6 replies to this topic

[suresh5192]

Dear all,

good day

 

             Iam Suresh from India, recently we have completed BRC audit, during the audit auditor was  raised a NC against 2.7.1 Fraud and malicious contamination of products are not considered in hazard analysis. any body having this please advise 

 

 

 

thanks in advance for your help.

[pHruit]

You'll probably need to include these as additional types of hazard in additional to the usual physical/chemical/micro/allergen hazards. I added two new hazard types. You can then include these in your hazard analysis for relevant steps in your process flow.

To be honest the whole exercise feels a bit like BRCGS wanted to cram them into the "HACCP" section for the sake of looking like it's still high on the agenda, as it seems a bit strange to me given that separate systems to control these types of risk are already effectively mandated by section 4.2 and 5.4.

You may well therefore find that each step in your hazard analysis at which a potential risk appears, is already controlled by these existing systems as part of your prerequisites. Nonetheless you'll need to jump through the hoops of documenting as much within your HACCP plan itself

[Charles.C]

Dear all,

good day

 

             Iam Suresh from India, recently we have completed BRC audit, during the audit auditor was  raised a NC against 2.7.1 Fraud and malicious contamination of products are not considered in hazard analysis. any body having this please advise 

 

 

 

thanks in advance for your help.

afaik HACCP Codex (eg as claimed to be implemented by BRC) is solely interested in Process Safety (NOT Quality, etc) related hazards and does not involve fraud type scenarios. Or malicious contamination.

 

BRC maybe concocted their version of Codex HACCP to match the the scope of their (equally questionable) "risk assessment" in section 3.5.1.1 Unfortunately "fraud"  in 3.5.1.1 (see Glossary)  is (deducibly) not strictly the same as "fraud" in 2.7.1.

 

The BRC Guidelines to 2.7.1 are suspiciously "muted" over these add-ons.

 

The Prerequisite route as suggested in previous Post seemingly offers the least argumentative way out of this "waste of paper".

[Kara S.]

The auditor was looking to see if you considered any potential food fraud with your ingredients like these examples: 

• Melamine in Milk 
• https://www.ideagen....ever-pulled-off

Not all food fraud is a risk to health but may just be for economic gain. To correct the non-conformance, take a look at your suppliers and ingredients to see if any of them are known to have had issues with this in the past, if any could cause harm to your consumer, and how you might monitor it if there is a potential risk. 

[Charles.C]

The auditor was looking to see if you considered any potential food fraud with your ingredients like these examples: 

• Melamine in Milk 
• https://www.ideagen....ever-pulled-off

Not all food fraud is a risk to health but may just be for economic gain. To correct the non-conformance, take a look at your suppliers and ingredients to see if any of them are known to have had issues with this in the past, if any could cause harm to your consumer, and how you might monitor it if there is a potential risk. 

Hi Kara,

 

It is a criticism of BRC that for Food Fraud, just as for some other sections like weight control, they are attempting to provide a due diligence document  for UK purposes in addition to satisfying GFSI. This is in contrast to SQF and FSSC22000.

[Kara S.]

Hi Kara,

It is a criticism of BRC that for Food Fraud, just as for some other sections like weight control, they are attempting to provide a due diligence document for UK purposes in addition to satisfying GFSI. This is in contrast to SQF and FSSC22000.

So Charles, are you saying that they are just looking for a blanket statement about food fraud and not something as in depth as I described?

[Charles.C]

So Charles, are you saying that they are just looking for a blanket statement about food fraud and not something as in depth as I described?

Hi Kara,

 

Also see Post 3.

 

My own criticisms of BRC Food Safety Standard include that BRC8 specifically states (see 2.7) that their following material is equivalent to Codex HACCP. It is patently not, eg with respect to fraud and malicious contamination (In fact BRC's current HACCP format harkens back to the HACCP style of the  ca.1980-1990s which was subsequently abandoned via Codex/NACMF et al).

 

In respect to Fraud itself, historically this has gradually become a semantic and interpretive nightmare for GFSI who were obliged to modify their original definition such that  BRC8's definition (see the Glossary) is now no longer aligned with GFSI. BRC issued a monograph detailing their interpretation of food fraud which, as suggested by the Glossary def. does not require a specific safety-related characteristic.

 

JFI - these are, afaik, GFSI's original and (current) modified definitions of Food Fraud -
 

 

“Food fraud, including the subcategory of economically motivated adulteration, is of growing
concern. It is deception of consumers using food products, ingredients and packaging for
economic gain and includes substitution, unapproved enhancements, misbranding,
counterfeiting, stolen goods or others.” (GFSI, 2014)

 

 

“Food fraud: A collective term encompassing the deliberate and intentional substitution,
addition, tampering or misrepresentation of food, food ingredients or food packaging, labelling,
product information or false or misleading statements made about a product for economic gain
that could impact consumer health.” (GFSI Benchmarking Requirements, 2017)

 

 

Returning to the OP, yr investigative suggestion is fine IMO but it is probably easier to move these 2 haccp aliens to a simple extension column in the Fraud (vulnerability assessment) in section  5.4.2 (or [yet again !] in para 3.5.1.1) in (my) anticipation of a long string of NRSRs (No Reported Safety Risks). If a (unexpected) safety finding does occur, can be added to the haccp plan where required.

(above is I think equivalent to proposal in Post 2).

(Regarding the searching, not many wide-scoped, free ones left afaik.Trello maybe).