BRC Non-Conformance clause 2.2.2
Afternoon,
We had our BRC audit last week and were hit with a non conformance for the following on our Declaration of Compliance.
The current Declaration of compliance includes date of issue and “regulation 10/2011 and its amendments,” without identifying which amendments are being referenced.
has anyone else had this issue? I cannot see anywhere in the BRC standard where I have to list all 15 subsequent amendments to the above clause. Our wording states "EC regulation 10/2011 and all subsequent amendments"
I look forward to your comments.
Thanks
Ian
Afternoon,
We had our BRC audit last week and were hit with a non conformance for the following on our Declaration of Compliance.
The current Declaration of compliance includes date of issue and “regulation 10/2011 and its amendments,” without identifying which amendments are being referenced.
has anyone else had this issue? I cannot see anywhere in the BRC standard where I have to list all 15 subsequent amendments to the above clause. Our wording states "EC regulation 10/2011 and all subsequent amendments"
I look forward to your comments.
Thanks
Ian
Hi Ian,
Packaging not my area but Packaging ver6/2.2.2 seems to be -
2.2.2 The HARA team shall maintain awareness of and take into account:
• historical, known and foreseeable product safety hazards associated with specific processes and raw materials
• intended use of the product (where known)
• known likely product defects that affect safety
• relevant codes of practice or recognised guidelines
• legislative requirement
Seems to be an attempt to transfer clause 2.3.2 from the food standard. Beautifully garbled IMO.
Afternoon,
We had our BRC audit last week and were hit with a non conformance for the following on our Declaration of Compliance.
The current Declaration of compliance includes date of issue and “regulation 10/2011 and its amendments,” without identifying which amendments are being referenced.
has anyone else had this issue? I cannot see anywhere in the BRC standard where I have to list all 15 subsequent amendments to the above clause. Our wording states "EC regulation 10/2011 and all subsequent amendments"
I look forward to your comments.
Thanks
Ian
This strikes me as exceptionally pedantic. In many years of doing BRC Food, I've never once been asked to specifically list all amendments to a cited regulation in the HACCP plan. It's fairly common practice throughout the UK and Europe to refer to regs in exactly the manner you have.
How did the rest of your audit go?
If this was your only minor then I might just take it on the chin, but if there are a few others then I'd potentially ask your cert body to review this one, as your written statement in your HACCP plan covers the requirement based on the views of pretty much everyone else I've so far encountered in the UK and EU industry.
The (unusually?) emphatic tone (eg closing paragraph) of the BRC's Interpretation material for this clause could be construed as supportive towards auditorial nitpicking.
Afternoon,
We had our BRC audit last week and were hit with a non conformance for the following on our Declaration of Compliance.
The current Declaration of compliance includes date of issue and “regulation 10/2011 and its amendments,” without identifying which amendments are being referenced.
has anyone else had this issue? I cannot see anywhere in the BRC standard where I have to list all 15 subsequent amendments to the above clause. Our wording states "EC regulation 10/2011 and all subsequent amendments"
I look forward to your comments.
Thanks
Ian
IMO, such NC about DoC content should belong to 3.4.3. Clause 2.2.2 asks HARA to consider any law requirement for DoC.
My company's DoCs also state EU 10/2011 with its amendments, and note in details some significant items such as SML, intended use. No specific amendments (number or date) are written.
Our auditor read and accepted our template.
The (unusually?) emphatic tone (eg closing paragraph) of the BRC's Interpretation material for this clause could be construed as supportive towards auditorial nitpicking.
I checked the Interpretation for BRC packaging after reading this and:
- I was right about my pointing to 3.4.3 in the above comment.
- They provide an example.
3.4.3 Example:
The supplier of plastic film for use in packaging breakfast cereals completes a statement of compliance for all its products which contains the following information:
- name and address of the manufacturer
- date of issue or version of the declaration
- product name/function, including the brand or trade name of the material where appropriate
- confirmation that the composition of the product complies with the requirements in the country of manufacture and use, where know
- information about substances that were used and for which legal limits or specifications exist in order to enable the downstream processor or the party responsible for the first placing on the market to adhere to these limitations (e.g. regarding specific migration limits or recycled content).
The statement of the compliance is specific to each product type and a procedure for the review of these statements is in place. Each declaration also contains a statement pertaining to the limitations on use (i.e. that the information contained in it is subject to change for further batches of the material and should only be used for the batch purchased, when purchasing from stock)
An auditor would find that this supplier is complying with the clause requirements.
Any idea?
Your auditor was trying to make himself look good (Either that or he wanted a list for himself and didn't want to go to the effort of researching it!)
I use much the same phrase as you but with the extension 'amendments to the date of this Declaration' and it has never been questioned by any auditor or customer.
On a similar point, if your market is in the UK, since Brexit, you need to state compliance with UK legislation, as on their own EU10/2011 etc no longer apply. Your pedantic auditor will probably then want you to list the Scottish, Welsh (and probably NI, but who knows what the latest is there) variants.