BRC Issue 6 Seminar Overview of Changes HOW TO GET STARTED Ulrich Schraewer QS-Development - BRC for Food Safety Version 6 About Us 2 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 QS-Development - BRC for Food Safety Version 6 Overview 3 What to do first? Methods & tools explained on key-clauses of section 1 to 7 - Risk Assessment - Root Cause Analysis - Plans Vertical Audit QS-Development - BRC for Food Safety Version 6 What to do first? 4 QS-Development - BRC for Food Safety Version 6 Example: Cold Smoked Salmon 5 QS-Development - BRC for Food Safety Version 6 6 QS-Development - BRC for Food Safety Version 6 Low Risk/High Care/High Risk Clauses 7 Filter specification Frequency of air changes Source of air Positive air pressure QS-Development - BRC for Food Safety Version 6 Section 1: Senior Management Commitment 8 At least monthly communication with management Other clauses with defined frequencies: 1.1.2 3.4.4 3.9.2 4.13.8 4.14.2 Quarterly monitoring of objectives Monthly inspections in open product areas Annually Traceability testing (achievable in 4 hours) Quarterly in-depth pest control surveys Four-hourly temp. check - if no alarm on temp. record equipment. QS-Development - BRC for Food Safety Version 6 Section 2 : The Food Safety Plan - HACCP 9 QS-Development - BRC for Food Safety Version 6 2.7 Hazard Analysis 10 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 at each process step” QS-Development - BRC for Food Safety Version 6 Section 3: FSQM-System 11 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 RISK ASSESSMENT QS-Development - BRC for Food Safety Version 6 Other clauses were risk assessment is required: 12 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. QS-Development - BRC for Food Safety Version 6 Example: Risk Assessment 13 QS-Development - BRC for Food Safety Version 6 Example: Risk Assessment 14 QS-Development - BRC for Food Safety Version 6 Section 3: FSQM-System 15 3.7 Corrective Action (Fundamental) 1. “Verification that corrective action has been implemented and is effective.” – Clause 3.7.1 2. “Identification of the root cause of the nonconformity….” – Clause 3.7.1 QS-Development - BRC for Food Safety Version 6 Example: Corrective Action 16 QS-Development - BRC for Food Safety Version 6 Root Cause Analysis 17 Ł Ishikawa Diagram - http://en.wikipedia.org/wiki/Fishbone_diagram Ł 5 Why’s - http://en.wikipedia.org/wiki/5_Whys QS-Development - BRC for Food Safety Version 6 Example: Root Cause with 5 Why’s 18 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? - 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 QAManager. 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. QS-Development - BRC for Food Safety Version 6 Section 4: Site Standards 19 4.3.1 4.4.4 4.5.2 4.11.6.2 4.13.3 Layout, product flow & segregation Building fabric Utilities CIP Pest Control ? Plan or Schematic Plan is required QS-Development - BRC for Food Safety Version 6 Section 4: Site Standards 20 METAL DETECTOR IS A MUST OR ABSOLUTELY WATERTIGHT RISK ASSESSMENT QS-Development - BRC for Food Safety Version 6 Section 5: Product Control 21 5.2 Management of Allergens Risk Assessment required including: “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 QS-Development - BRC for Food Safety Version 6 Section 6: Process Control 22 Temperature Mapping QS-Development - BRC for Food Safety Version 6 www.FSAI.ie – Guidance Note No. 20 23 QS-Development - BRC for Food Safety Version 6 www.FSAI.ie – Guidance Note No. 20 24 QS-Development - BRC for Food Safety Version 6 Section 7: Personnel 25 Best Practice Tip: Apply clause 7.4.4 to your in-house laundry! QS-Development - BRC for Food Safety Version 6 Protocol – Page 65 26 QS-Development - BRC for Food Safety Version 6 Vertical Audit 27 Production Records, Recipe, Mixing Records Supplier (Goods Inwards Record, Delivery Dockets) Customer (Despatch Record, Invoices) Specification Supplier Approval Documents Process Records & SOP’s CCP Records & SOP’s Training Records Cleaning Records Test Results Preventive Maintenance Records Etc. QS-Development - BRC for Food Safety Version 6 Recap 28 Use decision tree to establish your areas + Appendix 2 Review your HACCP flow diagram (include areas identified) Develop plans and schematic plans (include areas identified) Consider new frequencies Conduct risk assessments Conduct a pre-audit Conduct root cause analysis & take appropriate action QS-Development - BRC for Food Safety Version 6 Thank You 29 Thank you for your attention! www.qsd.ie QS-Development - BRC for Food Safety Version 6