Hazard and Risk Management System
Having now got the report from my recent BRC inspection, under observations on oportunities for improvement in areas of compliance the following is stated:
"There is some confusion concerning items which are excluded from consideration under the HACCP plan. Wood cannot be excluded as it is in the process area by virtue of pallets".
The auditor (on the audit) stated that it really should be sub-contracting of production due to no sub-contracting of production being undertaken.
The standard states:
3.2.5 Decide which sections in 5, 6 and 7 are not applicable to the company using hazard analysis, and document the reason for their exclusion.
Sub-contracting of production is under section 4.
Has anyone any ideas?????
In 4 inspections, this is the first time such a thing has been observed upon and on every inspection prior (with same auditor) the wooden forme exclusion has been fine.
Kind regards,
Steve
Having now got the report from my recent BRC inspection, under observations on oportunities for improvement in areas of compliance the following is stated:
"There is some confusion concerning items which are excluded from consideration under the HACCP plan. Wood cannot be excluded as it is in the process area by virtue of pallets".
The auditor (on the audit) stated that it really should be sub-contracting of production due to no sub-contracting of production being undertaken.
The standard states:
3.2.5 Decide which sections in 5, 6 and 7 are not applicable to the company using hazard analysis, and document the reason for their exclusion.
Sub-contracting of production is under section 4.
Has anyone any ideas?????
In 4 inspections, this is the first time such a thing has been observed upon and on every inspection prior (with same auditor) the wooden forme exclusion has been fine.
Sorry Steve I'm not sure what the auditor means. I can understand subcontracting of production being an exclusion if you don't do any. Can you clarify the wood situation, do you have any in production? Were you claiming an exclusion in your HACCP plan? You should really clarify with the auditor if you don't understand something in the report. Did you by any chance have an extended lunch?
Simon
Sorry Steve I'm not sure what the auditor means.
That was exactly how I felt when I read your posting yesterday.
Perhaps, your auditor is looking for "Wooden Pallet Management" procedures
Thanks for your replys, I have a wood management procedure that is fine and checked prior to palletising any product and hourly quality checks, the exclusion I inserted was:
Wooden Forme(s) (to hold blades for die cutting).
Reason: No other effective base material is available (letters of confirmation from suppliers available on file).
There was a hold up of the report due to a problem with it (auditor write up!!).
I'll drop the auditor an e-mail.
Just a little perplexing as I would have thought such an observation would have incurred a corrective action (NO corrective actions raised on the inspection).
Kind regards,
Steve
You may recall there was a thread on this topic a few months ago Woodexclusion in which a highly experienced BRC/IOP auditor cast doubt on the validity of this exemption.
I can understand your auditor having an issue with your case for exemption of wooden equipment in a particular area in which you happily have wooden pallets which would almost certainly be in worse condition than well cared for cutting formes, I imagine no NC was raised as whether excluded or not the formes were in a condition which the auditor felt unlikely to pose a contamination risk. Although the standard recomends that wooden equipment is removed where practical IMO this allows you to keep wooden formes for which there is no viable alternative without claiming exemption and thus avoiding the confusion with the wooden pallets.
Steve.
You may recall there was a thread on this topic a few months ago Woodexclusion in which a highly experienced BRC/IOP auditor cast doubt on the validity of this exemption.
I can understand your auditor having an issue with your case for exemption of wooden equipment in a particular area in which you happily have wooden pallets which would almost certainly be in worse condition than well cared for cutting formes, I imagine no NC was raised as whether excluded or not the formes were in a condition which the auditor felt unlikely to pose a contamination risk. Although the standard recomends that wooden equipment is removed where practical IMO this allows you to keep wooden formes for which there is no viable alternative without claiming exemption and thus avoiding the confusion with the wooden pallets.
Dear Mart,
Thanks for directing me to the other post, I did not get to read it for whatever reason, and thanks to Brian for enlightening me with the comments there.
I shall amend documentation accordingly.
Kind regards,
Steve