3 replies to this topic

[Peter Bramwell]

I believe it is possible to omit certain points from the BRC/IoP audit if it is not relevant to your company. Has anybody found the best way to do this?

Pete

[MartLgn]

I believe it is possible to omit certain points from the BRC/IoP audit if it is not relevant to your company. Has anybody found the best way to do this?

Pete

Peter.

There is sort of but I wouldn't get the scissors out just yet .

There is a clause in the standard that allows you to propose an exemption from certain clauses if your Hazard Analysis indicates there is no risk posed by doing so rather than it not being relevant to your company, this distinction is more important than it may seem at first as you must have solid evidence to support your exemption proposal and the auditor must accept it as a valid reason for them not to audit against a particular clause. Although the standard has a broad scope it is written in such a way that that there are no significant parts that are not applicable to any packaging producer. I believe the background to the exemption proposal is to allow facilities such as papermills and glass factories exemption from blatantly innnapropriate measures rather than allowing companies with more controllable environments to cherry pick the most appropriate parts of the standard for them.

Edited by MartLgn, 29 November 2006 - 05:31 PM.

[Gaskit]

Peter.

There is sort of but I wouldn't get the scissors out just yet .

There is a clause in the standard that allows you to propose an exemption from certain clauses if your Hazard Analysis indicates there is no risk posed by doing so rather than it not being relevant to your company, this distinction is more important than it may seem at first as you must have solid evidence to support your exemption proposal and the auditor must accept it as a valid reason for them not to audit against a particular clause. Although the standard has a broad scope it is written in such a way that that there are no significant parts that are not applicable to any packaging producer. I believe the background to the exemption proposal is to allow facilities such as papermills and glass factories exemption from blatantly innnapropriate measures rather than allowing companies with more controllable environments to cherry pick the most appropriate parts of the standard for them.

Having learn't a valuable lesson from another thread regarding exemptions, I opted for the following:

Section 4.12 of BRC / IoP Subcontracting of production.

I have inserted a page in the quality manual (official document and controlled) which states:

A N OTHER does not employ sub-contract packer for any products.

Seems to work!

Regards,

Steve

[Simon]

Peter,

If you tell us what category you are (A/B?), what your product is and what you are try to omit we'll talk it over.

Simon