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BRCGS clause 5.1 Product Design and Development

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Nazia Ammad

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Posted 29 December 2022 - 02:34 PM

Hello Everyone

 

Can someone please explain the following clauses of BRC clause 5.1 product design/development

 

5.1.1 The company shall provide clear guidelines on any restrictions to the scope of new product developments to control the introduction of hazards which would be unacceptable to the site or customers (e.g. the introduction of allergens, glass packaging or microbiological risks).

 

What documents should I have to fulfill the requirements of above clause, it seems that I should have a "policy statement" on this clause in which we can mentioned that what type of hazards are not acceptable in our company e.g "glass container as packaging will not be acceptable". Right now we don't have any restrictions for product development, so should I pass this as "N/A - not applicable" OR should I have to have some policy statement on this, if someone please help me on this.

 

5.1.2 All new products and changes to product formulation, packaging or methods of processing shall be formally approved by the HACCP team leader or authorised HACCP committee member. This shall ensure that hazards have been assessed and suitable controls, identified through the HACCP system, are implemented. This approval shall be granted before products are introduced into the factory environment.

 

Also, is there a separate document required to fulfil the requirements of above clause, or should I simply get my formulations, HACCP plans and SOPs signed by the authorized person, please help me on this



kingstudruler1

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Posted 29 December 2022 - 04:46 PM

IMO you could have one procedure that covers all of section 5.1. 

 

5.1.1.   I guess you could just state that there are no restrictions on product development if that is the case.

 

5.1.2   You need to have a procedure in place on how you commercialize new products, and make changes to ingredients, packaging, how processing equipment, processes, etc.   

 

How you document this process is up to you.   I prefer to have a form that covers new products and changes.   I have attached a simple example of how you could document this on one form.   

Attached Files


Edited by kingstudruler1, 29 December 2022 - 04:48 PM.

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Duncan

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Posted 29 December 2022 - 07:20 PM

Hello Everyone

 

Can someone please explain the following clauses of BRC clause 5.1 product design/development

 

5.1.1 The company shall provide clear guidelines on any restrictions to the scope of new product developments to control the introduction of hazards which would be unacceptable to the site or customers (e.g. the introduction of allergens, glass packaging or microbiological risks).

 

What documents should I have to fulfill the requirements of above clause, it seems that I should have a "policy statement" on this clause in which we can mentioned that what type of hazards are not acceptable in our company e.g "glass container as packaging will not be acceptable". Right now we don't have any restrictions for product development, so should I pass this as "N/A - not applicable" OR should I have to have some policy statement on this, if someone please help me on this.

 

 

 

You should consider all restrictions, so for example if you don't want NPD projects to introduce new allergens to your processing facility then you could list out all allergens that may not be included in new NPD materials.

 

If your HACCP process flow includes a heat treatment process step, then you may want to introduce a restriction on microbiological properties for any raw materials (e.g. toppings/additions) applied to any NPD products after that process step.

 

A lot of this is tied to your HACCP plan, but in broad terms, consider anything that would cause an NPD project to be rejected at feasibility stage.


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Tony-C

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Posted 30 December 2022 - 04:24 AM

Hi Nazia,

 

Any restrictions you have should be based on preventing the introduction of hazards to your existing product range e.g. allergens where you have allergen free, raw products where you have RTE products. These can be documented in your procedure or a policy.

 

To answer your question if you have no restrictions, BRCGS Guidelines for clause 5.1.1 states:

Any such restrictions must be documented. Where no restrictions apply, this need not be documented.

 

For 5.1.2 All new products and changes to product formulation, packaging or methods of processing I use a Process Change Approval Form.

 

Attached File  Process Change Approval Form Example.png   464.94KB   4 downloads

 

I would use a simpler form for minor changes.

 

Kind regards,

 

Tony



Nazia Ammad

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Posted 30 December 2022 - 08:43 AM

Thank you all, your responses are very helpful for me. I have developed the procedure for design/development and also have the form, but I was little bit confused that to make these points part of my procedure will work and fulfils the clause requirements or not, but now I am much clear. Thanks again





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