6 replies to this topic

[WorkingFromWork]

Hello, this is one part of the BRCGS Standard that has confused me for some time.

 

I created an internal audit program with a schedule for internal audits that is based on risk and previous audit performance. I listed each of the requirements for the standard in that schedule. Do I need to include more audits than these?

 

Do I need to also include a section in the schedule for processes that are audited aside from the list of requirements in the standard?

 

I feel like I've been told that we need to audit our specific work instructions, like "did the worker wrap the pallet around 3 times?" but I do not see where that is a requirement. 

 

Really could use some insight as to how this works. Really appreciate any help. Thank you.

[GMO]

Hi WorkingfromWork (great name by the way).  How I've always approached BRCGS auditing internally was to take the standard, check the standard was replicated into our procedures and then check those procedures were being applied.

 

So for example, let's take a section at random:

 

5.3.2 which is about identifying and listing allergen containing ingredients and materials on site.

 

You'd expect that to be reflected into an SOP on allergen control which would include the specifics about how materials are labelled (e.g. with a tag) which you'd then look into the factory for examples of conformity, non conformity and talking to staff, their level of understanding.

 

You might have a situation where your internal procedure goes further than BRCGS requires, for example, specific coloured tags for specific allergens and find non conformances against that.  To my mind for best practice, you should still raise it against an internal BRCGS scope audit because you've then gone against your procedure.  The reason I think even a BRCGS auditor may expect that is the catch all fundamental clause in section 6.1 about the site operating to work instructions and procedures.

 

Whether your wrapping of the pallet is a non con?  As with all things "it depends".  Are you getting a lot of product damage in store?  Is 3 layers critical for the stability of the pallet?  If it shifted slightly are there quality or even health and safety concerns?  Only knowing your product will you be able to confirm.

 

You could probably get away without doing the above internally as long as procedures are compliant with reality the day of audit but if you want a really good quality system that's working in practice, I'd say it's best practice to do that multi level audit, i.e.:

 

• What does it say in BRCGS?
• Is there a statement of intent, policy or procedure (if required, not needed for all sections.)?
• Is it in an SOP?
• Are all documents compliant or above BRCGS requirements?
• Are we then actually doing it in practice in the factory?  Both in a way compliant with BRCGS and our internal procedures?
• Do people understand the requirements and why in the factory?
• Are they formally trained against the SOP in the factory?

 

Remember even internal audits are sampling exercises.  So you need to look for evidence on each clause but you won't necessarily be expected to look at huge numbers of examples.  A sample is fine.  Then going into more depth on that sample is quite helpful I think.

[WorkingFromWork]

Thank you for your advice GMO, but I am still confused. Also, this is for packaging materials and not food.

 

 

I guess I will word my questions like this:

1. If we have a procedure that is not used to fulfil a requirement of the BRCGS Standard, does it need to be audited? If so, why?

 

2. If we have a procedure that is used to fulfil a requirement of the BRCGS Standard, does it need to be audited beyond that the requirement of the standard is being followed? If so, why? Like do I need a non-conformance report where the scope of the audit is "SOP for doing this thing that is partly used to fulfil part of the standard requirements"?

 

Right now, my audit schedule is just a long list of all the requirements in the standard like this as an example:

1.1 - Jan

1.2 - Feb

1.3 - Mar

 

But do I need to audit any processes outside of this, like 

 

1.1 - Jan

SOP-1 - Jan

SOP-2 - Jan

1.2 -Feb

SOP-3 - Feb

1.3 - Mar

SOP-4 Mar

 

This is what I thought I had to do for some reason, but I am not seeing why based on a standard requirement. It significantly increases the number of audits and we are a small company, so I want to make sure. Sorry if this is confusing or a bad question. I am new to these things.

[GMO]

Oops, missed it was packaging but I think the same principles apply.

 

No I wouldn't audit the SOPs separately but just take the SOPs associated with that section and audit them at the same time as part of the same audit.  So your SOP on, say, goods receipt is audited at the same time as your internal audit against that section.  Auditing your procedures are compliant with the standard and complied with is, to my mind, part of any audit.

[jfrey123]

Thank you for your advice GMO, but I am still confused. Also, this is for packaging materials and not food.

 

 

I guess I will word my questions like this:

1. If we have a procedure that is not used to fulfil a requirement of the BRCGS Standard, does it need to be audited? If so, why?

 

2. If we have a procedure that is used to fulfil a requirement of the BRCGS Standard, does it need to be audited beyond that the requirement of the standard is being followed? If so, why? Like do I need a non-conformance report where the scope of the audit is "SOP for doing this thing that is partly used to fulfil part of the standard requirements"?

 

I'm not as familiar with BRCGS specifically, but I have thoughts to your questions in general from a GFSI mindset.

 

1.  If it's part of your FS-QMS, I would audit it.  It may not have a direct tie into your BRC requirements, but if it's part of your food safety program overall then I would want to review that the procedure is being performed correctly and has the intended result.  I kind of struggle to think of a single program I've seen with my companies that didn't somehow in some small way tie into the GFSI codes we were under.

 

2.  Kinda along the point I made above, I think an effective internal audit addresses both that your SOP is working as intended and also whether it meets the BRC standard.  I tend to review the programs individually during the year, documenting how we've audited the program worked as written and whether legislation or GFSI updates require us to update the program.  But then before our SQF audits, we do a full self-assessment against the standard to make sure we're compliant (because they require it).  So realistically, I'd be auditing our SOP's a few at a time each month, then doing the one big assessment prior to our unannounced windows opening.  I think that would be acceptable for BRC as well, but happy to be corrected if someone has a more experienced view.

[Aboutaleb10]

What About Sharing your internal Audit plan , to see How you activate it ?

[kingstudruler1]

You may be thinking of it in a different way than I am use to.   No that it is a bad way, just different.   You seem to be looking for "what" to audit and not "How" to audit.  The  scope / "what" is already given to you - it is the standard.   

 

For instance, when you audit 1.1.1, you should be asking your self "how" do I prove that I meet this requirement?   In doing so, you would review the management commitment statement and make sure it meets the requirments,  verify where it might be posted, and possibly even question employees on its existance and thier familiarity with it.  ive never created a checklist of everything I feel I need to look at in order to acheive compliance.   That just seems like a alot or work - if im understanding your thought pattern correctly.   

 

If your procedure is needed to achieve compliance with some portion of the standard, it will be included in your audit.  

 

I feel like I've been told that we need to audit our specific work instructions, like "did the worker wrap the pallet around 3 times?" but I do not see where that is a requirement.   

 

You would probably review these written work instructions in 1.3.2.  I would not say you have to go to the line a verify that is what they are doing.   If you happened to see it not happening during a walkthrough, you could consider it a minor non conformity.  Or if you happened to witnees it being done corrrectly it could be considered evidence that the work instructions are being followed correctly.    Some people may choose to visually watch employees completing work instructions as a form of training verification.  (6.1.2)  There are other way to verifiy training effectivenes.