks,
 
Dan
 


#2 mgourley

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Posted 27 November 2019 - 10:52 AM

There is your justification for not sieving. Good risk assessment.

 

Marshall



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#3 Charles.C

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Posted 27 November 2019 - 02:31 PM

Hi Dancla,

 

I assume the 2nd "if we" was a typo. And the logic in same sentence is irrefutable. Especially in absence of a MD.

 

IMO it (obviously) presumably comes down to the methodology/environment/workers involved in reception/storage/repack.

 

Unfortunately, for me, seeing would be (required for) believing.

 

You might think about sending some finished product out for MD screening. (unless you get equivalent coverage from external feedback). The standard auditor query is - Show me the(some) evidence. :smile:


Kind Regards,

 

Charles.C


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#4 FSQA

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Posted 27 November 2019 - 02:40 PM

I assume the 2nd "if we" was a typo. And the logic in same sentence is irrefutable. Especially in absence of a MD.

Agreed with Charles on this, its not a good idea to say that we cannot do it because we are busy.

 

 

All of our customers are B to B customers so all materials sold are for further processing and in most cases will undergo further sieving/metal detection before going to end user.

IMO: this can be your best approach. If you can communicate your process with your customer and can work with them in writing that these product went through repackaging but not through a sieve or MD and based on the supply chain model, they SHOULD be performing it, it can cover you, since your product requires further processing and it is not going directly to the end user.



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