11 replies to this topic

[Sarahr78]

Hi all, just wondering if any of you have had chance to review the new Storage and Distribution standard and if you had any comments? I would be interested to see your views.

 

Thanks 

[babsbesafe123]

Hi Sarah

 

I didin't see your post before and started my own thread but haven't had any replies either - I work with a number of SME's handling fresh fruit & produce and am really disappointed to see that the standards continue to become more bureaucratic and requiring resources that small businesses simply don't have. I appreciate that BRCGS are moving towards GFSI but some of the new requirements go way over & above what food businesses are required to do by law and may require considerable financial investment at a time when the industry is really struggling due to repercussions from Covid.

 

In addition to that, I've noted that within exclusions from Scope, the cutting and trimming of fresh produce are now stated despite, as I understand it, a number of objections raised against it at consultation stage. My food safety consultancy work is mainly with market based fruit & vegetable suppliers and this will have a major impact on them going forward.

 

This will mean that any market based fruit & veg suppliers will either continue their (very low risk) practice of improving the quality/presentation of the vegetables by trimming the occasional leaf of a head of cauliflower and no longer have use of the BRCGS logo because of an exclusion from scope or will see an increase in rejections of product for quality reasons because customers will receive products that may not meet their specifications with regard to quality of appearance!

 

I've contacted BRCGS about this but would appreciate feedback from anyone else out there who may be facing this issue?

 

What do you think to the Issue 4 revisions?

 

Kind regards

 

Barbara Evans

Edited by babsbesafe123, 25 November 2020 - 01:23 PM.

[Foodworker]

There are a number of requirements that I don't like, but the one which is annoying me most at the moment is 10.1.1.1 under the Wholesale Module.

 

It states "The company shall be able to trace all product lots back to the last manufacturer and forward to the customer of the company"

 

This clause is applicable to both wholesaler own brand and generic branded products. Bearing in mind that the Standard can cover foods and all manner of non foods and consumer products, if you are a wholesaler you may be selling products ranging from shampoo to yogurts under massive international brands like Unilever, Procter & Gamble, Heinz etc made in literally thousands of factories around the world, some owned by these brands and some sub-contracted

 

The definition of 'Manufacturer' in the Glossary makes it clear that the manufacturer is the producing factory and not the brand owner.

 

The chances of Unilever telling a small wholesaler which factory they use to make their shampoo is nil, even if you could find the right person to ask.

 

I would challenge Tesco, Sainsbury, Walmart  and any other large retailer to be able to do it.

 

The clause as it is written (and therefore audited) is impossible to be complied with.

[babsbesafe123]

There's a simliar issue with the fruit and veg as you would normally trace back to your supplier but the new wording requires that traceability has to be extended either back to the packing plant or to the grower themselves. Even if suppliers would release that information, much of which is commercially sensitive, the potential for being able to get responses within 24 hours is nigh on impossible. The irony is that within 15 years of working in this industry, there have been only about 5 actual recalls relating to this type of product so it's not even frequent enough, in my opinion, for it to be an issue.

[babsbesafe123]

I would add that I purchased a copy of the interpretation guidelines yesterday (£125 for a digital pdf???) and it did help to clarify some of the clauses and what BRCGS need to be satisfied they are being met. I'm still foxed by the clause relating to demonstration of safety culture, how on earth does that get applied to a family run business with less than 10 employees!!

[Foodworker]

What do the Guidelines say about traceability on generic branded products?

 

I have no problem with the level of traceability on wholesaler own brands, but for generic brands it is unworkable.

 

It is a specific change from the previous version of the Standard which only had the requirement for wholesaler own brands

 

I probably will buy a copy but I am saving up my pennies.

[Foodworker]

Apart from being quite a nice advert for Peak Logistics, I can't see how the link helps with the previous posts.

[Charles.C]

Apart from being quite a nice advert for Peak Logistics, I can't see how the link helps with the previous posts.

 

Thks. Corrected.

[babsbesafe123]

"Foodworker" you can have this one on me....

10.1 General requirements applicable to all wholesalers

10.1.1 Traceability The wholesaler shall be able to trace all product lots back to the last manufacturer and forward to the customer of the company.

Clause Requirements 10.1.1.1 The company shall maintain a traceability system for all batches of product which identifies the last manufacturer or, in the case of primary agricultural products, the packer or place of last significant change to the product. Records shall also be maintained to identify the recipient of each batch of product from the company.

 

STORAGE AND DISTRIBUTION ISSUE 4 INTERPRETATION GUIDELINE brcgs.com 139 Part I Part II Appendices Clause Requirements Interpretation A traceability system needs to be established at all stages of the process, identifying the manufacturer from whom products have been supplied and to which customers they have been supplied. With regard to the traceability of branded products (section 10.2), the level of traceability shall cover the site operation and one step up (or the immediate upline customer) and one step down (or the first downline customer). There is no requirement within the test to trace beyond this or to contact suppliers or recipients. The traceability system must ensure that products supplied to customers are adequately labelled or identified to facilitate traceability. Traceability details need to be retained in a format that allows access in timely manner. The Standard expects full traceability from the last manufacturer or, in the case of agricultural products, the packer or last significant change of the product. The traceability system must also identify the customer (i.e. to whom the product was sent) and all steps within the process for which the company has responsibility (e.g. if the product is subcontracted for storage, or if there is further processing or relabelling, then these steps must be included). 

[Foodworker]

Thank you.

 

The one step back/one step forward is what I hoped it would say.

 

It does beg the question as to why they use the word 'manufacturer' in the clause rather than supplier.

 

I also like that they have stated that customers and suppliers do not need to be contacted as part of the test. I have had countless arguments with auditors on this.

[babsbesafe123]

I think the requirement to contact customers is more a test of the recall/withdrawal procedures. I've had the same discussions at audit and it varies depending on who the auditor is. I think that if you can demonstrate that you are able to contact the customer (i.e., select 2 or 3 of the Traced" customers, send a test email saying that you're testing your recall alert systems and ask them to confirm receipt), that should satisfy the auditor.

[Foodworker]

What I do now is identify the customer through the traceability system and send a mail saying that we are updating records and want to confirm the correct contact details in event of a problem. That demonstrates that we are able to contact the customer correctly and serves some purpose at least.

 

I have had auditors wanting to find which customers that our customers have sold on to until I tell them where to get off. That is the customers' systems being challenged not ours.

 

I have been in companies where they have received a recall notice as part of test and despite it clearly saying 'TEST' or similar, they have started quarantining materials and products. If you shut down a production line because of a misunderstanding you will quickly lose friends and stopping something like the Heinz baked bean line will cost you millions.