Specific questions BRC-IoP

Hello I hope the Topic Title is meaningful enough I could'nt find another.

As I mentioned in my Introduction I'm a student for food packaging technology in Germany and I'm a trainee for a corrugator company to fulfill the BRC-IoP agreements.I have this standard right here.

So we produce some corrugated cardboards that have direct contact to food without any barrier:"High risk cat.1" 

Established standards are GMP, FSC-Chain of Custody, PEFC, quality assurance program, ISO9001:2008, ...(I'm sure there are others but these are directly relied to BRC-IoP I think)

 

Feel free to ask for more informations!

 

 

 

Lets start right away with some questions:

 

1. Regarding 4.8.1:Members at a e.g. cutter machine or corrugator machine do wash their hands at a water conduit witch is needed to wash away the colors from the printing cylinder. Is warm water and soap needed or is an assigment enough that says "Staff members have to wash their hands at given places".
2. Regarding 4.11.3:The manufacturing hall has many roof hatches. Do they need fly screens or are flytraps (with light) enough (plus a risk assess).
3. Regarding 4.2.1:Hardly reachable spots like a roof beam over a machine aren't easy to clean(spiderweb, dust). How accurate do they have to be for the auditor? Can the cleaning be a bit more careless?
4. Do we need arrangements for the roof hatches against sudden rainfall e.g. Sensors? Or an assignment that they have to be closed generally.
5. Are loose objects like eartips acceptable? Because they could fall into maschines because of its type of construction.
6. There are cabines for the staff in the production hall: The employees use them to store their bags and water bottles (in lockers). The door has a closing mechanism but it's often locked so the doors are open.Is this a problem for the auditor?Is this a cause of risk?
7. Regarding 4.8.2:A toilet opens more or less directly into a production hall(It opens into a open runway for the haulage contractors what is separated with a barrier for the lift trucks). The room starts with a straight washing room and to the right toilets.Would it be enough to set up a wall at the beginning of the room (with a door)?Or does this toilet meet the requirements?

 

 

Thats it for now I appreciate every information I can get!
Sorry for my english skills!

 

 

 

Thanks

 

 

 

-André

-

Hello I hope the Topic Title is meaningful enough I could'nt find another.

As I mentioned in my Introduction I'm a student for food packaging technology in Germany and I'm a trainee for a corrugator company to fulfill the BRC-IoP agreements.I have this standard right here.

So we produce some corrugated cardboards that have direct contact to food without any barrier:"High risk cat.1" 

Established standards are GMP, FSC-Chain of Custody, PEFC, quality assurance program, ISO9001:2008, ...(I'm sure there are others but these are directly relied to BRC-IoP I think)

 

Feel free to ask for more informations!

 

Lets start right away with some questions:

 

1. Regarding 4.8.1:Members at a e.g. cutter machine or corrugator machine do wash their hands at a water conduit witch is needed to wash away the colors from the printing cylinder. Is warm water and soap needed or is an assigment enough that says "Staff members have to wash their hands at given places".
2. Regarding 4.11.3:The manufacturing hall has many roof hatches. Do they need fly screens or are flytraps (with light) enough (plus a risk assess).
3. Regarding 4.2.1:Hardly reachable spots like a roof beam over a machine aren't easy to clean(spiderweb, dust). How accurate do they have to be for the auditor? Can the cleaning be a bit more careless?
4. Do we need arrangements for the roof hatches against sudden rainfall e.g. Sensors? Or an assignment that they have to be closed generally.
5. Are loose objects like eartips acceptable? Because they could fall into maschines because of its type of construction.
6. There are cabines for the staff in the production hall: The employees use them to store their bags and water bottles (in lockers). The door has a closing mechanism but it's often locked so the doors are open.Is this a problem for the auditor?Is this a cause of risk?
7. Regarding 4.8.2:A toilet opens more or less directly into a production hall(It opens into a open runway for the haulage contractors what is separated with a barrier for the lift trucks). The room starts with a straight washing room and to the right toilets.Would it be enough to set up a wall at the beginning of the room (with a door)?Or does this toilet meet the requirements?

Thats it for now I appreciate every information I can get!
Sorry for my english skills!

 

Thanks

 

-André

 

Hi André

1.Re:4.8.1
Normally hand-washing facilities should be separate from those for other purposes. The requirement is for 'Suitable and sufficient hand-washing facilities shall be available to enable cleaning of hands before commencing work, after breaks, and as necessary during the course of work. Such hand-washing facilities shall provide, as a minimum:
- Sufficient quantity of warm water
- Unscented liquid soap
- Single-use towels or suitably designed and located air driers
- Advisory signs to prompt use (including consideration of appropriate languages)'.

2.Re:4.11.3
Roof hatches need to be locked or screened

3.Re 4.2.1
If they are difficult to clean and not cleaned at regular intervals then the machine/line should have covers

4. Better they are locked closed as per 2.

5. Loose objects are not acceptable, if you use ear plugs then they should be on a cord and detectable

6. Storage of personal items shouldn't be in the production hall

7. 4.8.2 Possibly adequate segregation if there is an hand wahsing area in between, easier to understand what you are describing if you post a floor plan with the walls and doors

Regards,

Tony
 

Thank you for your answer Tony-C!

 

 

1.Re:4.8.1

Our washing facilities do match the requirements.They are found in every toilet.
We have disinfectant dispensers(And handlotion) at every entrance to the production hall.

So, I understand now that we need an extra washing place as required at specific machines/places in the production right?

 

5. Okay thats an interesting point because a sister company uses loose ear plugs and is BRC/IoP certificated.I will be there in a couple weeks so I let you know what their experience is.

 

6.There are also lockers in the production room at the sister company ONLY FOR BAGS AND WATERBOTTLES.

 

7. You will get your plan ..its 16 o'clock so its closing time!

 

 

 

I hope you are not confused why I'm not asking my company at first...but I want to know as much as I can before I rumble them up :D

Okay heres the plan.I modified it for yr understanding.

Obviously the arrow shows the toilet the green lines are the barrikades.

The blue broken line is the runway for everyone and the yellow line is for the lift trucks.

 

BUT the mentioned straight washing room wasnt right. Its a toilet-cabine on the side what "makes it straight".

 

Whats your opinion on this one?Where should we put up a wall?

 

 

 

 

Another Question:The Cover plates we use for staples are sometimes a bit dusty. But they have no directly contact because of a corrugated cardboard interlayer. Does this fit into the requirements?

Okay heres the plan.I modified it for yr understanding.

Obviously the arrow shows the toilet the green lines are the barrikades.

The blue broken line is the runway for everyone and the yellow line is for the lift trucks.

 

BUT the mentioned straight washing room wasnt right. Its a toilet-cabine on the side what "makes it straight".

 

Whats your opinion on this one?Where should we put up a wall?

 

Another Question:The Cover plates we use for staples are sometimes a bit dusty. But they have no directly contact because of a corrugated cardboard interlayer. Does this fit into the requirements?

 

Mmm... you have a degree of segregation, where are your hand washing facilities? there should be some entering production area?

 

Don't really understand the question! a build up of dust means should be cleaned more regularly if in the vicinity.

 

Regards,

 

Tony

I asked because 4.12.4 says something like "Pallets with direct contact to the product..." ...so, I've thought if theres an interlayer between the product and the plates ( I assume that plates belong to this requirement) there is no direct contact to the product.

 

 

For your info:

My BRC certification contact said that loose ear plugs are allowed. The employee should recognize when the plug falls out.

 

I asked because 4.12.4 says something like "Pallets with direct contact to the product..." ...so, I've thought if theres an interlayer between the product and the plates (I assume that plates belong to this requirement) there is no direct contact to the product.

The interlaywer is a last resort and a temporary solution.
I would try to find a better solution.
 
 

For your info:
My BRC certification contact said that loose ear plugs are allowed. The employee should recognize when the plug falls out.

I have seen loose ear plugs this week in a Dutch factory. It would not be acceptable in the UK in my experience. Why? Becuase it is a potential contaminant and we should not rely on human factor (recognizing) and ultimately it is very easy to get a substitute that works (as Tony mentioned)

Okay interesting...Im totaly on your side! If I would be the client I wouldnt accept this.
But somehow its allowed here. (For the certification)

 

 

And yes I will find another solution...But I dont like to just give an assignment (Cleaning) ...thats so risky

Okay interesting...Im totaly on your side! If I would be the client I wouldnt accept this.
But somehow its allowed here. (For the certification)

 

 

And yes I will find another solution...But I dont like to just give an assignment (Cleaning) ...thats so risky

 

The  reason may be due to the cost of the cord ?.    yr location is clearly successful at merging risk assessment with economic objectives. (Possibly with  the exception of raw RTE vegetables / E.coli O104 from recent memory).

 

Rgds / Charles.C

 

1.Re:4.8.1
Our washing facilities do match the requirements.They are found in every toilet.
We have disinfectant dispensers(And handlotion) at every entrance to the production hall.
So, I understand now that we need an extra washing place as required at specific machines/places in the production right?

 
Why you need handlotion? Is it allowed to be used?

Money always matters Charles.C ;D

@scppvjune
No I dont think its needed for BRC-IoP Maybe for GMP?!
Workers only use it after their work.

 

 

 

 

Do you have some general questions/advice for me what I could ask our sister company?Or what I should look up for?
As you can see (and I mentioned it I think) I'm totaly new to this mess :D

 

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