6 replies to this topic

[BB2019]

Good morning everyone,

 

Trying to make an internal failure correct so that it will not be a major for the companies BRC audit next month. They had an employee leave that coordinated the trending and managed the quarterly management review. When that employee left in March no quarterly reviews were done afterwards and it is now December.

 

I see this error and it is going to get corrected but is there anything they can do to keep from getting a major nonconformance during the BRC Audit next month? 

I didn't know if it is better to write it up in the internal audit, complete the root cause and corrective action and keep moving forward. The facility has board meetings and I might be able to show evidence the goals were getting reviewed at those meetings, but its a stretch.

 

For everyone's piece of mind this is a very low risk facility with <10 employees and no CCP's so the consequence of not reviewing did not effect product but it is a clear violation of the standard.

 

Any advice is welcome, as I help the company pick up the pieces in time for the audit.

 

 

[ally1822]

Good morning everyone,

Trying to make an internal failure correct so that it will not be a major for the companies BRC audit next month. They had an employee leave that coordinated the trending and managed the quarterly management review. When that employee left in March no quarterly reviews were done afterwards and it is now December.

I see this error and it is going to get corrected but is there anything they can do to keep from getting a major nonconformance during the BRC Audit next month?
I didn't know if it is better to write it up in the internal audit, complete the root cause and corrective action and keep moving forward. The facility has board meetings and I might be able to show evidence the goals were getting reviewed at those meetings, but its a stretch.

For everyone's piece of mind this is a very low risk facility with <10 employees and no CCP's so the consequence of not reviewing did not effect product but it is a clear violation of the standard.

Any advice is welcome, as I help the company pick up the pieces in time for the audit.

We had something similar to this a couple of years ago.
I would person generate a non conformance myself to show you found the error and that your corrective action will be to investigate how this happened I.e staff member left and pick up the audit from now on going forward . Of course collate any information you can get to say there is commitment from the senior management team . State that you will review this quarterly .
Hopefully the auditor will understand and give you a minor . Although it says to review quarterly I actually review each section month by month so you could possibly review one December and one jan before the audit . That will give you 3 reviews instead of the 4 scheduled for the year . Just a thought


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[Jeffrey Ort]

I agree with Ally1822 and I have done this a few times when performing last minute challenges to systems. 

Write yourself the NC, as a major or minor (based on risk) and  ensure that the root cause identifies that there was not a deputy to the role responsible for the trending and reporting.

• The key is you have identified the issue (deficiency)
• Assign proper level of NC
• Perform root cause analysis
• Create the corrective action (could be create the missing information to share at next review meeting)
• Identify the preventive measure - there will be a fixed meeting agenda to ensure that all items are reviewed in accordance to our system requirements.

 

Best of luck with your audit!

[BB2019]

I appreciate the input everyone, just nice to hear some second opinions on how to handle this.

 

Thank you!

[Hoosiersmoker]

Hope all is well with the audit preparations. Does BRC require quarterly Management Review? If they only require annual, and you currently identify that annual is adequate couldn't you just change the frequency to annually and conduct a meeting? I realize that is not ideal and there was a period of time when you were not following your requirement, but technically it's wouldn't be a direct violation of the code.

[ally1822]

Hope all is well with the audit preparations. Does BRC require quarterly Management Review? If they only require annual, and you currently identify that annual is adequate couldn't you just change the frequency to annually and conduct a meeting? I realize that is not ideal and there was a period of time when you were not following your requirement, but technically it's wouldn't be a direct violation of the code.

Hi ,our audit is in December each year so our company does an annual review every November to cover of everything from the last annual review meeting to implementing new problems through the year . We set an agenda of what we are going to discuss then minute the meetings . Be aware of new clauses in the standard like food safety culture and environmental monitoring make sure you discuss and mention them in your minutes. We had a minor last year over something similar although we spoke about it it wasn’t minuted . I hope this helps . We passed our audit from December with a AA GRADE I was pleased to say the least .


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[Kit2019]

We changed our policy for the senior management review meetings, since the BRC seems to have changed that requirement.

 

Now, we only have one annual senior mgmt meeting.

We have monthly (regular) management meetings.

 

The one snag that we had was the requirement for quarterly updates of the continual improvement objectives that would no longer be covered in our non-existent quarterly meetings. However, the guide specifies that this is a report. So I just create a quarterly report and turn that in to senior mgmt.

 

We are a pretty small company as well, luckily. I'm sure it would all be more complicated at a bigger organization.