Review Of (4. Technical Management System)

Next up for review is section 4. Technical Management System which covers:

4.1 Technical Management Policy
4.2 Documentation Control
4.3 Specifications
4.4 Management of Incidents and Product Recalls
4.5 Traceability
4.6 Process Control
4.7 Internal Audits
4.8 Complaint Procedure
4.9 Supplier Monitoring
4.10 Sub-Contracting of Production
4.11 Product Analysis

Rather a large section with a lot of detailed requirements. Feel free to add your comments.

Regards,
Simon

For what they're worth my comments on this section.

1. There is some duplication / crossover in this section with requirements contained in ISO 9001:2000, for example in document control and internal audits. BRC/IOP Auditors are required to cover every clause of the standard and tick all the boxes. It's a lot to get through and I wondered, where a business is certified to ISO 9001:2000 whether it might be possible to verify compliance with ‘low risk' items such as the above by cross referencing with the previous ISO audit report. Perhaps not…it's just a thought. It would add more value to the audit process if auditors spent more time in production and concentrated hard on the real risks to food safety.

2. In the spirit of improvement most (if not all) of the ‘Recommendations on Good Practice' in this section should now become requirements.

3. A minimum frequency (possibly annually) should be specified for:

- management review
- product recall test

4. The wording of the ‘Recommendations on Good Practice' contained in 4.4.1:

'The Designated Manager should be responsible for ensuring corrective action including the review of all records of incidents and that preventative action is taken'

Does it make any sense?

Regards,
Simon