First: What has been changed in BRC 7?
- Exclusions are limited to the following conditions: The excluded products can be clearly differentiated from products within scope AND The products are produced in a physically segregated area of the factory
- The shift in ownership from being solely QA’s responsibility, now the entire company needs to have an audit ready mind-set every day, and should take part in ensuring food safety requirements are met.
- Supplier approval requirements now include packaging and, the requirement of risk assessments for substitution or fraud, which should be reviewed at least annually and includes a need for more active verification of any high risk suppliers’ HACCP, food safety, or preventative controls programs. This needs proof that suppliers have a functional traceability program and not just a reliance on COAs or questionnaires.
- Mis-labelling on products and packaging where items need to be changed because of a change in supplier, a new country of sale, or a new country of origin; which must go to all applicable parties; including a formal process for getting labels from the storage room to the line where it is applied to the product.
- Understanding the risks of substitutions, fraud, and economic adulteration. Since this will be different for every site and every industry, carrying out a risk assessment evidences your understanding of the risks to your specific company, which will then require solution focussed mitigating strategies.
The Six most common Non-Conformities in BRC 7?
Auditing has been carried out on BRC Version 7 since July 2015 and a global picture is beginning to emerge of the successes and failures in complying with it. Auditors can also see how their findings compare with colleagues and whether the same failures are recurring globally, or whether regional differences are being discovered. Since every Auditor has attended many training sessions and passed an online examination, before carrying out any Audit’s to Version 7; examining the most common non-conformities found during the first 3 months ought to deliver a message to companies; but will it be good or bad?
John Kukoly, the BRC Americas Director recently published an online webinar The Impact of BRC Food 7: Most Common Non-Conformities which delivers the observations of BRC for the top reasons for audit failure during the first three months of the scheme and offers advice about achieving ongoing successful continuation of certification. Here is the QADEX view of what the most common non-conformities have revealed so far:
1. Supplier Approval BRC V7: 184.108.40.206
BRC7 Requirements: The Company shall have a documented supplier approval and ongoing monitoring procedure to ensure that all suppliers of raw materials, including packaging, effectively manage risks to raw material quality and safety and are operating effective traceability processes.
The approval and monitoring procedure shall be based on risk and include one, or a combination of: a) Certification e.g. to BRC Global Standards or other GFSI recognised scheme. b) Supplier audits, with a scope to include: product safety, traceability, HACCP review and good manufacturing practices, undertaken by an experienced and demonstrably competent product safety auditor. Or for suppliers assessed as low risk only, supplier questionnaires.
Where approval is based on questionnaires, these shall be reissued at least every three years, and suppliers will be required to notify the site of any significant changes in the interim. The site shall have an up to date list of approved suppliers.
This is a vast administrative process for any company to be able to conform to the Standard, and large companies with hundreds of suppliers, will need to put in place robust systems of information gathering, which can require a huge resource input of staff and hours to achieve. A small company with fewer suppliers can be equally hard pressed to find the available man hours from a smaller employee base.
The major difficulty with this, is that the information needs to be gathered from a third party, and this is going to eat up more time than you might imagine. Firstly by chasing in responses to a questionnaire for suppliers who are identified as low risk; or more importantly for suppliers with a higher perceived probability of risk; instigating a process for them to undergo certification or supplier evaluation, focusing on traceability and food safety.
Involving Purchasing, Production and QA in the process.
The audit process is identifying that a truly robust programme of Supplier Approval needs to include all areas of the company who have dealings with them. Namely: QA – who will need to know the responses from each supplier in order to complete their quality assurance processes. Purchasing – to validate their decision to buy from each specific supplier over another, and Production – because they will have the evidence for why each chosen ingredient is needed.
Watertight Inventory Process
Auditors have been able to discover gaps in the inventory process, especially where some raw ingredients arrive rarely or sporadically, or are so insignificant, that they have been omitted from the programme. This can happen when a large stock of a little used ingredient means that it has not been purchased since the new programme came into effect, and Auditors are finding them having slipped through the net.
Cheaper suppliers can be higher risk
The audit process is uncovering a higher level of risk in using less qualified suppliers who have been chosen because of their cheaper cost of the ingredient. The senior managers should understand how to evaluate this against the higher cost of an ingredient with its inherent reduced risks.
QADEX have an easy software solution that can do all this for you. Details of it are here: http://www.qadex.com/supplier-risk/supplier-approval-management
2. Vulnerability Assessment 5.4.2
BRC7 Requirements: A documented vulnerability assessment shall be carried out on all food raw materials or groups of raw materials, to assess the potential risk of adulteration or substitution. This shall take into account:
- Historical evidence of substitution of adulteration
- Economic factors which may make adulteration or substitution more attractive
- Ease of access to raw materials through the supply chain
- Sophistication of routine testing to identify adulterants
- Nature of the raw material
The vulnerability assessment shall be kept under review to reflect changing economic circumstances and market intelligence which may alter the potential risk. It shall be formally reviewed annually.
Levels of understanding
The audit process is revealing the general levels of understanding in each industry about the risks of food fraud. Does your site have information about the possibilities for fraud with the ingredients used in your products, and do you know where to look for this information? Being able to evidence that your company understands these risks can be relatively simple to achieve if you have managers who have undertaken any training to do with food fraud, and if they can then evidence to the auditors, that they are using recognised risk assessment tools to determine the level of risk.
Implement a complete strategy
Of course, this needs to be taken on to its natural conclusions for any risk assessment process, and for a strategy of risk mitigations to be identified, agreed and put in place. This may involve being a member of various trade associations to ensure that up to date information is received, as well as keeping up to date with helpful web based information sites, such as www.foodfraud.org and receiving their weekly or monthly newsletters (online or hard copy)
QADEX have an easy software solution that can do all this for you. Details of it are here: http://qadex.com/vulnerability-tool
3. Supplier Risk Assessment 220.127.116.11
BRC7 Requirements: The Company shall undertake a documented Risk Assessment of each raw material or group of raw materials including packaging, to identify potential risks to product safety, legality and quality. This shall take into account the potential for: Allergen contamination, foreign body risks, microbiological contamination, chemical contamination, substitution or fraud.
Consideration shall also be given to the significance of a raw material to the quality of the final product. The risk assessment shall form the basis for the raw material acceptance and testing procedure and for the processes adopted for supplier approval and monitoring. The risk assessments shall be reviewed at least annually.
Grouping can help:
Packaging can be classed as a group of raw materials as can individuals, and the above test must be made on everything you buy from suppliers. If you can sensibly ‘group’ raw materials, this will avoid having to carry out separate risk assessments for each one. For a Supermarket bringing in hundreds of ingredients, this would otherwise need a team of full time staff1. Easy groups would be things such as: Dry goods, wet goods, Tinned goods, plastic goods, powdered goods, etc.
Don’t forget to include all the different types of packaging for your products, and think bigger than just your specific site, thinking as broadly as you can about everything that could possibly be a risk to your general industry or market sector. I’m sure we don’t need to remind you of the dreaded horsemeat scares, but utilise that style if ‘what if’ thinking.
QADEX have an easy software solution that can do all this for you. Details of it are here: http://www.qadex.com/supplier-approval-procedure/supplier-relationship-management-software/
4. Ingredient / WIP Identification 3.9.1
BRC7 Requirements: Identification of raw materials including primary and any other relevant packaging, processing aids, intermediate / semi processed products, part used materials, finished products and materials pending investigation shall be adequate to ensure traceability.
Keep track of all ingredients
This means that no matter how long it takes your finished product to be made, and how many stages it may go through during final production, the traceability of each separate ingredient should be able to be determined anywhere along its journey. This can be achieved with an appropriate system of labelling and the procedures recorded and logged to present during the audit process.
Staff Training opportunity
Making sure that the right labels follow the production process can easily involve lots of different staff, in many different rooms or production areas. This is a good opportunity to engage them all in your traceability programme, by explaining why the labels are required, and to enlist their help in making the process as efficient as possible on every production run.
5. Chemical Controls 18.104.22.168
BRC7 Requirements: Processes shall be in place to manage the use, storage and handling of non-food chemicals to prevent chemical contamination. These shall include as a minimum:
- An approved list of chemicals for purchase
- Availability of material safety data sheets and specifications
- Confirmation of suitability for use in a food processing environment
- Avoidance of strongly scented products
- The labelling and or identification of containers of chemicals at all times
- A designated storage area with restricted access to authorised personnel
- Use by trained personnel only
Internal Audits will help
It sounds too simple to say ‘control the choice and use of all chemicals’ as there can be many protocols around the use of some of them. But correct labelling, storing and handling by suitable ‘trained’ personnel, with written statements or protocols of how they are used should be in place.
If you do not have ‘Laboratory’ trained staff who are used to such stringent processes, and the signed authorisation – or at least recording of usage in a log book – then any reputable Health and Safety Consultant, should be able to deliver these procedures for you to implement, self-audit and then provide the evidence during the BRC standard version 7 audit.
6. Door Conditions 4.4.9
BRC7 Requirements: Doors shall be maintained in good condition. External doors and dock levellers shall be close fitting or adequately proofed. External doors to open product areas shall not be opened during production periods, except in emergencies.
Where external doors to enclosed product areas are opened, suitable precautions should be taken to prevent pest ingress.
Evidence with Maintenance processes
This out to be an easy point to make sure that you comply with. Joint working with your maintenance manager should identify the level of inspection and maintenance for the doors concerned, and if they are not specifically mentioned in the maintenance book or list of routine checks, it is a simple task to add this line into them. A secondary form of internal barrier can be decided on with your maintenance team.
Then evidencing that this is covered by your maintenance contract during BRC7 Audits will be a simple matter. Especially if any repair procedure carried out on them is also recorded and dated and can be shown to the auditors. The reason for the repair will show the auditor that you have considered what has caused any damage and taken suitable steps to prevent it recurring.
We hope that this will give a quick reference to checking your systems before your next audit for BRC 7, and don’t forget that QADEX can also help you to achieve the first three, with our approved software packages that can help any sized company, from a small family business, to a large independent supermarket or brand.
If you would like more information on how this might work for you, just call us on:
+44 (0) 845 302 4780 or click here to contact us and request a meeting