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BRC Audit on new factory not yet producing

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Miss Frankie

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Posted 11 March 2024 - 08:00 PM

We have a BRC Audit on Thursday. Audit was scheduled before I joined the company.

We are not yet running any product. We're still in construction mode.  Moving in equipment, building walls, installing lines. etc.

 

 

I have MOST of our policies in place.  Still waiting for them to get approved from out Canadian office. 
I don't have any HACCP plans yet, as lines aren't completely in place yet. I do have a pretty good start on a couple of our lines that will be running later, as they are the same as our CA facility. But what we're starting with isn't ran up there.

I don't even have any QA test equipment yet (MOST of it has been ordered) 

 

They were hoping to be production before now, which is why the audit was scheduled. But now we're looking at a couple test runs in April.

 

What should I except during this audit?   I think it should be postponed until we're close to production, but it's not my call.



Ishau

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Posted 11 March 2024 - 08:12 PM

You should expect your audit to either fail on a fundamental requirement if you were actually producing.

If you were not producing, and haven't started producing yet, then strictly speaking the auditor should walk away because it won't be a valid audit.

Protocol requires you to be producing during the audit, and to have roughly 3 months worth of records. Doesn't sound like you have this.



Miss Frankie

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Posted 11 March 2024 - 08:34 PM

You should expect your audit to either fail on a fundamental requirement if you were actually producing.

If you were not producing, and haven't started producing yet, then strictly speaking the auditor should walk away because it won't be a valid audit.

Protocol requires you to be producing during the audit, and to have roughly 3 months worth of records. Doesn't sound like you have this.

 

That's what I was thinking.  But the CAN office is more versed in BRC than I am (I'm coming from SQF)
Maybe the QA in CAN is saying audit, but it's more of a gap audit?  Or possibly an audit with a consultant. 
I do know the head of QA from CAN will be down for it.  

 

I'll have to do some digging to figure out exactly what type of audit it's supposed to be.



SQFconsultant

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Posted 11 March 2024 - 08:58 PM

You need to contact the CB - this is a gigantic issue for an Auditor that is paid on contract having to walk in, find out you are not ready, call in and they redline the order and he/she walks out and then doesn't get paid the full amount that they should have and now can not fill in the time to make up for it.

 

It's not right - the CB will charge all expenses and the part of the fee, so they are covered, but the Auditor most times gets stiffed.

 

Do the right thing.

 

Beleive me, if you don't do something now, it will look really bad to your customers, mess up the earnings for the Auditor and then you'll have to have to do the whole thing over again.

 

Interestingly enough I walked into a facility as an SQF Auditor and they were not running product, they thought it no big deal - it was a big deal, I left in under 10 minutes after calling it in and was able to get some beach time in and an early flight home from LA to New York.


All the Best,

 

All Rights Reserved,

Without Prejudice,

Glenn Oster.

Glenn Oster Consulting, LLC -

SQF System Development | Internal Auditor Training | eConsultant

Martha's Vineyard Island, MA - Restored Republic

http://www.GCEMVI.XYZ

http://www.GlennOster.com

 


Miss Frankie

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Posted 11 March 2024 - 09:19 PM

Okay, I did some digging. It's an internal audit with a BRC consultant.
The CAN office told me BRC Audit.  I didn't think that could be right, but that's what it said on the calendar.



MDaleDDF

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Posted 12 March 2024 - 02:45 PM

If they're coming in a consulting role I'd move forward, but if it's indeed an internal audit, I'd push that back too.   How can you internal audit if you're not up and running?


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jfrey123

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Posted 12 March 2024 - 04:23 PM

I'd assume the consultant has been hired to get you audit-ready prior to starting operations.  I've been involved as a consultant with companies in the same boat:  we'd go in, review the SOP's, walk and review the intended process, and advise where we saw opportunities for improvement.  If you can get your management to confirm that is the intent, I wouldn't even be counting this as an audit but rather a pre-audit prep.  



Miss Frankie

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Posted 12 March 2024 - 11:03 PM

From the information I'm getting, it's a consult and will focus on facility standards, then we'll look at things that are in place to see if they are BRC compliant. 

 

As I said before, this was in place prior to me starting here.  
 

I've been editing documents from CAN to make them fit USA, and they cover EVERYTHING.  There are documents for things stating why there are documents for something, then a form documenting the steps.
I'm getting CLOSE to having all the forms updated, and have been doing daily walks through the plant watching progress.  Things are moving, but still has a ways to go.



GMO

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Posted 26 March 2024 - 02:33 AM

Sounds like a pre audit prep / consultant visit would be a great idea with where you are. How did it go?

I’m sure the consultant said this but that HACCP plan which is similar to another site? Make sure you do the work up front for your site with a cross functional team and have it in place before any test runs. You’d be surprised how often a “test” run ends up being for human consumption even if only for onsite staff.





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