6 replies to this topic

[BluePanda]

Hi all, according to the interpretation for the above clause "It is necessary to define the frequency of inspections and this may be done using industry standards, customer requirements, on the basis of risk or by a combination of these." My concern is that because our frequency changes depending on the job size and complexity, we don't really have a "defined" frequency. In our SOP we only state that quality checks are being done at "Regular intervals".  Will this be enough to satisfy the clause even though we don't have a defined frequency? Will I need to do a Risk Assessment on this changing Regular Intervals?

[Scampi]

Not BRC myself, but I know our federal regulatory body would not accept regular intervals. Ever

 

SQF won't either

 

What does work is language like

 

Once every 20,000 units    or      once every hour of operations

 

 

That way you've defined the frequency, but not the duration....

 

hope that helps

[pHruit]

Why not define per product/group or equivalent, as suited to your process?
I can't imagine that any BRC auditor will accept "regular intervals" as an actual frequency, but there is nothing that says your interval has to be a fixed universal value across all product types.

If you get a "new" type of job, just add this to your schedule as a new category, with its own set of suitable intervals/methods etc.

[Roshni]

Hi NHer, It is always advisable to define the frequency for testing. One of the method for defining the criteria for frequency is carry out risk assessment. 

 

Do the initial risk assessment, based on which define the frequency. Verify the effectiveness and revisit the process for any changes. Hope this helps.

[beautiophile]

[interval] = 1 / [frequency]

An industrial standard or customer requirements usually make a set of loose (long interval), medium and enforced (short interval) frequencies; or in more scales whatsoever. A risk assessment helps to decide what frequency level to pick from the set.

[BluePanda]

Thank you all for your advice. I guess my concern at the moment is defining that frequency without creating an issue for us.

 

the only thing I can state with confidence is that our operators does a make ready for every job at each process prior to starting production but the actual checks during production varies by the job quantity and operator experience hence the "regular interval". So they do the quality checks during production but its with varying frequency.

 

Would there be an encompassing phrase/statement that can satisfy this clause for this varying interval where it would not compromise what we are already doing in production?

[pHruit]

 

the only thing I can state with confidence is that our operators does a make ready for every job at each process prior to starting production but the actual checks during production varies by the job quantity and operator experience hence the "regular interval". So they do the quality checks during production but its with varying frequency.

 

Would there be an encompassing phrase/statement that can satisfy this clause for this varying interval where it would not compromise what we are already doing in production?

The bit in red is potentially problematic for you, unless you can show that everyone does the minimum (defined!) testing, and others choose to exceed this.

As far as I can see, the only way to have an all-encompassing phrase for this will be to use one that doesn't really say anything, but instead points the reader/operator to a separate schedule where you've defined actual frequencies.

I still think you'll need to put that associated schedule together, as a live document so you can add new products/variations/production sizes etc, but so that you also still have a clear an unequivocal list so that (a) you have something against which you can train people, and (b) you have something nice and clear to show to your BRC auditor(s).