9 replies to this topic

[PropTech]

Our plant operates alarm and belt stop metal detectors on our lines. These detectors do not have rejection bins or mechanisms. 

Our procedure defines the process of where stock triggering  metal detectors is effectively quarantined to prevent release. This includes the wrapping and clear labeling of product to communicate to staff that the product is nonconforming and not to be moved, processed or disturbed.

 

The Internal Auditor is adamant that the BRCGS interpretation guide for the clause (attached) is stating that a lockable container must be used in the the absence of automatic rejection system.

 

It is my position that the use 'typically'  in the interpretation (In the absence of the either must or shall) means that a lockable container is not compulsory. I believe that the existing controls in place are sufficient in compliance with the requirements of the clause and interpretation.

 

I could capitulate and just buy a box. But I am reluctant to introduce a new piece of production furniture and rewrite/retrain our established procedure for no real improvement/gain in control unless it is necessary.

. 

 

 

What are peoples thoughts? 

 

Attached Files

•  BRCGS Extract.jpg   209.12KB   2 downloads

[kingstudruler1]

My opinion is that you can't or shouldn't audit the guidance.   As is, it appears to meet the standard.  

 

 

a few section up in 10.4.2 the guidance has something about a "good Practice for monitoring a magnets performance is to have a policing magnet.   Are they requiring that too?  

[KTD]

During one of my very first BRC audits years ago, I pointed out to an auditor that we were following/meeting the recommendations given in the Guidance for a specific clause. The auditor stated that he audited to the Standard, not to the Guidance...

 

My suggestion is to use the Guidance for ideas, but make sure that you meet the requirements of the clause as written...not interpreted.

 

KTD

[SQFconsultant]

During one of my very first BRC audits years ago, I pointed out to an auditor that we were following/meeting the recommendations given in the Guidance for a specific clause. The auditor stated that he audited to the Standard, not to the Guidance...

My suggestion is to use the Guidance for ideas, but make sure that you meet the requirements of the clause as written...not interpreted.

KTD

(The auditor stated that he audited to the Standard, not to the Guidance.)

Interesting, this is how I audited as well, however there is some lee way for the Auditor if they wanted to be a bit more fair.

However, I would go ahead and modify - does this mean however that a blow off mechanism will be required as well?

[SHQuality]

External auditors will also use the interpretation guide when auditing, so ignoring the interpretation guide while auditing doesn't seem like a good idea to me.

To me, the need for a closed box is linked to an rejection mechanism. 

 

That said, I think using an automated rejection mechanism might offer the chance for your production to run faster and more smoothly without interruption upon detection.

[Charles.C]

SQF actually declare (at least when I last looked) in their Standard that where a conflict occurs between text in the Standard and Guidance, the former supercedes.

 

I anticipate BRC are the same although generic statements can obviously be pragmatic.

 

A few years ago, a (claimed) BRC auditor stated in a thread that he never read the Guidance so as to avoid bias.

[Robert Rogers]

Left up to interpretation is "where product cannot be automatically rejected" examples are provided. In your case with lack of physical reject mechanism currently in place, one could argue that product cannot be automatically rejected. 

 

issue 8

4.10.3.2 The metal detector or X-ray equipment shall incorporate one of the following:

• an automatic rejection device, for continuous in-line systems, which shall either divert contaminated

product out of the product flow or to a secure unit accessible only to authorized personnel.

• a belt stop system with an alarm where the product cannot be automatically rejected (e.g. for very

large packs)

• in-line detectors which identify the location of the contaminant to allow effective segregation of the

affected product.

 

wording is similar in issue 9 

 

I am however an advocate of a well-designed, validated and verified foreign material prevention and detection program with access controls in place to ensure authorized interventions. 

[eleanorn]

Interpretation Guidelines are guidance and not auditable.

Standard clauses are auditable - direct quote from BRCGS Training to ATPs to state to Sites and Auditors during training for Issue 9.

[SHQuality]

Interpretation Guidelines are guidance and not auditable.

Standard clauses are auditable - direct quote from BRCGS Training to ATPs to state to Sites and Auditors during training for Issue 9.

 

In to my understanding, the guidance often explains how the Standard should be interpreted when people do not agree on the matter.

 

So in this case, the question would be: how do you manage the risk of implicated product being reintroduced in the process line if you do not have locked containers for rejects? If you can answer that sufficiently, you don't need the locked containers.

 

Risk analysis should remain the basis of your actions.

[eleanorn]

Agree 100%!

 

In to my understanding, the guidance often explains how the Standard should be interpreted when people do not agree on the matter.

 

So in this case, the question would be: how do you manage the risk of implicated product being reintroduced in the process line if you do not have locked containers for rejects? If you can answer that sufficiently, you don't need the locked containers.

 

Risk analysis should remain the basis of your actions.