17 replies to this topic

[Bansal]

Goodmorning Everyone,

 

Wanted to check with that do we need to update the review date of SOPs and policies if it is  three year or more than three year old, even though there are no changes?

 

 

Thanks in advance!

[olenazh]

Not sure about BRC, but with FSSC22000 I review all my SOPs annually and record it. Even if there's no change - just write "Annual review. No changes" What I noticed - the auditors have always paid particular attention to this matter.

[Setanta]

Agree with Olenazh.  

You should review annually to check (verify)   that there aren't any changes to your facility and that it matches the current level of SQF you want to be certified at.

[Scampi]

if you haven't reviewed the SOPs in 3 years, how could you possibly know that nothing has changed???

 

I review my entire plan annually regardless of the GFSi's requirements are

[Bansal]

sounds perfect, so you mean i do need to update review date and  in revision history i can write Annual review.. right?

[Bansal]

hi Scampi, answer to your question is that we update immediately SOP/Policy if there are any changes and if there are no changes then No updating.

 

That's what i was doing so far but i liked every body's idea too to update every year.

[nwilson]

Currently with SQF and there is a checklist from SQFI that we use to audit all documents in the system with on an annual basis.  This checklist serves as the review portion and is signed off per code section when completed.  If a document is reviewed and there are no updates either per internal review or per SQF code then the document is left as is and is deemed compliant in the checklist table.  If you are using change control in the document(s) themselves such as a table to signify your updates you could use this to state reviewed and no changes needed as well.  Our documents list the: last date the document was updated , version #, and the original creation date.  I would assume that an annual review would be the standard as the entirely of your program should be audited on an annual basis (SQF Requirement).  

[Scampi]

hi Scampi, answer to your question is that we update immediately SOP/Policy if there are any changes and if there are no changes then No updating.

 

That's what i was doing so far but i liked every body's idea too to update every year.

 What happens over time as a company grows, is that changes happen that you may not be aware of.........the only way to capture them is to review annually

 

I have a calendar that breaks the entire SQF scope across 11 months (pre audit month is audit prep only)  and I just follow the calendar et voila!

[Bansal]

Wow! this means we need to review annually for sure, but no need to update date or version, if there are no change just record in SQFI document. But BRC does not such document .. so what you say do i need to update date  on every document and just wondering version too since there are no changes?

 

Currently with SQF and there is a checklist from SQFI that we use to audit all documents in the system with on an annual basis.  This checklist serves as the review portion and is signed off per code section when completed.  If a document is reviewed and there are no updates either per internal review or per SQF code then the document is left as is and is deemed compliant in the checklist table.  If you are using change control in the document(s) themselves such as a table to signify your updates you could use this to state reviewed and no changes needed as well.  Our documents list the: last date the document was updated , version #, and the original creation date.  I would assume that an annual review would be the standard as the entirely of your program should be audited on an annual basis (SQF Requirement).  

 

Wow! this means we need to review annually for sure, but no need to update date or version, if there are no change just record in SQFI document. But BRC does not such document .. so what you say do i need to update date  on every document and just wondering version too since there are no changes?

Wow! this means we need to review annually for sure, but no need to update date or version, if there are no change just record in SQFI document. But BRC does not such document .. so what you say do i need to update date  on every document and just wondering version too since there are no changes?

[Bansal]

 What happens over time as a company grows, is that changes happen that you may not be aware of.........the only way to capture them is to review annually

 

I have a calendar that breaks the entire SQF scope across 11 months (pre audit month is audit prep only)  and I just follow the calendar et voila!

[Bansal]

 

 What happens over time as a company grows, is that changes happen that you may not be aware of.........the only way to capture them is to review annually

 

I have a calendar that breaks the entire SQF scope across 11 months (pre audit month is audit prep only)  and I just follow the calendar et voila!

 

Thanks Scampi!

[Setanta]

You said, "Wow! this means we need to review annually for sure, but no need to update date or version, if there are no change just record in SQFI document. But BRC does not such document .. so what you say do i need to update date  on every document and just wondering version too since there are no changes?"

 

 

 

If you aren't documenting that you performed a review, or whatever you've done, it didn't happen. Not in the eyes of most auditors anyway.  You can simply add Reviewed 2/2/22-with initials

Edited by Setanta, 27 January 2022 - 11:27 AM.

[Scampi]

Setanta as usual is spot on..............whether you initial and date each SOP at review, or create a separate reassessment/review log, you must document it

 

Also, FDA/USDA also have requirements...............everyone seems to forget that

 

The Food Safety Plan Builder guides the user through the following sections:

• Facility Information
• Preliminary Steps
• Good Manufacturing Practices (GMP) & Prerequisite Programs
• Hazard Analysis & Preventive Controls Determination
• Process Preventive Controls
• Food Allergen Preventive Controls
• Sanitation Preventive Controls
• Supply-Chain Preventive Controls
• Recall Plan
• Reanalysis of Food Safety Plan

[Charles.C]

Goodmorning Everyone,

 

Wanted to check with that do we need to update the review date of SOPs and policies if it is  three year or more than three year old, even though there are no changes?

 

 

Thanks in advance!

Hi Namishka,

 

A rather trivially simple 2 questions -

 

Which clause(s) in the Standard is this query/thread dealing with ?

 

Assuming a Clause exists, have you already looked at the appropriate section  in BRC/ I.G. ?

[Bansal]

Hi Namishka,

 

A rather trivially simple 2 questions -

 

Which clause(s) in the Standard is this query/thread dealing with ?

 

 

Assuming a Clause exists, have you already looked at the appropriate section  in BRC/ I.G. ?

Good question Charles!

 

To be honest, I don't see any clause saying that every year SOP/policies apart from quality policy and objectives, need to be reviewed, that's why i am confused and checking with IFSQN experts.

 

Still idea's poured in here are really great and appreciable!!

 

BRC clause 3.2.1 says only documentation control not necessarily that every SOP need to be reviewed every year.

 

Please correct me if i m wrong.

 

Thanks in advance!

[MlissaB]

A number of our sites are BRC Packaging certified. We just recently made the change from annual review of documents to every two years, unless otherwise required, e.g. HACCP, GMPs etc. This was based on many factors. We have a number of sites that are co-packers and that side of the business, many of which are FDA FFR or FDA Med Dev registered, and they have their docs on a 2 year review cycle so we are aligning to their process. We have also had established documents for a number of years and are finding that the large majority of them are settled to the point where they are not changing so the annual reviews become an unnecessary and non-value added drain on resources. We use an on-line software for our Quality Management Documents which drives this so all reviews are recorded there so it's easy to see how many times a document has been reviewed without changes and/or what those changes were. I believe regularly scheduled reviews are crucial, I just don't see that annually is necessarily required, unless of course, you are audited to a standard that requires it.

[sqflady]

While there is no requirement to annually update the date, that is still the expectation of many customers.  If you do choose not to update the date annually, I would suggest preparing a statement saying that all documents are valid for a period of "2 years, 3 years, etc.  If a change is made, a revision will be issued".  

[Charles.C]

Goodmorning Everyone,

 

Wanted to check with that do we need to update the review date of SOPs and policies if it is  three year or more than three year old, even though there are no changes?

 

 

Thanks in advance!

Hi Namishka,

 

Believe it or not, the word "review" occurs 243 times in the Standard !

"haccp review" occurs 14 times on its own.

In contrast the acronym  SOP does not appear at all. (Probably because it's American origin ?) I interpret is as ISO Procedure, Work Function, PRP etc

 

The significance is that whether a SOP must be reviewed (with ancillary documenting, eg Post 12) may relate to the specific SOP/Policy.

 

For example, assuming SOPs are involved in the following  -

 

3.5.1.1 At a minimum risk assessments must be reviewed every 3 years

. (ie frequency  >= 1 / 3 year)

3.6.4 Specification review shall be sufficiently frequent to ensure that data is current or at a minimum every 3 years, taking into account product changes, suppliers, regulations and other risks.Reviews and changes shall be documented.

4.2.2 Where raw materials or products are identified as being at particular risk, the threat assessment plan shall include controls to mitigate these risks. Where prevention is not sufficient or possible, systems shall be in place to identify any tampering. These controls shall be monitored, the results documented, and the controls reviewed at least annually.

4.11.8.3 The company shall review the environmental monitoring programme at least annually and whenever there are:

etc etc

 

So a "Vanilla" suggestion could be to simply define a Procedure stating that Review Frequency where applicable is compliant with the Standard's requirements.

 

Offhand, I don't recall seeing any mandatory review frequencies more than once per year other than those triggered by the usual "a Change Occurred" caveat.

 

So, additionally (bravely), could  add to the Vanilla above something like -  and elsewhere at a minimum of every "X" years. (I anticipate that auditors will not quibble with X = 1 but may if more "creative"). (the "where applicable" is still implicitly included, ie user's option).

(BRC would probably adore to see a generic "risk-based" in the above text but that would be pure narcissism IMO)

 

PS - life is surely easier here if you have software, eg -

https://help.mypolic...ocument-reviews

 

PPS -  I rather liked this generic opinion (where applicable) -

I recommend companies should document in their QMS that management reviews shall be held at least annually. This statement allows businesses to carry out more frequent reviews where a risk presents itself such as product recall, process change or supplier issues while also not committing themselves to unnecessary more frequent reviews.
https://antarisconsu...eview-meetings/
(No affiliation)