HACCP Flow Import and Export

Hello

Our HACCP Flow states 

Supplier / buying

Transport

Storage

Delivery/ rejection

We do do import and export, however i have covered all risks in my risk assessment for transport/ buying / delivery.

We,ve just had BRC audit and we have NCN that our flow doesnt state import / export. We use clearing agent for all our export.

What is your view on this ? How would you add it to our current flow ?

Honestly I'm not surprised this picked up an NC. Your existing risk assessment can certainly be referenced in the hazard analysis for the various steps on the process flow to which it applies, but IMEX the auditors will expect to see that your process flow includes every "activity".

I'd be inclined to add the import/export as individual steps - if you "import" to the UK then this is one step, and if you subsequently export again later then I'd probably put that as a separate step. Your "hazards" at this step will depend on the product, but could be e.g. micro-related (even if not pathogenic) due for example to spoilage caused by delays at customs, or failure to clear customs due to incorrect documentation (again, not food safety, but this is the sort of "hazard" in the relatively loose BRC Agents & Brokers sense that could occur here).

your haccp plan should be highly detailed and a risk assessment does not a haccp plan make (it's a supporting doc)

what if you're importing from a country with VERY different food safety requirements?  That is an example of why the step needs to be listed and PCP measures listed