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#1 Ingredients55

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Posted 10 March 2020 - 11:37 AM

Hello,

I know there is few topics like this but i haven't seen any of them giving a clear answer.

 

So.. we have recently had our BRC audit. we have HACCP fully developed & implemented. we are agents, we do not handle any products, etc.

The auditor said our HACCP flow is too complex and we have too much details included.

 

What would be your suggestion for a short HACCP flow ? Purchase - Transport/ Storage- Delivery ?

 

Could somebody attach any example ?

 

Thank you in advance :) 

 



#2 pHruit

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Posted 10 March 2020 - 11:47 AM

In the words of some bloke called Albert: Things should be as simple as possible, but not simpler ;)

Is the auditor's complaint that you have physically included things that aren't relevant, and given specific examples of things he believes fall into this category, or that the presentation is overly complex?
It might help if you can share a copy of the flow diagram (after stripping out any identifying features if needed) so we can get an idea what's going on.

When we first prepped for A&B I came to the conclusion that our process flow was in danger of heading in the direction that it sounds like yours might have done - we had a lot of different activities to cover. We therefore broke the overall plan down into modular "chunks", each of which is more easily understood, and the main flow diagram then also looks relatively simple as it's simply constructed of blocks representing these different modules. FWIW every auditor since our first go at Issue 1 of the standard has been happy with this, and it's also doubled as a useful teaching aid for new starters in some areas, to get an idea of what physically happens in that part of the business.



#3 etsang06

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Posted 10 March 2020 - 01:28 PM

I haven't had the BRC audit yet, but I've just finished coming up with the policy and flow diagrams for this section.

What I basically did was have 1 main process flow for our broker company that includes steps like product development, supplier approval, purchasing, logistics, to delivery to customer. And then i have separate process flows for every item that we deal with. 

Can someone let me know if that is correct or OK?

 



#4 pHruit

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Posted 10 March 2020 - 02:20 PM

I haven't had the BRC audit yet, but I've just finished coming up with the policy and flow diagrams for this section.

What I basically did was have 1 main process flow for our broker company that includes steps like product development, supplier approval, purchasing, logistics, to delivery to customer. And then i have separate process flows for every item that we deal with. 

Can someone let me know if that is correct or OK?

It sounds as though you may be making this more complex than necessary, but only you are able to actually determine whether that is the case.

What do the individual flow diagrams show that the main flow doesn't? If the differences are that significant, is the main flow going to be useful or just confusing?

Are these processes genuinely different (in terms of the nature of the steps and associated hazards) for every single product, or could they at least be categorised into a smaller number of groups of products/processes with sufficient similarity to be assessed together?

You may be able to look at e.g. a single flow with multiple routing options to cover similar but slightly different products, or potentially split into groups each of which has their own flow and potentially own HACCP plan - the latter would not be at all uncommon in a manufacturing environment for different processes, so there is no reason you shouldn't be able to do this as an agent, if it's what is required to accurately characterise and risk-assess the process.

If you can provide a bit more information about the product range, and perhaps attach the current flow diagrams (or a few examples of these) then we might be able to provide more detailed feedback and suggestions.



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#5 etsang06

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Posted 10 March 2020 - 02:46 PM

It sounds as though you may be making this more complex than necessary, but only you are able to actually determine whether that is the case.

What do the individual flow diagrams show that the main flow doesn't? If the differences are that significant, is the main flow going to be useful or just confusing?

Are these processes genuinely different (in terms of the nature of the steps and associated hazards) for every single product, or could they at least be categorised into a smaller number of groups of products/processes with sufficient similarity to be assessed together?

You may be able to look at e.g. a single flow with multiple routing options to cover similar but slightly different products, or potentially split into groups each of which has their own flow and potentially own HACCP plan - the latter would not be at all uncommon in a manufacturing environment for different processes, so there is no reason you shouldn't be able to do this as an agent, if it's what is required to accurately characterise and risk-assess the process.

If you can provide a bit more information about the product range, and perhaps attach the current flow diagrams (or a few examples of these) then we might be able to provide more detailed feedback and suggestions.

 

Because as a broker we don't handle the food, I felt like we needed a separate process flow. All the other individual process flows are manufacturing related. I attached our broker process flow and a process flow of a product that we deal with (wine).

 

Can I get some ideas of what others are doing?

Attached Files



#6 pHruit

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Posted 10 March 2020 - 02:54 PM

Because as a broker we don't handle the food, I felt like we needed a separate process flow. All the other individual process flows are manufacturing related. I attached our broker process flow and a process flow of a product that we deal with (wine).

 

Can I get some ideas of what others are doing?

Ah, ok, now I understand.
For the BRC Agents & Brokers requirements in section 2 of the standard, you can effectively "ignore" the manufacturing part of the process - that bit would be generally be considered as a prerequisite within the supplier approval (section 4.1), and you're not expected to duplicate/replicate the HACCP system that your suppliers already (hopefully!) have in place.
The process flow diagram you're constructing therefore really only needs to relate to the activities within the scope of your control, so this might be from collection at factory gates, through customs processes, storage, transport etc - the exact scope will obviously depend on the products, the incoterms you work with etc.

 

In terms of your broker flow diagram, I wouldn't be scare about repeating steps to show the actual flow - for example, if you put stock into a warehouse, how does it then get to the customer? You can insert another transport step after it, even if you state in your hazard analysis etc that it's a "copy" of the other transport steps.

In terms of warehouse processes you could potentially break this down further - e.g. loading, palletising, temp-controlled storage etc if applicable.

The main thing I'd note if you're already familiar with "real" HACCP for manufacturing is that BRC in this context may be looking for all sorts of things that are "hazards" outside the scope of normal food safety ones, e.g. paperwork required for customs clearance, so you'll want to show you've considered all the steps where such things can occur and correspondingly included this in the hazard analysis.



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#7 Ingredients55

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Posted 10 March 2020 - 03:07 PM

Thank you for all the answers, any other examples of the Agents & Brokers HACCP flows and RAs?



#8 etsang06

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Posted 10 March 2020 - 03:14 PM

Ah, ok, now I understand.
For the BRC Agents & Brokers requirements in section 2 of the standard, you can effectively "ignore" the manufacturing part of the process - that bit would be generally be considered as a prerequisite within the supplier approval (section 4.1), and you're not expected to duplicate/replicate the HACCP system that your suppliers already (hopefully!) have in place.
The process flow diagram you're constructing therefore really only needs to relate to the activities within the scope of your control, so this might be from collection at factory gates, through customs processes, storage, transport etc - the exact scope will obviously depend on the products, the incoterms you work with etc.

 

In terms of your broker flow diagram, I wouldn't be scare about repeating steps to show the actual flow - for example, if you put stock into a warehouse, how does it then get to the customer? You can insert another transport step after it, even if you state in your hazard analysis etc that it's a "copy" of the other transport steps.

In terms of warehouse processes you could potentially break this down further - e.g. loading, palletising, temp-controlled storage etc if applicable.

The main thing I'd note if you're already familiar with "real" HACCP for manufacturing is that BRC in this context may be looking for all sorts of things that are "hazards" outside the scope of normal food safety ones, e.g. paperwork required for customs clearance, so you'll want to show you've considered all the steps where such things can occur and correspondingly included this in the hazard analysis.

 

Thanks pHruit! That makes a lot of sense. 

For the hazard analysis, I had only considered doing it on the actual food products that we deal with. So now I have to do one for our company's process flow.....

Looks like I have a lot of fixing up to do haha

Does anyone have a hazard analysis for the broker process that they can share? 



#9 pHruit

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Posted 10 March 2020 - 06:30 PM

Thanks pHruit! That makes a lot of sense. 

For the hazard analysis, I had only considered doing it on the actual food products that we deal with. So now I have to do one for our company's process flow.....

Looks like I have a lot of fixing up to do haha

Does anyone have a hazard analysis for the broker process that they can share? 

It's an understandable mistake, as the manufacturing end of things is the point at which one would traditionally apply HACCP.

I can't share our RA details as I'm contractually prohibited from doing so, but I would advise reading the interpretation guide section on this, and then reading it again a couple more times.

My experience has been that auditors will look at the broader stuff that is ambiguously dumped into the last bit of 2.6 - the fraud/malicious contamination bits are arguably also a bit incongruous within the context of HACCP, but they are included in the BRC Food standard too so a little less surprising. Hazards from "relevant regulatory authorities" is one to consider in detail, as it's an easy area to get caught out on since these may be "hazards" that have no bearing on safety or quality of the actual product. I've no idea what those might be for Canada, but for UK/EU purposes things like phytosanitary certificates, health certificates etc would be items where an absence of these would potentially be a regulatory "hazard". Broadly you're potentially looking at the necessary paperwork element in addition to the physical product itself.



#10 etsang06

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Posted 10 March 2020 - 07:19 PM

It's an understandable mistake, as the manufacturing end of things is the point at which one would traditionally apply HACCP.

I can't share our RA details as I'm contractually prohibited from doing so, but I would advise reading the interpretation guide section on this, and then reading it again a couple more times.

My experience has been that auditors will look at the broader stuff that is ambiguously dumped into the last bit of 2.6 - the fraud/malicious contamination bits are arguably also a bit incongruous within the context of HACCP, but they are included in the BRC Food standard too so a little less surprising. Hazards from "relevant regulatory authorities" is one to consider in detail, as it's an easy area to get caught out on since these may be "hazards" that have no bearing on safety or quality of the actual product. I've no idea what those might be for Canada, but for UK/EU purposes things like phytosanitary certificates, health certificates etc would be items where an absence of these would potentially be a regulatory "hazard". Broadly you're potentially looking at the necessary paperwork element in addition to the physical product itself.

 

Thanks for the insight pHruit! I just purchased the Interpretation Guide to help me on this as well! Really appreciate it :)



#11 etsang06

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Posted 18 March 2020 - 03:11 PM

Do all services listed in the scope need to be on the process flow diagram?

For example, we have one customer who we subcontract a printing company to print labels for them. But that is only for 1 small customer and I don't feel like it belongs on our big process flow.

Also upon customer request, we send out samples to testing to our 3rd party lab. Does that need to be on the process flow if it only happens once in while?

 

If I do have to put "Printing" and "Testing" on the process flow diagram....how can I show it so that it doesn't look like it is a mandatory step?

 

Appreciate anyone's input. Thanks!!



#12 pHruit

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Posted 18 March 2020 - 04:08 PM

Do all services listed in the scope need to be on the process flow diagram?

I'd read 2.4 / 2.5 as implying that yes, they do all need to be on the flow diagram / within the HACCP plan.

For these type of processes that aren't always used, I'd consider using a dotted line and labelling it as "optional", and/or having other routing lines showing that the step can be skipped sometimes. I'd also refer to it in you description of services under the last point of 2.4, noting that it is only an occasional thing.



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