6.2 Labelling & Pack Control – final part
(NEW) 6.2.4 Where on-line vision equipment is used to check product labels and printing, procedures shall be in place to ensure that the system is correctly set up and capable of alerting or rejecting product when packaging information is out of specification.
This clause of the standard only applies if you have equipment that automatically checks that the packaging or labelling is correct. If you only do these checks manually, then the previous clauses in the 6.2 section apply.
Where automated equipment carries out these checks, this clause requires this equipment to be challenged, to actually prove that it is working effectively.
For example if you use bar code recognition systems to check to make sure that you are using the correct piece of printed packaging, then you need to challenge the machine routinely. The frequency is up to you, I would suggest at least daily if not at the start and end of the day’s run (this way you’re proving that the whole days run is correct), but if you think that there is a reason why it doesn’t need to be this often make sure you document your reasoning as a risk assessment, so you can prove why you’ve assigned the frequency you have.
To prove that the bar code recognition machine is working you would need to develop a procedure where you challenge all of the machine functionality. You could put an incorrect bar code through and ensure that the machine recognises it. Think about the fail safe function of the machine – does it remove the pack or does it alarm and stop the line. If it rejects the pack you need to prove that it rejects the correct pack, so you may want to send a correct bar code down, followed by an incorrect, followed by a correct (like you would with metal detection) – to check that the timing is right and it rejects just the incorrect pack.
Remember in this situation you would need to do this test “in normal product flow” so you’d need to make sure that the line was running at normal production speed and you’d need to put the packs on the line with the normal production spacing. If the machine works by alarming and stopping the line, you’d need to make sure that as part of the test you are confirming that the alarm did go off and the line did stop. Think about the conveyors that are in place after the bar code scanner, if there is more than one, you may need to ensure that both conveyors stop, to ensure that the second conveyor doesn’t accidentally take the pack away down the line. In this case your procedure would need to confirm that all the required conveyors stop.
Use this theory to ensure that all automated systems that check labelling and coding have a procedure for each check that the machine does.
Remember to review the labelling and coding of all of your products and the checks that need doing (covered in newsletter 5) and where any of the requirements are not covered by the automated systems, then these checks must be done manually.
3.12 Customer Focus & Communication
Statement of intent: The company shall ensure that any customer-specific policies or requirements are understood, implemented and clearly communicated to relevant staff and, where appropriate, suppliers of raw materials, packaging and services.
This new section of the standard was actually in version 5 and for some reason was removed for version 6. It’s now been reintroduced to try and bring back the link between BRC and the customer standards, to try to strengthen the customers confidence in the standard – ultimately to reduce the need for customers to carry out their own audits of their suppliers, in addition to the BRC.
In reality, I personally think that this is only a tiny step towards integrating the customers standards or expectations into the standard and the way in which it will be applied will be very much down to the auditors knowledge of the customer standards.
A pure BRC auditor when going through the auditor conversion training by BRC from version 6 to version 7, is not being trained on the individual customer standards, and normally they wouldn’t even have access to them. Therefore only BRC auditors who are trained to carry out customer audits, to the customer standards will know the actual requirements of those standards. So, to me, this is going to be a section of the standard, where there is going to be a massive level of variation in the way it is audited.
For example, one of the sections of the standard that varies from the BRC to the customer standards, and also varies between customer standards is metal detection. If metal detection is being audited by an auditor with BRC training, but no knowledge of the specifics of the customers standards, you may pass the section with no non compliances. However, if the same audit was carried by an auditor with customer standards knowledge and not all of the customer standards are being adhered to you could end up with at least a minor, if not a major (if metal detection was defined at that site as a CCP). The non compliance would not be put against the metal detection section, but would be applied to this section of the standard because you are not adhering to the customers standards. Massive scope for variation in audit results, based on who does the audit. Plus a little unfair on the auditor I feel. If I was carrying out the audit, the way I would get round this is to ask the site who their customers are and pick a customer standard (the most detailed one) and ask the site to provide me with a copy of a particular section of their standard – such as metal detection for example. I’d then use this as my base for the audit. However there is one main problem with this – the customer standards are sometimes long and take some time to read, absorb and interpret. Doing this during an audit when the auditor is already really stretched for time is going to be really hard.
3.12.1 Where a company is requested to follow specific customer requirements, codes of practice, methods of working etc., these shall be made known to relevant staff within the site and implemented.
So, given what we’ve talked about above, there are two main points to this clause:
1. You need to prove that you are complying with all of your customer standards
2. That ‘relevant’ personnel are aware of the individual customers requirements
1. Compliance with the customer standards
This includes a number of aspects:
a) knowing what the customer standards are and what aspects of them are above and beyond what’s required in the BRC standard
b) showing the auditor that you can get access to them, so you can use the most up to date version (by logging onto the individual customer’s online system for example)
c) explaining how these are integrated into your own systems
d) where customers have alert systems you would need to show that you know about this, show that you can access the alerts and that you close them off in a timely manner. Please note though, this point would very much rely on the auditors knowledge of the individual customer systems – which I think is very unlikely unless they are actually trained to do that customers audits and it’s written into the customers audit requirements.
2. That relevant personnel are aware of the requirements
The word relevant in this clause is important. Relevant means the people who need to know. So, that would be the person(s) or team who incorporate the customer standards into the sites standards. It doesn’t mean everyone needs to know. As long as the requirements are included in the sites procedures and these are trained out effectively, it doesn’t really matter where the individual aspects of the procedures came from. The important part is that you are complying to all of your customers standards. You need to be able to explain who the relevant people are and show that they know how to get to the standards and apply them to the sites systems.
3.12.2 Effective processes shall be in place for communicating customer-specific requirements to the suppliers of raw materials and services as applicable.
This clause requires you to ensure that where the customer has a specific requirement, that requires not just your compliance but your suppliers as well that you ensure that this happens. The standard says that you need to communicate the customers requirements to your relevant suppliers and be able to show evidence of this, so you need to make sure it’s documented – for ingredients this would usually be specified in the ingredient specification.
Don’t forget that this includes services, so pest control etc would need to be included. So for example M&S have specifics in their standard about pest control, your pest controller would need to know that you produce product for M&S so that they apply the required level of service. But don’t forget this would need to be written into the contract/service agreement.
I can see this clause becoming more vital in the future as we get further into food defence. Where suppliers have to apply agreed chain of custody rules – so for example if it’s agreed that ingredients won’t be transhipped or have multi-drops on route but will be direct delivery only. This doesn’t normally appear in the specification but would normally be part of the umbrella agreements defined in the contract or service agreement.
Again, this is a complex area when you get into it, as the auditor would need to know the policies of the individual customers, for example that they only allow free range egg in their products, or that they have a list of banned additives.
Really I think the key to passing this section of the standard is to be able to show the auditor that you can get onto the customers systems and you can confidently work your way around the system and talk about the customers requirements. If you have one customer that’s key to you, as they take the largest proposing your product – make sure you know their systems inside out.
So, make sure you have all your customer log ins organised, check they work, sign off all the alerts that are outstanding and make sure you know how to get to their standards on the system.
That’s it for this week, as always if you have any queries about this section of the standard or any other, please ask them in the comments section below.
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