6 replies to this topic

[Cheryl Risty]

How do I write up BRC 1.1.8?

 

The company’s senior management shall have a system in place to ensure that the site is kept informed of and reviews:
•  scientific and technical developments
•  industry codes of practice
•  new risks to authenticity of raw materials
•  all relevant legislation in the country where the product will be sold (where known)

 

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[Evans X.]

Greetings Cheryl,

 

This clause is not so much about writing it up as much as being able to prove that you keep up-to-date. This can be done in several ways. Starting from the simplest way of all you can put a date on your "external" documents which will show when was your last review of them to make sure they are up-to-date. Going on many sites, like ISO or legislation (at least in EU this is possible), RASFF, Scholar etc provide an alert system via specific legislation/ISO that you point out or keywords for relevant topics (depends really on what alert system each platform provides). There are free and paid services according to your budget (sites with services that can send you weekly/monthly reports from all over the world on fraud and/or defense incidents with trend analysis and other statistics).

If you do want to write up a few words for this clause my opinion is write some general guidelines like checking this every 6 months/annually or that through an alert system or subscribed to that scientific forum/community (relevant to your field) like IFSQN    cause there are literally too many ways of monitoring these things.

 

Regards!

[pHruit]

Evans X's advice on this is good, but just to add if you're concerned about the documentation side of things in terms of having physical stuff to show an auditor, you can also include discussion on these your meetings and include in the minutes as evidence. For example you could have a set agenda item on your weekly/monthly/six monthly / annual meetings for e.g. scientific and regulatory developments.

If you still keep/use hard copies of things you can also print out some of the updates and initial/sign/date them to show when they've been reviewed, highlight parts of relevance etc.

[Charles.C]

Hi Cheryl,

 

In addition to previous, I suggest you obtain the valuable  BRC Interp.Guidelines which may help to minimise your struggles.

 

It is sometimes easy to over-elaborate on such Clauses which may depend on your specific Product/Process.

[Tony-C]

Thank you Charles, I’ll take that as a cue!

 

From BRCGS Guidance for Clause 1.1.8:

The company must be able to demonstrate that it maintains up-to-date knowledge of relevant legislation, scientific and technical developments, potential risks to raw materials (e.g. to the authenticity of the raw material) and industry codes of practice, such as Codex Alimentarius. Activities to achieve this may include:

• membership of a trade association that provides this service

• subscription to a service provider supplying legal updates

• help from government officials or local enforcement offices

• regular review of identified websites covering legislation and standards.

In addition to information relating to food safety, the site must also have a system to obtain and review information relating to the authenticity of raw materials and the potential for substitution or dilution of the ingredients. This information will be required to demonstrate compliance with clause 5.4.1.

 

So, to add to previous posts, there is also a emphasis on authenticity, section 5.4 is PRODUCT AUTHENTICITY, CLAIMS AND CHAIN OF CUSTODY, Clause 5.4.1 states: The company shall have processes in place to access information on historical and developing threats to the supply chain which may present a risk of adulteration or substitution of raw materials (i.e. fraudulent raw materials).

 

Kind regards,

Tony

[jfrey123]

To meet the similar requirements in SQF code, we've prescribed in a monthly management meeting procedures that those types of items are to be reviewed, and we pull recent data from online sources to add to the meeting itinerary/minutes.  We have relevant staff sign off on the minutes at the end of the meetings as verification they've been reviewed.  As mentioned above, it's more about being able to demonstrate you are aware of the changes that have come out in a timely fashion.

[Esoto728]

Correct nothing really has to be written up. Just have to prove. I suggest you subscribe to agencies and news for up to date information. For example usda, affi, food safety news tech etc. Then prior to audit print out your proof encase the auditor asks for it when you advise.