BRC clause 5.2.1 gaps not identified by the BRC Auditor

BRC certified facility

I recently discovered while I was reviewing the R&D procedure to approve new products and control formula changes that clause 5.1.2 was not respected. Basically I found absence of compliance in the following aspects: All new products and changes to product formulation, packaging or methods of processing shall be formally approved by the HACCP team leader or authorized HACCP committee member. Many of the steps in the risk analysis process was performed by R&D personnel but not following haccp analysis. Quality staff was focused on new supplier approval and general reviewer but they have not the leadership that clause 5.1.2 requiers as main approval.

My question: is this finding a noncompliance one? Because the plant is certified as BRC A+ version 8.

Is it possible that BRC auditor minimized the impact of this finding?

Treat your findings as an internal non-conformance and action accordingly so that you are compliant to the standard.  Auditors including BRC do sometimes miss things.

Thanks for the comments. I agree. It is likely to happen during such a big audit like BRC ones, you’ll miss something.  An ol’ auditor friend of mine used to say: “auditors are also human”.

Write yourself a nonconformance

• decide your NC status where you feel it should be - Critical, Major, Minor,
• correct the program and verification documents
• follow-up on the CAPA to ensure it has been completed and is effective.