4 replies to this topic

[chrisolson]

Hello All.

 

Issue

 

We are a bakery that's audited to BRCGS. We were testing the most vulnerable product inhouse (first product off the line after nuts). Durning an audit we were told we needed more Validation to back our testing so we sent out the product to a 3d party. We said we would send it out monthly and that seemed to satisfy. We ended up sending it every time we made nut product which is a lot more than once a month. We now have a mountain of data showing no positives from the most vulnerable product for a full year +. 

 

Questions,

 

Do I need to add this testing data to the RA in order to prove our frequency of testing

 

And if we have had no positives on 3d party testing (1-3 times a month) for a year, what frequency can we pull back to?

(once every other month, quarter?)

 

 

thanks 

 

 

 

[SQFconsultant]

I would go ahead and add it and then pull back to (put your obvious justification in writing) to once a month for 3 months, then once every other month for 3 months and finally once per quarter - you could pull way back right now, but might as well appease the auditor for this next audit and then pull back.

[kingstudruler1]

I despise the fact that they say its not good enough but wont tell you what is good enough.  

 

I like what Glenn suggested.  another added  suggestion would be to do in house testing of rinse water as well - if you have the lab and personnel.  

[Dorothy87]

Hi :)

 

I believe you have enough validation data

 

I would consider  once a month - randomly, and I would swab the line with rapid test before cleaning and after cleaning (verification) prior non-nut product production. 

 

 

[jay2023]

I despise the fact that they say its not good enough but wont tell you what is good enough.  

 

I like what Glenn suggested.  another added  suggestion would be to do in house testing of rinse water as well - if you have the lab and personnel.  

They are not allowed to provide advice as it counts as consultancy- if the next auditor isn't happy with the solution and you say 'the auditor said this would work' it will cause them problems.