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BRC 3.5.1.1. Risk associated with raw material which are subject to legislative control

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bertilledsmith

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Posted 19 May 2022 - 07:45 PM

Hello!

 

I am currently working on our supplier approval, and I am wondering about the last point that shall be taken into account:

" Any risks associated with raw materials which are subject to legislative control".

 

I don't really see how to build different risk levels for this point.

 

For example, our facility will receive raw material but this RM will be graded by the USDA. Therefore I can only see how it can fit into a pass or fail system, not a scale system. 

 

Can someone enlighten me about this very specific point? 

 

TYIA !



Evans X.

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Posted 20 May 2022 - 07:53 AM

Greetings Bertilled,

 

The biggest point here is to assess the risk posed by the possibility of your "failure" to track a change in legislation. An example could be the addition of a new raw material in the allergen lists (if I recall it is under discussion to add a couple more in the US, like sesame in 2023).

Simply put, if you hadn't predicted somewhere that you would make regular scans for updates then you risk missing something that has changed about a material. This could also be the highest concentration limit of a substance in end products, the ban of a raw material from use etc.

Yes it can be a simpler risk assessment but it is what it is!

However you can elaborate more on this, like taking into account micro/chemical parameters the FDA check for (according to legislation) when it sends samples of raw materials to its laboratories and see if you missed something which was added/removed/changed. It will possibly cross-ref with the RM for your food safety controls, but you may find something extra.

 

Hope it helps you get started,

Regards!


Edited by Evans X., 20 May 2022 - 07:54 AM.


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Charles.C

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Posted 21 May 2022 - 04:01 PM

Hello!

 

I am currently working on our supplier approval, and I am wondering about the last point that shall be taken into account:

" Any risks associated with raw materials which are subject to legislative control".

 

I don't really see how to build different risk levels for this point.

 

For example, our facility will receive raw material but this RM will be graded by the USDA. Therefore I can only see how it can fit into a pass or fail system, not a scale system. 

 

Can someone enlighten me about this very specific point? 

 

TYIA !

Hi bertilled,

 

The response probably relates to the specific type of materials you are handling and their specific, operational, USDA compliance (or non-compliance) characteristics. These are hopefully also included in your own Raw Material Specifications.

 

An Approved Supplier's operational Status level could also be risk related to a history of Regulatory /Quality compliance.

 

A General illustration of these inter-related aspects is included in the Excel in this (older) post where i used a logic somewhat analogous to yr OP -

 

https://www.ifsqn.co...al/#entry100194

(also see Posts 21 et seq)

 

BRC have successfully complicated the items in this Clause by stuffing them all together !. :smile:

 

PPS - other similar but simpler presentations than mine also exist on this forum.


Kind Regards,

 

Charles.C


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