Transcript BRC TECHNICAL STANDARD FOR COMPANIES SUPPLYING …

AWARENESS TRAINING
PROGRAMME
Technical Standard and Protocol for Companies
Supplying Retailer Branded Food Products
presented by
David Burns
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Who Were Involved ?
Retailers
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Safeway
Tesco
Asda
Sainsbury
Iceland
Somerfield
CWS
Boots
Waitrose
Trade
Associations
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FDF
BACFID
Inspection
Bodies
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Accreditation
Body
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EFSIS
TLC
Law Labs
RSSL
National Britannia
UKAS
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Consistency of Inspection
HIGHER LEVEL
Additional
Beneficial
Practices
BEST
PRACTICE
RECOMMENDATIONS
UKAS & EN 45004
NEW EN 45011
FOUNDATION
LEVEL
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Benefits of the Standard
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Accepted Standard based on best practice
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Inspection bodies accredited to EN45004 to achieve
maximum consistency in application and interpretation
(this is changing to EN 45011, refer to Protocol section)
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Open and transparent
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Encourages continuous improvement
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Cost effective, removes need for multiple inspections
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UKAS Accreditation (Mark)
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Benefits for the Retailer
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Removes “burden” of “routine” visits
Focus on HACCP development
Focus on quality
Focus on complaint issues
Focus on “hot” issues e.g GMO,allergen
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Benefits for the Manufacturer
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Resource benefit as due diligence visits
are reduced
Focus on factory issues
Focus on development
Focus on specific Retailer requirements
Cost effective, independent and
professional audit
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CERTIFICATION
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Accredited Certification (UKAS):
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Quality Management
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Product Certification
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TYPES OF STANDARDS
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Food Standards in Europe
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Voluntary Codes
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EU Legislated
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TYPES OF STANDARDS
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Voluntary Codes (for example)
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Animal Feeds
Cereals
Horticultural Produce
Dairy Produce
Beef, Lamb, Pork
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TYPES OF STANDARDS
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EU Legislated (for example)
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Food Labelling
Beef Labelling
Organic Food Production
Egg Production
Animal Welfare
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Environment
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HACCP
Majority of Food Chain Standards
incorporate
Hazard Analysis Critical Control Point
(HACCP)
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BRC - STANDARD CONTENTS
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1. HACCP System
2. Quality Management System
3. Factory Environment Standards
4. Product Control
5. Process Control
6. Personnel
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BRC - TECHNICAL STANDARD
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The BRC Standard is divided into two
levels, as follows:
Foundation Level
 Higher Level
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BRC & HACCP
Useful reference documentation as suggested by
the BRC Working Group
Title:
Hazard Analysis Critical Control Points (HACCP)
system Guidelines for its Application
Published in:
Codex Alimentarius Food Hygiene Texts
Ref. Number:
ISBN 92-5-104021-4
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THE STANDARD REQUIREMENTS
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1. HACCP
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HACCP - Principles
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Conduct hazard analysis
Determine critical control points
Establish critical limits programme
Monitor against programme
Establish corrective action
Verification and validation records
Establish documentation
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THE STANDARD REQUIREMENTS
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HACCP - Risk
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Assessment of the identified risk
Reference to appropriate technical documentation
Prioritisation of monitoring programme
Monitor recurring trends
Underpinned by technical personnel
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THE STANDARD REQUIREMENTS
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HACCP - Management
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HACCP led by Senior Management commitment
Reference to product legal and safety obligations
Technically competent HACCP team
Plotting the CCP through the production process
Identification with reference to technical working
instructions / methods for CCP
Proof of training / awareness for HACCP at all
appropriate levels
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THE STANDARD REQUIREMENTS
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2. QUALITY MANAGEMENT SYSTEM
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2.1 Quality Management System (QMS)
General Requirements
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Identify the processes needed for the QMS
application
Sequence and interaction of processes
Determine criteria and methods to ensure operational
control(s)
Resources management
Monitor, measurement and analysis
Implementation, planning and improvement
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THE STANDARD REQUIREMENTS
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2. QUALITY MANAGEMENT SYSTEM
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2.2 Quality Policy Statement
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Published statement by the Top Management
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Commitment to the Standard requirements
Appropriate to the purpose of the company
Commitment to continuous improvement
Establishing and reviewing quality objectives
Communicated and understood
Reviewed for continuing suitability
Authorised and approved by Top Management
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THE STANDARD REQUIREMENTS
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2.3 Quality Manual
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Development and maintenance of a formal
documented management system
The manual should be fully implemented and
supported by documented evidence (internal systems
auditing)
Procedures, and where applicable, referring to
specification and methods
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THE STANDARD REQUIREMENTS
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2.4 Organisational Structure, Responsibility and
Management Authority
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Authority and communication at appropriate levels
Responsibility of the management
Including clear responsibility of safety, legal,
environmental and quality matters
Technical responsibility of product compliance to
specification
Details of deputy personnel
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THE STANDARD REQUIREMENTS
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2.5 Management Commitment
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Top management commitment to the QMS
Importance of meeting customer, statutory and
regulatory requirements
establishing the quality policy
Ensuring quality and business objectives are established
Conducting management reviews
Ensuring the availability of resources
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THE STANDARD REQUIREMENTS
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2.6 Customer Focus
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Top management shall ensure that the customer
requirements (and expectations) are determined and are
met with the aim of enhancing customer satisfaction
Customers may include:
The immediate retailer
The transporter
The wider community, and consumer
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THE STANDARD REQUIREMENTS
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2.7 Management Review
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Top management shall ensure that the QMS is reviewed
at regular intervals, consistent with the management
objectives.
Agenda (may include):
Internal audit
Customer complaints
Production issues
Supplier evaluation of performance
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THE STANDARD REQUIREMENTS
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2.8 Resource Management
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The company shall determine and provide the resources
needed;
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To implement and maintain the QMS and continually
improve its effectiveness, and;
to enhance customer satisfaction by meeting customer
requirements
To provide financial resources required for HACCP study
and implementation
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THE STANDARD REQUIREMENTS
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2.9 Internal Auditing
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Programme of audits in consideration of risk
Senior management approval
Technical personnel
Documented results of audit
Review of audit results
Corrective and preventive actions
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THE STANDARD REQUIREMENTS
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2.10 Purchasing
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Purchasing information shall describe the product to be
purchased, including requirements;
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For approval of product, procedures, processing and
equipment
For qualification of personnel, and
Quality management system
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THE STANDARD REQUIREMENTS
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2.10.1 Supplier Performance Monitoring
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The evaluation and selection of suppliers;
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Formal evaluation and selection
Approved supplier list (product impact)
Product receipt inspection
Performance monitoring
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THE STANDARD REQUIREMENTS
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2.10.1 Supplier Performance Monitoring
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Supplier conformance with HACCP
Traceability of product supplied
Verification of supplier claims / approvals
Method and frequency of assessment in consideration of
risk
Supplier audits (programme)
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THE STANDARD REQUIREMENTS
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2.11 General Documentation Requirements
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2.11.1 Document Control
2.11.2 Specifications
2.11.3 Procedures
2.11.4 Record Keeping
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THE STANDARD REQUIREMENTS
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2.11.1 Document Control
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Policy statement
Quality manual
Technical procedures and methods
Administration procedures
Supporting records and archives
Reference standards appropriate to the scope
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THE STANDARD REQUIREMENTS
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2.11.2 Specifications
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Product specification
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Product name
Customer supplied specifications
Unique reference / issue number
Authorisation
Availability at point of use
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THE STANDARD REQUIREMENTS
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2.11.2 Specifications
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The company shall ensure that appropriate
specifications exist for:
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Raw materials (including packaging)
Completed products (including packaging)
In-process / part completed (where applicable)
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THE STANDARD REQUIREMENTS
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2.11.3 Procedures
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Production and administration control
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Procedure / process name
Customer supplied procedures (and methods)
Unique reference / issue number
Authorisation
Availability at point of use
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THE STANDARD REQUIREMENTS
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2.11.3 Procedures
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Production and administration control
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Process and performance driven
Clear, unambiguous and legible
Issued to appropriate personnel
Readily accessible at all times
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THE STANDARD REQUIREMENTS
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2.11.4 Record Keeping
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Information and data generated from the QMS
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Name of record(s)
Location of record(s) and traceability
Unique reference / issue number
Retention period (legal and/or contract obligation)
Disposal of archive records
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THE STANDARD REQUIREMENTS
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2.11.4 Record Keeping
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(continued summary)
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In line with procedures
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Records must be legible and genuine
Safe storage, traceable and retrievable
Contain appropriate information safety, testing,
legality and product quality
Computer back-up (as applicable)
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THE STANDARD REQUIREMENTS
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2.11 General Documentation Requirements
(continued summary)
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Reference standards appropriate to the scope, may include;
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Food Safety
Compositional standards
Metrology
Additives
Lot identification and traceability
Labelling and packaging information
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THE STANDARD REQUIREMENTS
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2.11 Documentation Control (continued summary)
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Approved for adequacy prior to issue
Documents shall be authorised
Identification and issue status controlled
Ensure access to documentation at all appropriate
levels
Control of customer / supplier documents
Obsolete documentation removed from use
Completed documents and records controlled
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THE STANDARD REQUIREMENTS
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2.12 Corrective Action
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Investigation of cause
Assessment of risk
Corrective actions completed in a timely manner
Implementation of corrective actions
Review of corrective actions
Verification of actions
Impact - Refer to HACCP
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THE STANDARD REQUIREMENTS
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2.13 Traceability
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Raw materials
Work in progress
Finished goods
Product identifiable at all stages of production
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THE STANDARD REQUIREMENTS
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2.13 Traceability (continued summary)
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Raw materials supply
Component supply
Packaging supply
Product re-call at all stages of production
Appropriate reference documentation
Reworking operations control
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THE STANDARD REQUIREMENTS
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2.14 Management Of Incidents and
Product Recall
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Product re-call at all stages of production
Appropriate reference documentation
Testing of the system(s)
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THE STANDARD REQUIREMENTS
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2.14 Management Of Incidents and
Product Recall
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Documented incident reporting procedure
Customer notification
Documented recall procedure
Product re-call at all stages of production
Control of non conforming products
Corrective and preventive actions
Verification of recall systems
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THE STANDARD REQUIREMENTS
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2.15 Complaint Handling
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Documented system for complaints
Effective management review
Implementation of corrective and preventive actions
Complete records of action taken
Approval of actions
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THE STANDARD REQUIREMENTS
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3. FACTORY ENVIRONMENT STANDARDS
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3.1 Location
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Location away from “offensive” trades
Maintenance of buildings and infrastructures
Internal fabric to prevent contamination
Boundaries clearly defined
Security of site location
Authorised movement of personnel
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THE STANDARD REQUIREMENTS
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3.2 Perimeter & Grounds
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Proper drainage
Waste water
Contaminated water / effluent
Storage protected from contamination
Security of the site boundary
Regular monitoring (audited)
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THE STANDARD REQUIREMENTS
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3.3 Layout / Product Flow
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Process flow to prevent contamination
Operative working space
Cross contamination (biological / chemical)
Laboratory facilities (where provided)
Environmental controls
Washing of equipment
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THE STANDARD REQUIREMENTS
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3.4 Fabrication
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3.4.1Walls
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Should be appropriate design
Finished surfaces
Removal of dirt, mould, bacteria
Consideration when cleaning of corners
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THE STANDARD REQUIREMENTS
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3.4 Fabrication
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3.4.2 Floors
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Water / drainage flow away from “high risk”
Clean and well maintained
Should be appropriate design
Finished surfaces
Removal of dirt, mould, bacteria
Consideration when cleaning of corners
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THE STANDARD REQUIREMENTS
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3.4 Fabrication
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3.4.3 Ceilings / Overheads
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Clean and well maintained
Should be appropriate design
Finished surfaces
Removal of dirt, mould, bacteria
Consideration when cleaning of corners
Falling items / dirt
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THE STANDARD REQUIREMENTS
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3.4 Fabrication
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3.4.4 Windows
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Clean and well maintained
Should be appropriate design
Prevention of ingress of pests
Glass should be protected from breakage
Use of glass should be avoided
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THE STANDARD REQUIREMENTS
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3.4 Fabrication
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3.4.5 Doors
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Clean and well maintained
Should be appropriate design
Prevention of ingress of pests
Use of glass should be avoided
Use of curtains
Secure
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THE STANDARD REQUIREMENTS
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3.4 Fabrication
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3.4.6 Lighting
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Should be adequate to carry out the function
Should be appropriate design
Glass (bulb, strip lights) should be protected
EFK tubes should be protected
Procedures for replacement of lighting
Glass management
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THE STANDARD REQUIREMENTS
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3.4 Fabrication
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3.4.7 Air Conditioning / Ventilation
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Should be appropriate design
Adequate ventilation
Dust and fume extraction
Use of filters
Air movement monitoring
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THE STANDARD REQUIREMENTS
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3.4 Fabrication
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3.4.8 Services
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Use of water, ice, and steam supply
Cleaning according to source
Monitored to prevent risk of contamination
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THE STANDARD REQUIREMENTS
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3.5 Equipment
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Positioned to give access
Ease of cleaning
Properly specified and commissioned
Planned maintenance programmes
Working use and set-up instructions
Operate to legal and safety requirements
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THE STANDARD REQUIREMENTS
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3.6 Maintenance
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Planned maintenance programme
Technically competent personnel
Outside Contractors
Manufacturers instruction (where applicable)
Breakdown procedures
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THE STANDARD REQUIREMENTS
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3.7 Staff Facilities
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Changing facilities
Work-wear appropriate to the task for staff and
visitors
Suitable equipment
Hand-washing / shower facilities
Toilet, smoking and catering facilities
Personal lockers and food controls
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THE STANDARD REQUIREMENTS
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3.8 Physical & Chemical Contamination Risk
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Appropriate and secure storage areas
Handling procedures and personnel training
Elimination (where possible) of wood, glass, clear
plastics in the raw material process areas
Glass and hard plastic register
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THE STANDARD REQUIREMENTS
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3.9 Housekeeping & Hygiene
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Cleaning schedules
Approved cleaning instruction / methods
Use of approved cleaning detergents
Cleaning practices to minimise the risk of cross
contamination
Monitoring of effectiveness
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THE STANDARD REQUIREMENTS
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3.10 Waste / Waste Disposal
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Minimise accumulation of waste in production
Disposal must meet legal requirements
Use of licensed waste contractors
Use of appropriate containers (closed / covered)
Aware of waste packaging regulations (obligation
towards recovery / recycling initiatives)
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THE STANDARD REQUIREMENTS
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3.11 Pest Control
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Use of approved contractors for pest control
Records and location of pest control baits
Correctly sited E.F.K’s
Use of screens on drains
Minimise waste materials on site
Raw materials inspected for pest infestation
Baits identified on plan
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THE STANDARD REQUIREMENTS
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3.12 Transport
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All vehicles must be fit for purpose
Good repair and hygienic
Part of a cleaning programme
Refrigeration controls must be to specification
In transit breakdown procedures (product controls:
safety, legality and quality)
Maintenance programme
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THE STANDARD REQUIREMENTS
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4. PRODUCT CONTROL
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4.1 Product Design / Development
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New products shall under-go production trials
Processes reviewed to ensure legally safe
Product testing and verification of methods
Shelf life cycles to be confirmed / verified
Use of storage conditions detailed
Plot new processes (HACCP)
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THE STANDARD REQUIREMENTS
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4.2 Product Packaging
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Minimise risk of contamination from packaging
Confirm packaging conforms to specification
Food safety legislation
Use of metal staples / other items
Packaging stored separate from raw materials
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THE STANDARD REQUIREMENTS
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4.3 Product Analysis
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Confirm product conforms to specification
Test results reliable
Use of accredited test laboratory
Technically qualified personnel
Records of results and verification
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THE STANDARD REQUIREMENTS
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4.4 Segregation
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Prevention of cross-contamination
In-process controls:
raw meat
cooked meat
packaging
waste materials
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THE STANDARD REQUIREMENTS
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4.5 Stock Rotation
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Identification of product location
Unique stock / item number
Details of shelf life
Product labelling (supplier traceable)
Internal audit programme
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THE STANDARD REQUIREMENTS
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4.6 Metal Detection / Foreign Body Detection
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Form a part of the HACCP documentation
Appropriate to the nature of the product
Minimise the risk
Procedures for equipment use
Maintenance of equipment
Isolation and quarantine procedures
Form a part of the internal audit programme
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THE STANDARD REQUIREMENTS
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4.7 Product Release
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Final product inspections / tests
Records of all inspections
Authorised personnel only (procedures)
Use of despatch documentation
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THE STANDARD REQUIREMENTS
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4.8 Control of Non-Conforming Product
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The company shall deal with non-conformity using
one or more of the following methods;
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Reject, remove and destroy product
Authorising product use by concession
Taking action to preclude product original use
Product correction, verified to specification
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THE STANDARD REQUIREMENTS
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4.8 Control of Non-Conforming Product
(continued summary)
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Identification of product
Segregation of product
Total rejection controls
Re-working and concessions
Product disposal (confirmation)
Records for all actions
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THE STANDARD REQUIREMENTS
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4.8 Control of Non-Conforming Product
(continued summary)
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Final product inspections / tests
Records of all inspections
Authorised personnel only (procedures)
Use of despatch documentation
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THE STANDARD REQUIREMENTS
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5. PROCESS CONTROL
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5.1 Temperature / Time Control
Where applicable:
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Control of raw materials
Control of work-in-progress
Environmental controls
Use of alarms in case of temperature failure
Procedures for all areas
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THE STANDARD REQUIREMENTS
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5.2 Quantity Control
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EU (UK) legal requirements
Quantity (average / minimum)
Measurement / weight (calibration)
Importers shall control packaging in line with EU
regulations
Inspection and testing records
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THE STANDARD REQUIREMENTS
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5.3 Equipment & Process Validation
Validation of:
Process methods (HACCP)
Product formulation (Specification)
Use of equipment (calibration and maintenance)
Regular review (internal auditing)
Control of records
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THE STANDARD REQUIREMENTS
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5.4 Calibration and Control of Measuring and
Monitoring Devices
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Traceable calibration of all test and measurement
equipment, including;
Scales and weigh bridges
Temperature
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Control of equipment calibration / test records
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THE STANDARD REQUIREMENTS
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5.5 Specific Handling Requirements
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Prevent cross-contamination (all areas)
Example:
Meat / vegetarian products
Peanuts – anaphylactic shock
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Use of handling methods / procedures
Use of customer specified procedures, as required
under contract
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THE STANDARD REQUIREMENTS
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6. PERSONNEL
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6.1 Personal Hygiene controls
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Raw material handling
Processing
Packing
Storage areas
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THE STANDARD REQUIREMENTS
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6.1 Personal Hygiene controls
Finger nails
Jewellery
Exposed skin / cuts
Smoking / eating
Hand cleaning
Perfume / after-shave
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THE STANDARD REQUIREMENTS
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6.2 Medical Screening
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Induction training / contract
Reporting procedures for infections, etc.
Visitors / contractors, where appropriate shall be
medically screened prior to visiting production
process areas
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THE STANDARD REQUIREMENTS
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6.3 Protective Clothing
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Hair covered to prevent contamination
Appropriate footwear used
Appropriate clothing (spares)
Approved laundry services (contractors)
Available for visitors
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THE STANDARD REQUIREMENTS
6.4 Training
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Induction training supervision
Personnel training at all levels to include
contractors and temporary staff
Review of training procedures
Use of equipment
Health and safety
Personnel (personal) records
Training records
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Certification Bodies
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Only Accredited Certification bodies to EN45011* with
the appropriate scope, shall carry out evaluations
against the BRC Standard, and issue certificates, or;
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Until 31st May 2003, to include those Certification
Bodies actively seeking accreditation to EN45011
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* The BRC requirement was EN 45004
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Before the initial evaluation
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The Supplier is required to review the BRC Standard
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Make any necessary amendments or improvements to
its operation and systems
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Provide background information on the site concerned,
by completion of a pre-evaluation questionnaire or proforma information sheet.
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The scope of the evaluation shall be defined
between the Supplier and the Certification Body
The scope shall be identified in the evaluation
report and any certificate of inspection.
The Supplier may contract the Certification Body
to evaluate matters beyond the scope of the BRC
Standard, but no relevant elements of the BRC
Standard shall be omitted.
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Any additions to evaluation scope may or may
not fall within the scope of the Certification
Bodies accreditation
A supplier may be advised to check with either
the Certification Body or UKAS before contracting
such additional work
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Evaluation Procedures
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Duration of evaluations will be dependant upon a number of
factors but due regard must be given to;
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size of the site
the types of processes to produce and store product
number of product lines
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Evaluation Procedures (continued)
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the number of employees related to food
(food safety)
size of random sampling
the number of non conformance’s as recorded in
previous evaluation
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At all evaluations there are four elements, which
shall be carried out;
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opening meeting
review of quality systems and procedures
site inspection
closing meeting
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Major
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There is substantial failure to meet the requirements
of a statement of intent and any mandatory clause of
the Standard.
Depending upon the level of certification sought
(Foundation or Higher), the mandatory clauses will
differ.
The mandatory clauses for Foundation Level are all
those listed in the Foundation Level column.
The mandatory clauses for Higher Level are as for
Foundation Level, and in addition, all the clauses in
the Higher Level column.
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Minor
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This is where absolute compliance to the statement
of intent and a mandatory clause has not been
demonstrated, but on the basis of objective evidence
the conformity of the product’s safety and legality is
not in doubt
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Recommendation
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There is a failure to meet a recommendation of good
practice.
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The report contains the following
sections:
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evaluation details
evaluation summary- overview of performance
details of non-conformance and corrective action
plan
detailed evaluation report
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THE STANDARD REQUIREMENTS
QUESTIONS
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