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BRC Scope decision

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John Moreton

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Posted 10 September 2015 - 08:35 AM

HI All

 

We have a decision to make for our scope of activity on the BRC audit.

 

Background

 

We manufacture vitamin and minerals Tablets and Capsules and also blend Sport Nutrition Powder, We then sell this in bulk IE in boxs of 1 mill Tabs/Caps ...... And we also provide a service where we can package these in to bottles

 

Decision

 

I want the scope of the Audit to cover the manufacturing of the tablets and caps in to Bulk and not include the packaging service we provide.

 

( We dont have an end of line detection device for packaging only at the manufacturing end)

 

 

I have conflicting advice saying we need to cover both processes/services and some say no just the Bulk service is fine however we would not be able to use the BRC logo/Accreditation on the bottle we package ( Which is fine )

 

I would really appreciate people views on this.

 

John 



CLS

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Posted 10 September 2015 - 11:50 AM

I may be naïve  but I would say the scope is your choice -  it may affect your marketability with customers however.


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trubertq

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Posted 10 September 2015 - 01:24 PM

Oh God no...scope is not your choice.....I'm reading up on it now and I'll be back to you in a bit


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trubertq

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Posted 10 September 2015 - 01:49 PM

OK , the standard says that you agree the scope with the CB before the audit, this is usually settled during a pre-audit and then they just ask each year if you want to change the scope. I know from experience that they are none too keen on exclusions for the obvious reason that they don't want people getting one product certified and then claiming certification for everything produced on a site. However, the company I work with HAVE exclusions but there are definite criteria and I quote:

 

" the excluded products can be clearly differentiated from products within the scope"

 

AND

 

"the products are produced in a physically segregated area of the factory"

 

 

it further says:

 

The certification of products must include audit of the entire process from raw material to end-product dispatch. It is not possible to exclude either parts of the process undertaken at the site OR parts of the standard.

 

So ...if your bottling line is in a separate part of the site segregated from the bulk area then you should have no problem.....you could always risk assess the requirements for a end of line metal detection ( I think this what you meant bu 'end of line detection') and show that it isn't necessary if that's all that's holding you back from having the smaller packs in the scope.

 

The absolute best people to speak to about this are the Certification body... I don't know what your plant looks like but this is based on my experience in a site which has exclusions.


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John Moreton

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Posted 10 September 2015 - 02:10 PM

Ah...well. we have a clear segregation in the process from manufacturing in to bulk and the bulk in to packaging, they are essentially 2 different process/products.

 

I understand the exclusion statements but i feel we can match what you highlighted " the excluded products can be clearly differentiated from products within the scope"

 

However they are all done in the same clean room/site complex.....but in separate enclosed rooms manufacturing one end of the complex and packaging the other end.



DavidAR

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Posted 11 September 2015 - 09:48 AM

Agree with above posts, however i argue some points especially when you consider for example some sites may bulk something then transport it to another site up the road for packing. (35 mile rule i think it is) where the scope of your initial site would cover that site too, beyond 35 miles then it would need its own certification.

 

 

I would as described above however argue / debate this out with your Certification Body as they may be able to help guide you in the right direction.

Second to this im presuming this is your 1st audit or you would perhaps have scope defined on previous years audit certificate?



trubertq

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Posted 11 September 2015 - 03:32 PM

I reckon that if you have separate enclosed rooms within the complex then you should be ok for exclusion, but as I said ... you need to talk to your Certification body.


I'm entitled to my opinion, even a stopped clock is right twice a day



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