5 replies to this topic

[Tony-C]

Hi Everyone,

 

BRCGS Compliance Report 2022 was published last month, I thought members may be interested in the most common non-conformances from 2022. There is a predominance of non-conformances against section 4.4 Building Fabric, 4.9.1.1 Chemical Control is again amongst the top ten as it was in 2021 which may be a surprise to some and clause 3.9.2 Traceability coding has appeared in the top ten in 2022.

 

Below are the details and the requirements that sites have failed to meet in their certification audit.

 

BRCGS Food Standard Top 10 Non-Conformances in 2022

 

 BRCGS Food Standard - Top 10 NCs 2022.png   249.84KB   2 downloads

 

4.11.1 Premises and equipment hygiene

The premises and equipment shall be maintained in a clean and hygienic condition.

 

4.6.1 Equipment construction & maintenance

All equipment shall be constructed of appropriate materials. The design and placement of equipment shall ensure it can be effectively cleaned and maintained.

 

4.4.8 Doors

Doors (both internal and external) shall be maintained in good condition. At a minimum:

• external doors and dock levellers shall be close fitting or adequately proofed

• external doors to open product areas shall not be opened during production periods except in emergencies

• where external doors to enclosed product areas are opened, suitable precautions shall be taken to prevent pest ingress.

 

4.9.1.1 Chemical controls

Processes shall be in place to manage the use, storage and handling of non-food chemicals to prevent chemical contamination. These shall include, at a minimum:

• an approved list of chemicals for purchase

• availability of material safety data sheets and specifications

• confirmation of suitability for use in a food-processing environment

• avoidance of strongly scented products

• the labelling and/or identification of containers of chemicals at all times

• a designated storage area with restricted access to authorised personnel

• use by trained personnel only.

 

4.4.1 Walls

Walls shall be finished and maintained to prevent the accumulation of dirt, minimise condensation and mould growth, and facilitate cleaning.

 

4.4.4 Ceilings

Ceilings and overheads shall be constructed, finished and maintained to prevent the risk of product contamination.

 

3.9.2 Traceability coding

Identification of raw materials (including primary packaging), intermediate/semi-processed products, part-used materials, finished products and materials pending investigation shall be adequate to ensure traceability.

 

4.4.2 Floors

Floors shall be suitably hard-wearing to meet the demands of the process, and withstand cleaning materials and methods. They shall be impervious, be maintained in good repair and facilitate cleaning.

 

4.15.1 Storage facilities

Procedures to maintain product safety and quality during storage shall be developed on the basis of risk assessment, understood by relevant staff and implemented accordingly. These may include, as appropriate:

• managing chilled and frozen product transfer between temperature-controlled areas

• segregation of products where necessary to avoid cross-contamination (physical, microbiological or allergens) or taint uptake

• storing materials off the floor and away from walls

• specific handling or stacking requirements to prevent product damage.

 

2.7.1 Hazard identification

The HACCP food safety team shall identify and record all the potential hazards that are reasonably expected to occur at each step in relation to product, process and facilities. This shall include hazards present in raw materials, those introduced during the process or surviving the process steps, and consideration of the following types of hazard:

• microbiological

• physical contamination

• chemical and radiological contamination

• fraud (e.g. substitution or deliberate/intentional adulteration)

• malicious contamination of products

• allergen risks (see section 5.3).

It shall also take account of the preceding and following steps in the process chain.

 

Source of Non-conformance Information - BRCGS Compliance Report 2022

 

Kind regards,

 

Tony

[GMO]

I remember when v8 came in with the hazard identification sections aligned with the FSMA and my team member swore he'd done the work.  Auditor came, he hadn't.    

I was not a happy bunny.

 

Having had some AIB audits though, it is striking me that there are more "AIB style" non cons being identified.  For those not familiar with that standard it's VERY factory based and puts massive focus on fabrication.  

 

It's interesting that culture isn't though... I know v9 beefs it up but to my mind, nobody is doing it well yet and even having worked on it on and off for 10 years, I'm only 80% there for what I want it to look like to really bring value.  Let's face it, most factories are currently ticking a box.

[Sayed M Naim Khalid]

It is interesting most of the time similar repetitive noncompliance. Why do businesses not improve? Does this mean that food safety is expense they better off be cited for noncompliance than implementing food safety corrective actions? 

[GMO]

It is interesting most of the time similar repetitive noncompliance. Why do businesses not improve? Does this mean that food safety is expense they better off be cited for noncompliance than implementing food safety corrective actions? 

 

Food safety is generally a cost to a business up front with no guarantee of a return.  Sure we talk about cost of quality (or non quality) in scrap, complaints, legal action or lost sales and the benefits of good food safety with secure jobs etc.

But is that reality?  I'm now over 20 years in the food industry and I wearily lug myself along knowing that if I'm asking for investment and it has a return (so it pays for itself in <2 years) AND it has a food safety benefit; I'll get it.  If it's only for food safety, it's going to be tougher.  

 

The thing most businesses haven't got their head around is that "non financial benefit capex" isn't now just food safety and health and safety but it's also sustainability.  So if that pot of money that they are allowing us to spend doesn't grow overall, the amount for food safety will shrink.

 

Add that to the fact many food companies are in dire financial positions.  The prices in the shops isn't the whole inflation, much is being absorbed by the companies themselves.  I know of three suppliers who have gone under this year.  

 

So faced with a potential of business failure, increasing ethical demands on limited resource, I get why some business owners will weigh up the risk and put a machinery guard in to prevent an accident or a new pump to prevent a spill than a new floor to prevent an audit non conformance.

[Tony-C]

I remember when v8 came in with the hazard identification sections aligned with the FSMA and my team member swore he'd done the work.  Auditor came, he hadn't.    

I was not a happy bunny.

 

Having had some AIB audits though, it is striking me that there are more "AIB style" non cons being identified.  For those not familiar with that standard it's VERY factory based and puts massive focus on fabrication.  

 

It's interesting that culture isn't though... I know v9 beefs it up but to my mind, nobody is doing it well yet and even having worked on it on and off for 10 years, I'm only 80% there for what I want it to look like to really bring value.  Let's face it, most factories are currently ticking a box.

 

I agree GMO, I would have thought food safety culture would be in there. It was in 2021, I'll post that summary next.

 

Kind regards,

 

Tony

[Tony-C]

BRCGS Food Standard Top 10 Non-Conformances in 2021

 

Clause 4.11.1 Premises and equipment hygiene - Section 4.11 Housekeeping and Hygiene:

The premises and equipment shall be maintained in a clean and hygienic condition.

 

Clause 4.6.1 Equipment construction & maintenance - Section 4.6 Equipment:

All equipment shall be constructed of appropriate materials. The design and placement of equipment shall ensure it can be effectively cleaned and maintained.

 

Clause 4.4.8 Doors - Section 4.4 Building Fabric, Raw Material Handling, Preparation, Processing, Packing and Storage Areas:

Doors (both internal and external) shall be maintained in good condition. At a minimum: …..

 

Clause 4.9.1.1 Chemical controls - Section 4.9 Chemical and Physical Product Contamination Control: Raw Material Handling, Preparation, Processing, Packing and Storage Areas:

Processes shall be in place to manage the use, storage and handling of non-food chemicals to prevent chemical contamination. These shall include, at a minimum: …….

 

Clause 4.4.1 Walls - Section 4.4 Building Fabric, Raw Material Handling, Preparation, Processing, Packing and Storage Areas:

Walls shall be finished and maintained to prevent the accumulation of dirt, minimise condensation and mould growth, and facilitate cleaning.

 

Clause 2.7.1 Hazard identification - Section 2.7 List all Potential Hazards associated with each Process Step, conduct a Hazard Analysis and consider any measures to control Identified Hazards (Equivalent to Codex Alimentarius Step 6, Principle 1):

The HACCP food safety team shall identify and record all the potential hazards that are reasonably expected to occur at each step in relation to product, process and facilities.

 

Clause 4.15.1 Storage facilities - Section 4.15 Storage Facilities:

Procedures to maintain product safety and quality during storage shall be developed on the basis of risk assessment, understood by relevant staff and implemented accordingly.

 

Clause 1.1.2 Food safety culture - Section 1.1 Senior Management Commitment and Continual Improvement:

The site’s senior management shall define and maintain a clear plan for the development and continuing improvement of a food safety and quality culture.

 

Clause 3.4.1 Internal audits - Section 3.4 Internal Audits:

There shall be a scheduled programme of internal audits.

At a minimum, the programme shall include at least four different audit dates spread throughout the year. The frequency at which each activity is audited shall be established in relation to the risks associated with the activity and previous audit performance. All activities shall be covered at least once each year.

 

Clause 4.11.2 Cleaning procedures – Section 4.11 Housekeeping and Hygiene:

Documented cleaning procedures shall be in place and maintained for the building, plant and all equipment. Cleaning procedures for the processing equipment and food contact surfaces shall, at a minimum, include: …

 

Source: BRCGS Compliance Report 2021