brc6 global food - handling of selected issues

HOW TO GET STARTED

BRC Issue 6 Seminar Overview of Changes

HOW TO GET STARTED

Ulr ich Schraewer

QS-Development - BRC for Food Safety Version 6

About Us2

� Degree in Food Science & Technology

� Over 11 years experience working/auditing in the Food Industry


� ISO 9001 Lead Auditor

� BRC Certification Auditor

� IFS Food Certification Auditor

Overview3

� What to do first?

� Methods & tools explained on key-clauses of section 1 to 7

- Risk Assessment


- Risk Assessment

- Root Cause Analysis

- Plans

� Vertical Audit

What to do first?4


Example: Cold Smoked Salmon5


6


Low Risk/High Care/High Risk Clauses7


� Filter specification

� Frequency of air changes

� Source of air

� Positive air pressure

Section 1: Senior Management Commitment

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At least monthly communication with management


Other clauses with defined frequencies:

1.1.2 Quarterly monitoring of objectives3.4.4 Monthly inspections in open product areas3.9.2 Annually Traceability testing (achievable in 4 hours)4.13.8 Quarterly in-depth pest control surveys4.14.2 Four-hourly temp. check - if no alarm on temp. record equipment.

Section 2 : The Food Safety Plan - HACCP9


2.7 Hazard Analysis10

Clause 2.7 in conjunction with clause 5.2.3

Third bullet point of clause 5.2.3:

� “Assessment of the risk of allergen cross-contamination


� “Assessment of the risk of allergen cross-contamination

at each process step”

Section 3: FSQM-System11

3.4 Internal Audit (Fundamental)

“The scope and frequency of the audits shall be established in relation to the risks associated with the activity and

previous audit performance…” - Clause 3.4.1


previous audit performance…” - Clause 3.4.1

RISK ASSESSMENT

Other clauses were risk assessment is required:

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� 3.4.4 Risk Assessment (RA) for the frequency of inspection

� 3.5.1.1 RA for each raw material or group of materials

� 4.5.1 RA for water sampling points and frequency


� 4.10.6 RA to minimise foreign body contamination of packaging containers

� 4.11.1 RA for frequency and methods of cleaning

� 4.13.8 RA for the frequency of in-depth pest control surveys

� 6.3.2 RA frequency of checking measuring devices.

Example: Risk Assessment13


Example: Risk Assessment14


Section 3: FSQM-System15

3.7 Corrective Action (Fundamental)

1. “Verification that corrective action has been implemented and is effective.” – Clause 3.7.1


implemented and is effective.” – Clause 3.7.1

2. “Identification of the root cause of the non-conformity….” – Clause 3.7.1

Example: Corrective Action16


Root Cause Analysis17

Ł Ishikawa Diagram - http://en.wikipedia.org/wiki/Fishbone_diagram

Ł 5 Why’s - http://en.wikipedia.org/wiki/5_Whys


Example: Root Cause with 5 Why’s18

1. Why was no review of the competencies of staff carried out? (Clause 7.1.5)

- QA Manager forgot.

2. Why did the QA Manager forget to carry out the review?

- The QA Manager did not check the review summary sheet.

3. Why didn’t the QA-Manager check the review summary sheet?


3. Why didn’t the QA-Manager check the review summary sheet?

- The QA Manager did not get any reminder.

4. Why didn’t the QA Manager get any reminder?

- The QA Assistant was on holidays and there is no software to remind the QA-Manager.

5. Why is there no software with reminder option for reviews?

- A paper system instead of paperless system is used.

- Existing software is poor and does not provide review options.

Section 4: Site Standards19

4.3.1 Layout, product flow & segregation

4.4.4 Building fabric

4.5.2 Utilities

?QS-Development - BRC for Food Safety Version 6

4.5.2 Utilities

4.11.6.2 CIP

4.13.3 Pest Control

Plan or Schematic Plan is required

?

Section 4: Site Standards20


METAL DETECTOR IS A MUST

OR

ABSOLUTELY WATERTIGHT RISK ASSESSMENT

Section 5: Product Control21

5.2 Management of Allergens

Risk Assessment required including:

“Consideration of the state of the allergenic material


“Consideration of the state of the allergenic material

,i.e. powder, liquid, particulate.” – Clause 5.2.3

Ł http://www.food.gov.uk/multimedia/pdfs/maycontainguide.pdf

Ł http://allergytraining.food.gov.uk/english/default.aspx

Section 6: Process Control22


Temperature Mapping

www.FSAI.ie – Guidance Note No. 2023


www.FSAI.ie – Guidance Note No. 2024


Section 7: Personnel25


Best Practice Tip:

Apply clause 7.4.4 to your in-house laundry!

Protocol – Page 6526


Vertical Audit27

� Production Records, Recipe, Mixing Records

� Supplier (Goods Inwards Record, Delivery Dockets)

� Customer (Despatch Record, Invoices)

� Specification

� Supplier Approval Documents

Process Records & SOP’s


� Process Records & SOP’s

� CCP Records & SOP’s

� Training Records

� Cleaning Records

� Test Results

� Preventive Maintenance Records

� Etc.

Recap28

þ Use decision tree to establish your areas + Appendix 2

þ Review your HACCP flow diagram (include areas identified)

þ Develop plans and schematic plans (include areas identified)

þ Consider new frequencies


þ Consider new frequencies

þ Conduct risk assessments

þ Conduct a pre-audit

þ Conduct root cause analysis & take appropriate action

Thank You29

Thank you for your attention!


www.qsd.ie