4 replies to this topic

[Simon]

BRC/IoP Global Standard - Food Packaging and Other Packaging Materials

SaferPak have reviewed Issue 2 of the Standard and created a guide to the revisions:

Download Review Document (pdf 147kb)

The Standard may be purchased at the following link:

http://www.tso.co.uk...ctID=0117022225

Regards,
Simon

[rheath]

Simon,

Thanks for the guidance notes. I have now had my audit against the new standard and it went pretty smoothly.

Its worth mentioning for those people that allow watches (Category A) that the new standard states (7.6.1) Watches shall not be worn, unless for ethnic, medical or religious reasons.

Wasn’t a problem for us as we don’t allow them anyway..

A few more interesting observations whilst being audited -

Traceability, the auditable clauses are 4.7.1 - The company shall ensure that its suppliers have appropriate traceability systems in place, 4.7.2 - An appropriate system shall be in place to ensure the customer can identify a product.

What about us as manufacturers of packaging - what is the auditable requirement for traceability

6.3.2 - Effective precautions shall be in place to prevent pests entering the premises - no problem with this but why do we then need clauses 6.3.6, 5.1.4 & 5.1.5?

For info 6.3.6 - The building shall be suitably proofed against the entry of all pests including ducts and cable entry points, 5.1.4 - External silos, pipe work or other access points for product and/or materials shall be appropriately sealed so as to prevent pest entry, 5.1.5 - Drains shall be properly trapped or otherwise protected so as to prevent entry of pests.

Surely If you meet 6.3.2, you meet 6.3.6, 5.1.4 & 5.1.5!!

Anyway that’s my observations, pedantic or otherwise

Regards

Richard

[Simon]

What about us as manufacturers of packaging - what is the auditable requirement for traceability

Good point - what did you and the auditor conclude?

6.3.2 - Effective precautions shall be in place to prevent pests entering the premises - no problem with this but why do we then need clauses 6.3.6, 5.1.4 & 5.1.5?

Another good point. Perhaps they should invite you on the next review panel.

Anyway that's my observations, pedantic or otherwise.

Pedantic no. A nit-picker maybe...but NEVER pedantic! :P

Regards,
Simon

[rheath]

Hi Simon,

“Good point - what did you and the auditor conclude?” -

Effectively the conclusion was that it is not possible to give minor non conformances against the standard for our traceability (4.7), however this does not mean that we can do without a traceability system as we would then have a 'substantial failure to meet the requirements of the statement of intent' = major non-conformity.

Although not recommended, in theory you should be able to scrape through 4.7 with a poor traceability system. This said I would suspect the auditor would find a way of ensuring this is reflected somewhere.

With respect to picking holes in the standard - I have to be fair to the Technical Advisory Committee, I am sure it is very difficult to pick up duplication, omissions etc when reviewing pages of text around a table.

My observations were picked up from the actual audit where I had to demonstrate compliance in a live situation.

Do you know if the Technical Committee does trial run audits during the review / drafting phases of new standards? It does seem to highlight problems fairly quickly..

[Simon]

Do you know if the Technical Committee does trial run audits during the review / drafting phases of new standards?  It does seem to highlight problems fairly quickly..

My feeling is they don't run trial audits, but I may well be wrong. Excellent idea though. Maybe someone in the know could tell us more about the review process.

Regards,
Simon