BRC 2.11 - Is Corrective Action required for HACCP with no CCPs?

2.11

Establish a Corrective Action Plan

2.11.1

The HACCP food safety team shall specify and document the corrective action to be taken when monitored results indicate a failure to meet a control limit, or when monitored results indicate a trend towards loss of control. This shall include the action to be taken by nominated personnel with regard to any products that have been manufactured during the period when the process was out of control.

Hi all - I have just completed an internal systems audit of the HACCP / Food Safety Plan. The above-mentioned clause - 2.11.1 - is this applicable for plans that have no CCP's? We have no corrective action documented in the HACCP plan however we have no CCP's, only quality control points. Is this a non-conformance? I want to document the corrective action - even for just quality control points.  Any advice appreciated. 

2.11.1 is for CCPS, so if the plan does not have any ccps this section would not be applicable.  

certainly other non conformities need to be addressed for any item that puts quality and food safety at risk.   these may be more applicable in section 3.7 and or 3.8.

  I personally don't like putting quality control points in the haccp / food safety plan.    

I hope this helps.  

Hello, indeed N/A,

For IFSV7 (2.2.3.9 ), apply to CCPs as also other control measures

best regrds,

Leila

2.11.1 is for CCPS, so if the plan does not have any ccps this section would not be applicable.  

 

...

  I personally don't like putting quality control points in the haccp / food safety plan.    

 

...

 

 

I fully agree, it's just noise having the QCP's in there, but I've been bullied by enough auditors to include them that I now do.

I fully agree, it's just noise having the QCP's in there, but I've been bullied by enough auditors to include them that I now do.

The appropriate, definitively time-tested, response is simply - Where is this required in the Standard ?