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Can the Traded Products module still be excluded in issue 6?

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smart17

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Posted 29 January 2020 - 09:28 AM

Dear all, 

 

I am preparing for the ISSUE 6-Packaging Products for the BRCGS. 

In ISSUE 5 the traded goods module could been excluded . 

Is it the same for ISSUE 6 can been excluded or its compulsory?

 

Kind Regards 

 



nwells1024

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Posted 29 January 2020 - 11:53 AM

There was not traded product section in issue 5 of the standard; was there a standalone document/module which specified similar requirements?  If so, we were never audited against it in the past 3 years since our certification.  I would think that now that it is an entire section of the standard, it will not be so simple to risk assess out of your scope.  My recert audit isn't until June though so I cannot say with any certainty.



LILDANNY50

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Posted 29 January 2020 - 11:59 AM

Hi Smart17, 

 

Please see below material quoted from BRC issue 6 packaging: 

 

'Products purchased for resale by a site (i.e. traded products) can form an agreed exclusion and therefore the requirements of section 7 (Part II) will not be applicable. It should be noted that the BRCGS logo cannot be used for promoting traded products even when they form part of the certificated scope.'

 

This is on page 70 of the latest packaging standard. 

 

Thanks



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pHruit

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Posted 29 January 2020 - 12:54 PM

There was not traded product section in issue 5 of the standard; was there a standalone document/module which specified similar requirements?  If so, we were never audited against it in the past 3 years since our certification.  I would think that now that it is an entire section of the standard, it will not be so simple to risk assess out of your scope.  My recert audit isn't until June though so I cannot say with any certainty.

 

Scope exclusions aren't about risk assessment for BRC - I'd suggest reading page 70 (in Part III - audit protocol) of the standard.

For manufacturing operations you can only have exclusions in specific circumstances; it must be possible to easily differentiate from products within scope and they must be produced in a physically segregated area of the factory. Broadly this is to stop sites using exclusions as a bodge to make the audit easier whilst trying to still pass off all products as "BRC certified". (Yes, I know BRC doesn't certify the products, and yes, I have seen food manufactures use this type of tactic ;) ).

 

As LILDANY50 noted above, traded goods are slightly separate to this and can be an agreed exclusion without any specific risk assessment or similar - your choice is to comply with the requirements in the new section, or have your certificate for Issue 6 show an exclusion on it. It's pretty much identical to the food standard in this approach.



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