5 replies to this topic

[Jim E.]

We have had BRC certification for many years, but this year we have a twist!  We purchased a raw material storage facility that is off site.  It is less than 50km away (actually about 8km). Now I am wondering if we need to add it to the scope or put it in the exclusion list.  The production facility really has nothing to do with except for possibility that the raw will come to our plant for processing at some point. Much like our other growers who store their raw until we are to process it. The storage facility is controlled and monitored by the agronomy department and has Canada GAP certification as a storage facility.

 

Should I or should I not include this for upcoming audit?

 

Thanks

 

   

[QAGB]

I would say you should include it in the scope of your audit particularly if you do own the building. In a past life, I worked in a facility that had an offsite storage facility. We technically rented the building from others, so it wasn't outright "owned" by the company. We did have our workers working there, so it became a little tricky to explain to our auditors. They were ok with us keeping it off our scope by considering it outsourced space, which required us to have a service agreement signed by our leadership and the ownership of the outsourced space.  However, we treated it as an extension of our own company, and conducted GMP inspections monthly there. Any non-conformances with the building's structure or integrity had to be fixed by that space's ownership.

[SQFconsultant]

I see no reason to included an outsourced inbound storage facility in your scope.

[Charles.C]

ahem -

 

From BRC8 -

 

1.6.4  Storage facilities – off-site
While storage facilities on the same site as the production facility shall always be included within the audit of the site, it is not uncommon for sites to also own additional off-site storage facilities. Where additional storage facilities are owned and managed by the company in the vicinity of the production site (i.e. within a radius of 50 km), these shall be identified on the audit report and either audited as part of the site audit or specifically excluded.

 

 

 

3.5.3.1 There shall be a procedure for the approval and monitoring of suppliers of services. Such services shall include, as appropriate:
•  pest control
•  laundry services
•  contracted cleaning
•  contracted servicing and maintenance of equipment
•  transport and distribution
•  off-site storage of ingredients, packaging or products
•  off-site packing of products
•  laboratory testing
•  catering services
•  waste management.
This approval and monitoring process shall be risk-based and take into consideration:
•  risk to the safety and quality of products
•  compliance with any specific legal requirements
•  potential risks to the security of the product (i.e. risks identified in the vulnerability and food defence assessments).

 

 

4.2.3 Areas where a significant risk is identified shall be defined, monitored and controlled. These shall include external storage and intake points for products and raw materials (including packaging).
Policies and systems shall be in place to ensure that only authorised personnel have access to production and storage areas, and that access to the site by employees, contractors and visitors is
controlled. A visitor recording system shall be in place.
Staff shall be trained in site security procedures and food defence.

 

[QAGB]

Hi Charles, 

 

I feel as though the original poster understood that. They want to know if they should add it to their audit, or exclude it specifically (which one is best).

 

I would say add it to the scope because our auditors were always a bit iffy about scope inclusion/exclusion of our additional warehouse space. My point to the OP was to be sure they outright own the facility rather than renting the space, because there is some additional cloudiness to that if they don't really own it.

 

If I had to judge from a customer perspective, they'd probably rather the additional warehouse is included under the scope of the audit.

[Charles.C]

Hi Charles, 

 

I feel as though the original poster understood that. They want to know if they should add it to their audit, or exclude it specifically (which one is best).

 

I would say add it to the scope because our auditors were always a bit iffy about scope inclusion/exclusion of our additional warehouse space. My point to the OP was to be sure they outright own the facility rather than renting the space, because there is some additional cloudiness to that if they don't really own it.

 

If I had to judge from a customer perspective, they'd probably rather the additional warehouse is included under the scope of the audit.

 

Hi QAGB,

 

Yes, I noticed the "50km" but the post included zero x-ref. so some further context seemed useful.

 

TBH, I found the, IMO, critical last few words of 1.6.4 seriously ambiguous, ie whose choice ? (twist or bust ? ).(IIRC the BRC8 text/Guidelines on "exclusions"  consequences suggest BRC can potentially be quite aggressive as discussed in a recent thread here**). (Guilty unless proven innocent).

 

 Jim E, any comments ?.

 

PS - ** - see BRC Guidance quote in this Post -

 

https://www.ifsqn.co...an/#entry155638

(not sure if this includes external areas)

Edited by Charles.C, 04 March 2020 - 05:45 PM.
edited