presentation - u schraewer - brc issue 6
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BRC Global Standard for Food Safety Issue 6
Overview of Changes
Seminar
Dublin, 20th March 2012
HOW TO GET STARTED
Ulr ich Schraewer
BRC Issue 6 Seminar Overview of Changes
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About Us
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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
Overview
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What to do first?
Methods & tools explained on key-clauses of section 1 to 7
- Risk Assessment
- Root Cause Analysis
- Plans
Vertical Audit
What to do first?
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Example: Cold Smoked Salmon
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Low Risk/High Care/High Risk Clauses
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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 objectives
3.4.4 Monthly inspections in open product areas
3.9.2 Annually Traceability testing (achievable in 4 hours)
4.13.8 Quarterly in-depth pest control surveys
4.14.2 Four-hourly temp. check - if no alarm on temp. record equipment.
Section 2 : The Food Safety Plan - HACCP
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2.7 Hazard Analysis
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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”
Section 3: FSQM-System
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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
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 Assessment
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Example: Risk Assessment
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Section 3: FSQM-System
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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 non-
conformity….” – Clause 3.7.1
Example: Corrective Action
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Root Cause Analysis
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Ishikawa Diagram - http://en.wikipedia.org/wiki/Fishbone_diagram
5 Why’s - http://en.wikipedia.org/wiki/5_Whys
Example: Root Cause with 5 Why’s
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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 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 Standards
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4.3.1 Layout, product flow & segregation
4.4.4 Building fabric
4.5.2 Utilities
4.11.6.2 CIP
4.13.3 Pest Control
Plan or Schematic Plan is required
?
Section 4: Site Standards
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METAL DETECTOR IS A MUST
OR
ABSOLUTELY WATERTIGHT RISK ASSESSMENT
Section 5: Product Control
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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
http://www.food.gov.uk/multimedia/pdfs/maycontainguide.pdf
http://allergytraining.food.gov.uk/english/default.aspx
Section 6: Process Control
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Temperature Mapping
www.FSAI.ie – Guidance Note No. 20
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www.FSAI.ie – Guidance Note No. 20
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Section 7: Personnel
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Best Practice Tip:
Apply clause 7.4.4 to your in-house laundry!
Protocol – Page 65
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Vertical Audit
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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.
Recap
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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
Thank You
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Thank you for your attention!
www.qsd.ie