7 replies to this topic

[cw2299]

We're a BRCGS warehouse that currently receives, stores and ships product for our customers who have all finished/retail packed/products.    We have some customers that want us to start repacking products of theirs in to different counts or mixed boxes.   We don't currently have the ability to do so with our current staff but we do have a business partner that repacking is there forte.   We have a plan to have them do the actual repacking of the sealed, finished product from the master cases they come in into either smaller counts or mixed item count boxes at/inside our facility.  They will be doing the whole process at our facility.   I know this isn't possibly the most ideal circumstance but also not in my control.   We plan on having them do the repacking for us, we use our warehouse and their labor and we have full system traceability.    I'll be doing GMP training, allergen, pest and security training.   With the training I'm hoping that we'll be ok come audit time.   I've got a service agreement drafted but I'm struggling with contractor vs subcontractor for this arrangement.   I have a verification checklist for the repack but I'm still working on something for cleaning checklist.  The customer is aware that we use this service and they'd be working with our business partner directly to have product packed as they require but as the business partners facility isn't audited or currently in condition, the plan is to have them repack at our facility.   I know its alot and I missed alot but any and all input is welcome.

thank you

[jfrey123]

So the labor is coming from an unaudited source?  Is your current BRC cert under Storage and Distribution?  And if so, are you going to inform your CB that you want to get the Contracted Services Module for Contract Packing?  You can handle the unaudited labor via your own training, seems nearly identical to a facility utilizing a temp labor force.

 

But doing stuff outside your BRC cert means your client needs to know they cannot use your certificate for any labeling of this repacked product.  Not the end of the world if they don't care about that, and as for your auditors you can state it was all purposely not to be included in your cert.

 

But by getting into opening and repacking material, even if you decide to call it all outside of your BRC Storage and Distribution scope, you'll still need to adjust all of your environmental and sanitation practices to reflect that you're now opening material.  Does the product contain allergens?  Because if yes, now all of your other customers need to be aware you're introducing an allergen risk to what they believe is only a pass through storage and distribution operation.  What protocols do you have for the equipment you want to bring in?  How will it be cleaned and sanitized between runs?  So on, so forth...

[Lynx42]

We do this.  Showing completed GMP's are important. 

We have a specific repack SOP with one page of GMP's and the second with details for the specific project (including PPE - even though no exposed products our customer wants us to wear hairnets) and have it like it's a one page lesson that has a signature sheet attached.  Even if the same people come in for multiple projects we have them sign on their first day of the specific project, then a daily sign in sheet.

Cleaning sheets, we have a daily form that gets filled out.  Someone from our team fills out a daily pre-operational checklist for cleaning tables and tools (even pens and tape guns get wiped down).  It is completed again after lunch.  We also have a spot for our leads or supervisor to do random checks to make sure everyone is following instructions and wearing the proper gear.  

I would suggest an environmental risk assessment and a clothing risk assessment.  It's all enclosed product, but we remove the primary packing to put it in new packs so it is very low risk and we don't do any environmental monitoring, but we've got the risk assessments in case we are asked.  

I would also suggest a sheet for them to record any damage and how many labels are used.  

[Lynx42]

One more thing...  We just relabel the outer packaging.  We do not relabel or otherwise change anything on the primary packaging, just taking 12-pack cases, put them in 4 or 6 pack cases, then label the new case as a 4 or 6 pack.  Our customers tell us what goes on the label, we print one and send it to them, they verify it, then we double check it against their email approval and keep a record of the printed approval and an actual label.  

We have to notify the customer if we over print labels and have 50 or more left over at the end of projects.  The customer sends us the blank labels to use.

[Tony-C]

Hi cw2299

 

As jfrey123 has indicated, I would think the best solution all round would be to ensure you comply with Module 15 Contract packing (repacking, assembly packing) and add it to your scope.

 

Re. Contractors vs Subcontractors, technically your business partner is a contractor if that isn’t within your scope and a subcontractor if it is within your scope.

 

Contractor or service provider - A person or organisation providing services or materials.

 

Subcontractor - A company or organisation to which the main storage and distribution site subcontracts an activity that is otherwise covered by its scope of certification (e.g. subcontracted storage or distribution of product).

 

Kind regards,

 

Tony

[cw2299]

So the labor is coming from an unaudited source?  Is your current BRC cert under Storage and Distribution?  And if so, are you going to inform your CB that you want to get the Contracted Services Module for Contract Packing?  You can handle the unaudited labor via your own training, seems nearly identical to a facility utilizing a temp labor force.

 

But doing stuff outside your BRC cert means your client needs to know they cannot use your certificate for any labeling of this repacked product.  Not the end of the world if they don't care about that, and as for your auditors you can state it was all purposely not to be included in your cert.

 

But by getting into opening and repacking material, even if you decide to call it all outside of your BRC Storage and Distribution scope, you'll still need to adjust all of your environmental and sanitation practices to reflect that you're now opening material.  Does the product contain allergens?  Because if yes, now all of your other customers need to be aware you're introducing an allergen risk to what they believe is only a pass through storage and distribution operation.  What protocols do you have for the equipment you want to bring in?  How will it be cleaned and sanitized between runs?  So on, so forth...

The labor is coming from an unaudited source but we are adding repacking section of the BRC to our audit this year.   The customer that needs the BRC packing is our long term goal but we can't work on them until we are certified.    

 

As for opening boxes we are opening overpacks of finished products, there is not direct contact with the customer product itself outside of the finished cartons.   They will be using allergens, all of our customers at this facility come from the same manufacturer and have allergens.   The only equipment that will be used is tables and maybe a conveyer.  We will not change the finished product in any way other than packing it down to smaller amounts per case or mixing items in a case for displays or special orders.   I am looking to update cleaning in the area but outside of table cleaning and updated frequency I don't see much that I should be cleaning.  Open to suggestion and thanks for the input.

[cw2299]

Hi cw2299

 

As jfrey123 has indicated, I would think the best solution all round would be to ensure you comply with Module 15 Contract packing (repacking, assembly packing) and add it to your scope.

 

Re. Contractors vs Subcontractors, technically your business partner is a contractor if that isn’t within your scope and a subcontractor if it is within your scope.

 

Contractor or service provider - A person or organisation providing services or materials.

 

Subcontractor - A company or organisation to which the main storage and distribution site subcontracts an activity that is otherwise covered by its scope of certification (e.g. subcontracted storage or distribution of product).

 

Kind regards,

 

Tony

I guess thats kind of what I'm struggling  with currently.  We're setting up now and our customer wouldn't be BRC certified which they are ok with at this point but we plan to be certified later this year.   I have an agreement for our partner(contractor) but do they change from contractor to subcontractor when we add repacking to our BRC cert.   Do we need a new contract?  I'm trying to make sure to cover my bases and treat them as they need to be but it is causing me some confusion.

[cw2299]

Lynx42/

jfrey123

 

Thank you. 

 

We do this.  Showing completed GMP's are important. 

We have a specific repack SOP with one page of GMP's and the second with details for the specific project (including PPE - even though no exposed products our customer wants us to wear hairnets) and have it like it's a one page lesson that has a signature sheet attached.  Even if the same people come in for multiple projects we have them sign on their first day of the specific project, then a daily sign in sheet.

Cleaning sheets, we have a daily form that gets filled out.  Someone from our team fills out a daily pre-operational checklist for cleaning tables and tools (even pens and tape guns get wiped down).  It is completed again after lunch.  We also have a spot for our leads or supervisor to do random checks to make sure everyone is following instructions and wearing the proper gear.  

I would suggest an environmental risk assessment and a clothing risk assessment.  It's all enclosed product, but we remove the primary packing to put it in new packs so it is very low risk and we don't do any environmental monitoring, but we've got the risk assessments in case we are asked.  

I would also suggest a sheet for them to record any damage and how many labels are used.  

I have a large overarching GMP training for our warehouse's that cover a lot but with the chance for different people needing to come in I might change my thoughts on the training for this team.  I appreciate the input on the even wiping down tape guns and pens.    I'll work on environmental risk assesement and clothing assesment so I can move onto cleaning sheets next.  I appreciate the input very much