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Why would a company exclude despatch from the scope of their BRC certification?

BRC Scope

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#1 Bigblue1878

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Posted 13 March 2020 - 04:04 PM

Hi,

 

I've been in food manufacturing for year and not come across this before. On 2 separate occasions recently I have reviewed a BRC certificate with the despatch of materials excluded from the scope. Why would someone do this and what benefits would a site receive from this exclusion?

 

Thanks



#2 pHruit

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Posted 13 March 2020 - 04:50 PM

These were BRC Food (i.e. manufacturing) certificates?
BRC have been a bit more robust, at least in theory, about what can or cannot be excluded from scope, although the standard largely refers to exclusion of products rather than processes such as despatch.

An exclusion might be in place because that part of the factory processes for customers / industries that don't require the certification, or being a touch more cynical, because it's been poorly invested in / maintained and might be difficult to get through a certification audit without actually investing a bit in it... ;)

 

Can you provide an example of the wording of one of the scopes and corresponding exclusions (without any details that might identify the certificate holder)?

Might allow us to make a bit more sense of it.



#3 Bigblue1878

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Posted 13 March 2020 - 04:55 PM

These were BRC Food (i.e. manufacturing) certificates?
BRC have been a bit more robust, at least in theory, about what can or cannot be excluded from scope, although the standard largely refers to exclusion of products rather than processes such as despatch.

An exclusion might be in place because that part of the factory processes for customers / industries that don't require the certification, or being a touch more cynical, because it's been poorly invested in / maintained and might be difficult to get through a certification audit without actually investing a bit in it... ;)

 

Can you provide an example of the wording of one of the scopes and corresponding exclusions (without any details that might identify the certificate holder)?

Might allow us to make a bit more sense of it.

Hi,

 

The certificate states:

 

 

 

 

Exclusions from scope:

Butter, powder, milk co-products (serum ...) and dispatch of finished product



#4 pHruit

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Posted 13 March 2020 - 04:58 PM

Hmm, interesting. Based on the BRC standard's requirements those products will be manufactured separately to those within scope. The broad "dispatch of finished product" wording is curious though. One could read this as meaning dispatch of the finished butter/power/milk co-products, or as a more general exclusion of the dispatch stage of all finished products.

The latter would be very surprising though, as that would surely be part of the process for the in-scope products. I think your only option may be to ask your supplier to provide further clarification!



#5 Bigblue1878

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Posted 13 March 2020 - 05:01 PM

Yeah we've done that and waiting for the agent to contact the site to gain the answer

 

Thanks



#6 SQFconsultant

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Posted 13 March 2020 - 06:35 PM

I have seen an exclusion for shipping/dispatch at a company and the reason was I found quite eye opening!

 

The customer that required the BRC certification was also the company that picked up the product using their own fleet of trucks - they did not want their dispatch information nor trucks and documentation with their trucks reviewed during an audit.

 

hmmm.


Warm regards,

 

 

Glenn Oster

 

 

Glenn Oster Consulting, LLC / 800.793.7042 / USA, Centro & South America

SQF System Development, Implementation & Certification Consultants

Food & Food Storage/Logistics // eConsultant // Internal Auditor Training

www.GlennOsterConsulting.com

 

 

Do it in 3 Steps on the 3rd to the 6th for $33.00...
 

#7 Charles.C

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Posted 13 March 2020 - 09:53 PM

Not entirely obvious what "despatch" actually means.

 

It could imply exclusion of clause 4.16. ??

And could have Traceability ramifications. ?? (eg 9.5.2)


Kind Regards,

 

Charles.C


#8 zanorias

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Posted 14 March 2020 - 08:49 AM

Not entirely obvious what "despatch" actually means.

 

According to the stadard's glossary BRC define it as:

"Despatch/dispatch The point at which the product leaves the factory site or is no longer the responsibility of the company."


 



#9 BillC

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Posted 14 March 2020 - 01:46 PM

That sounds a bit off to me as well.

 

It could be that a company is a 100% co-packer with product ownership, warehousing (including the ownership of any attached warehouse or loading dock) held by an arms length third party.  Even then an auditor should consider the hand-off point to be it's dispatch.

 

Sounds to me like a quality control error on the part of the Certification Body.



#10 pHruit

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Posted 14 March 2020 - 04:14 PM

I share Glenn's view to an extent - seem to encounter more "hiding things from prying eyes" style exclusions than legitimate ones.

 

Not entirely obvious what "despatch" actually means.

 

It could imply exclusion of clause 4.16. ??

And could have Traceability ramifications. ?? (eg 9.5.2)

I'd be fascinated to know how it works with regard to 4.16. Irrespective of the actual impact I think the exclusion is worded very poorly, and the auditor (and the review team back at the cert body) should have picked up on how fantastically ambiguous it is!

9.5.2 is only applicable for traded goods - 3.9.3 would be the equivalent clause in the main part of the standard. It's worded slightly differently, but the IG is clear that this should be audited via a test exercise to include dispatch. I'd find it odd if they could exclude any part of this, as really it's just a detailed way of covering what are largely formal legal obligations for any food business in the EU, as per Article 18 of Regulation (EU) 178/2002.

 

Overall I'd say the author of that exclusion deserves 1/10. The words are legible and form a sentence of sorts, but the meaning is surely too vague to actually be useful!


Edited by pHruit, 14 March 2020 - 04:14 PM.





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