Feedback for the BRC Storage & Distribution Issue 4 consultation closed last week.

The publication of the standard is due in November this year.

We thought you might like to see our feedback to BRCGS for the consultation of the draft. Many of the points are due to inconsistencies throughout the Standards.

It’ll be interesting to see if they take any of our feedback on board, we have our fingers crossed.

We’d love to know what your thoughts are about the draft, please add them to the comments box at the bottom. You don’t need to use your real name and your email address will not be shown, so you don’t need to worry about commenting.

Requirement Comment
1.1.4 “results reported at least quarterly”.

Reported or reported and reviewed? If reviewed as well, this requirement would be best placed in the 1.2 review section.

1.1.5

1.1.6

1.2.4

3.3.3

3.5.2.2

SOI 4.2

4.3.4

6.1.4

These clauses refer to “product safety, quality, integrity, and legality.”, or sometimes just “quality, safety and integrity”.

The phrase product safety, legality appears 26 times in the draft, without the term integrity.

The phrase “product safety, quality and legality” appears twice without integrity. And so, on…

Please can we apply the terms consistently?

 

In addition to ‘integrity’ as detailed above, the word ‘integrity’ is also used to describe when the product should be intact (see packaging definition below). This is confusing.
In BRC Food – the glossary states food integrity as:

“Products that are of the nature, substance and quality expected (e.g. not substituted, diluted, adulterated or misrepresented).”

However, BRC Food glossary also defines authenticity as:

“Food authenticity is ensuring that food or raw materials purchased and offered for sale, are of the nature, substance and quality expected.”

BRC Packaging glossary defines integrity (packaging) as:

“Once a packaging container has been filled and sealed, its integrity is based upon its ability to contain, protect and preserve the contained product during its intended use.”

BRC S&D Issue 3 although it did use the word integrity (in both senses of the meaning) doesn’t define what it means by integrity in the glossary.

1.2.3 “The meeting shall be documented and used to revise the objectives”.

Surely this should be review? It wouldn’t be acceptable to change the objectives?

Section 1.2 Please can the standard clarify the difference between:

– Annual management review (final review, sign off, agree the year ahead)

– Quarterly reporting – although I’m presuming it should be review (to ensure that the site is on target to meet their objectives)

– And monthly meetings

These requirements are currently spread across two sections and many clauses – it would be provide clarity if they were together and explained as a cohesive structure to achieve the one goal (the objectives).

3.1.1.1 “navigable” can we keep it simple please? ‘in a way in which they are easy to find’ for example?
3.1.2 In Food and Packaging both the document section and the records section were updated to include digital formats. Here records have been updated but not documents.

Both document control and record completion are the same no matter what the standard – can’t we have them the same for consistency purposes?

3.2.1 Again consistency throughout the standards. Food states over 4 days. A&B states over 4 days (hidden in the interpretation) and now S&D says 2 days. Why?
3.2.4 States that root cause analysis should be used to determine corrective actions.

This is incorrect. RCA is not needed to correct the immediate problem.

Also, saying ‘where appropriate’ is really not helpful.

Can the standard please clarify when it would be appropriate?

3.3.3 Again this says RCA should be used to determine corrective actions.

The explanation (I appreciate it’s the same in Food, but my view of this still stands) that RCA should be applied when; “a non-conformity which places the safety, legality, integrity or quality of a

product at risk (including withdrawals)” is not helpful.

I would challenge anyone to come up with a non-conformance which doesn’t put the safety, legality, integrity or quality of the product at risk.

We use the theory of majors and criticals require RCA, whereas minors don’t (unless there’s a trend of minors). Would this not be more simple to understand?

3.5.1.1 Approval of consultants has come in again. It was in the draft of food, removed for the issue of food, added to packaging and now it’s in S&D. Please could we have consistency?

And if we apply consistency, should we not have labs in this list?

3.5.3 This section doesn’t make any sense to me at all.

Going by the food definition:

“Food authenticity is ensuring that food or raw materials purchased and offered for sale, are of the nature, substance and quality expected.”

Unless the site is doing the wholesale module, they are not purchasing or offering for sale.

And how are they expected to assess their customers? The only way they would know if their customers are sending them something that isn’t what it says on the tin – is by them going to audit their customer.

Surely, the combination of a confidential reporting system and a threat assessment for product defence is sufficient?

Personally, I think this section should be removed.

3.8.4 Again consistency, cyber crime was added to food and to packaging, but doesn’t appear here.
3.8.6 Again consistency, in food a regulatory non-conformity was added, but doesn’t appear here.
3.9.4 This has already been said in 3.3.
3.10.2 Again, this has already been said 3.3.3
4.2.1 In the other standards this is referred to as a threat assessment, not a risk assessment.
4.2.4 “Contractors and visitors, including drivers, shall be made aware of all procedures

for access to premises and the requirements of the areas they are visiting, with

special reference to hazards and potential product contamination.”

Should this not be hazards instead of threats and malicious contamination instead of product? Like this:

Contractors and visitors, including drivers, shall be made aware of all procedures

for access to premises and the requirements of the areas they are visiting, with

special reference to threats and potential malicious contamination.

4.4.8 This clause needs moving to section 7.4.
4.4.8 Also, this clause says it doesn’t apply to glass packaging. This is one of my bug bears – where in the standard is glass packaging breakage control covered? Even in the packaging standard – where they make glass it’s not covered. I’ve been to glass bottle manufacturing sites, where they have a glass breakage procedure for the lights, but it’s perfectly fine to break the glass in the process and not clean it up and control it so it doesn’t get into the bottle and sent to the site. Surely, this is a huge gap.
5.1.4 The additional checks seem sensible – my query would be why they’ve not been added to the other standards? Will they be added in the future?

And with that in mind, in issue 3 5.2.5 and 5.2.6 stated that vehicles must be secure – either with seals or other methods. Why has this requirement not been translated into the other standards? It would seem sensible to do so.

5.2.1

5.2.2

5.2.3

All repeated as they are covered in section 4.2.
5.4.3 Can we please add into this clause that controls for the temperature equipment on trailers must be secure. So that when the driver in the next cab is trying to sleep and the noise is bothering him – he can’t switch it off.
6.1.4 I understand that where automated equipment is in place to do checks it needs to be managed.

But surely this needs to be done, even if it’s done manually and where in the standard does that sit? There’s no assessment of what quality checks are needed and what controls should be put in place.

6.3 Please can this section be reviewed to clarify clearly that there are two distinct parts to this.

1. Calibration

2. Accuracy checks

6.3.3 Too many ‘and’s’:

“critical control points and product safety and legality”

6.3.2

6.3.7

Can these clauses be combined – they’re repetitive.
6.4 This section doesn’t talk about the settings being secure.

Also, for consistency is there any reason why the same clauses from the food standard cannot be used?

6.5.5 Proprietary – can this not be described more simply?
6.6.3 Why would a site need to inspect stock if the stock sits in an area which is effectively monitored already?

Does the clause mean stock that’s out of date and therefore the contamination could come from within the pallet? If that’s the case – that’s not clear.

6.6.11 Clause reference says 6.6.111

 

I think the survey should be scheduled, not timed. That implies something different.

7.3.2 This statement needs to state that validation is required to prove that the system is capable.
7.3.2

7.3.7

Can these clauses be combined – they’re talking about the same thing.
7.7 Can these clauses not be put into 7.4? Seems odd that they’re stuck at the end of the section on their own.
8.1 For consistency, should allergen awareness, pest awareness, labelling and product defence not be stated here.
9.1.1 Why are site maps in the hazard analysis section here, but maps are not in the hazard analysis section in the main body of the standard. I agree it’s best to put them there, are it highlights the purpose of them is so that hazards can be considered.

It would be good to decide one way or another for consistency.

9.1.2 Why is micro pulled out here on it’s own? Surely foreign bodies such as wood and glass would be in scope for open product?

And allergens also.

9.6 This clause is very vague. It seems odd to separate open product requirements to give clarity and then be so vague.

Are the standard really saying that PPE may really not be needed where the product is open? And if so, then why force the requirement that a hair net is a must (9.6.5)?

Module 10 Rather than go through everything in this section, my top line feedback is as follows:

 

It’s far too complicated when it really doesn’t need to be.

The terms; branded, wholesalers own and customer exclusive branded products are over complicated.

Surely they are just:

Traded

Own brand

Customer brand

 

The requirements in 10.1 are the same as in the standard – so why repeat them.

Same for 10.2

With the exception of 10B1.1 the same goes for all of 10A and 10B. Surely, just adding the term ‘wholesale’ into the main body of the standard would eliminate all of these additional clauses.

10B.2 same.

 

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