Are you aware of the top non-conformances since BRC Version 7 was implemented?
Read below for an insight into which BRC 7 clauses were part of the top non-conformances, their areas of coverage and how to prevent them.
The top non-conformance
Supplier Approval and Monitoring and Traceability come straight in at number 1 for the reason of non-conformances identified during audits.
The two clauses relating to Supplier Approval and Monitoring non-conformances are 126.96.36.199, which covers Raw material risk assessment and 188.8.131.52 which covers Supplier risk assessment. The third clause relating to Traceability non-conformances is 3.9.3, which covers Traceability approval of low-risk suppliers (but is surprisingly not part of the independent traceability section, which strangely enough is the second top reason for BRC non-conformance).
So now you know the top BRC 7 non-conformance, but exactly how often do sites fail this part of the audit?
The clause with the highest percentage of non-conformances is 184.108.40.206 (Supplier risk assessment) which equates to 17.8%, closely followed by clause 220.127.116.11 (Raw material risk assessment) at 16.1% and last but not least clause 3.9.3 (Traceability approval of low-risk suppliers) coming in at 10.3%.
Now you know the top cause for non-conformances. Next, we will break these down into more detail so you can have an understanding of what is required for each of these clauses so that you can take steps to ensure you can protect your business from future audits.
Clause 18.104.22.168 (Raw material risk assessment)
Clause 22.214.171.124 is all about raw material risk assessments. In short, a raw material risk assessment aims to outline any potential risks of the raw materials you use within your business, allowing you to mark raw materials as either high or low risk.
As part of BRC Version 7, when being audited the auditor will also be looking for two key parts of your risk assessment. It may be common for businesses to miss out one of these two criteria resulting in the high non-conformance rate.
The criteria for your Raw material risk assessment should be both Fraud and Packaging.
Clause 126.96.36.199 – Supplier risk assessment
Clause 188.8.131.52 is all about supplier risk assessments. As part of BRC Version 7, there are a few new parts of this clause that your business will need to consider.
The biggest cause for non-conformances in this area is providing risk assessments which are not detailed enough to show the auditor that you have considered all possible risks related to your suppliers.
But how do you make sure that your supplier risk assessment is detailed enough?
There are 4 main areas in which you should assess suppliers as part of your supplier risk assessment:
- Volume of raw material used
- Non-conformances, this will be from either delivery issues or issues such as complaints due to the raw material
- Delivery performance
- The risk of the raw material supplied
An important consideration in this section is Volume of raw material used. The way you risk assess this section varies from company to company based on the ingredients your company relies upon. You will need to make sure that this is in detail and relates directly to your business, for example, you may think of sugar as quite a low-risk ingredient, however, if you are a sweet business, a lack of sugar supply will be a risk for your business. Meaning that this risk assessment should be classed as high-risk as opposed to low risk.
After your Supplier risk assessment
After you have performed your supplier risk assessment you may have identified some high-risk suppliers that you will need to carry out an audit or a supplier questionnaire.
To avoid a non-conformance in this area you will need to make sure you have the correct scope in place for your audit or questionnaire.
You will need to ensure that your scope covers the following:
- HACCP review
- Product safety
- Good manufacturing practices
Clause 3.9.3 – Traceability approval of low-risk suppliers
The final clause in which 10.3% of sites fail clause 3.9.3, which is all about having adequate traceability approval of low-risk suppliers.
A slight update to this clause happened in BRC Version 7 which appears to be catching a few people out.
BRC now require you to have a traceability procedure in place for all of your low-risk suppliers as part of the approval and monitoring. Remember, this is a bit of a strange one as this is part of the traceability section of BRC Version 7 and not supplier approval and monitoring, another reason why this may account for 10.3% of non-conformances as it could get overlooked.