In this edition of Smart Knowledge, we’re going to cover the changes to BRC issue 8, around goods in checks
What’s the change?
There’s a new clause that has been added to section 3.5 for management of raw materials and suppliers. This new clause is 188.8.131.52 and it asks for:
- There to be a change control procedure in place, which ensures that changes to ingredients and packaging, are controlled and the information relayed to goods in personnel.
- The purpose of the new clause is to ensure that only the correct version of the ingredient or packaging is accepted at goods in.
Why has this been added?
Now, this clause was probably added to the standard, due to the number of recalls relating to printed packaging. Where packaging has been updated and this information hasn’t been relayed to goods in or production and therefore, the wrong packaging has been used.
TIP: You need to make sure that you cover ingredients as well as packaging, as the clause isn’t limited to just packaging!
It’s good to see that BRC are bringing elements of change control into the standard. Although for me, I would like to see it prioritised much more. Change control needs to manage all changes on site, to make sure they’re controlled effectively.
So, what do we do?
Firstly, check that your procedure details how ingredient and packaging changes are managed, to make sure that it includes the need to communicate the changes to the goods in personnel.
If you don’t have a change control procedure (which is possible, as the standard hasn’t really talked about how to manage changes before) you need to create one. Think about how you are going to manage changes in ingredients and packaging. I can provide you with a few suggestions, on how to do this…
- Change through changing the code
First you can change the raw material code for the ingredient or packaging, when it changes. That way, you can make sure you only order and supply the right code.
If you keep the same raw material code, you need to be able to identify that the ingredient or packaging has changed. You can do this through a version number, either directly following the raw material code, or for printed packaging – print the version number actually on the artwork. That way, the goods in personnel can check the ingredient or packaging and know which version it is.
If you can’t change the code, you need another way of identifying which version of the ingredient or packaging it is.
For printed packaging, you can get the goods in personnel to actually check the packaging against the correct version of the artwork, so they know it’s right.
Or, if the change to the ingredient has changed the specification, you can use the certificate of conformance or certificate of analysis as a way of identifying the ingredient. But this can only be used, if the certificate clearly shows this – it would need to reference the new specification (by date and/or version) or it would need to be clear from the analysis and specification for the analysis, on the certificate of analysis.
3. Don’t stop at just goods in…
Whichever option you choose, it’s a good idea to make sure that not only the goods in personnel manage this, but also production. Preferably there needs to be some sort of check on the records when ingredients and packaging are issued to production, by goods in, to confirm they are issuing the right material, but also by production, to state that they have received the right material.
What is the the number one recall?
Recalls due to allergens continue to be the cause of the number one recall, due to printed packaging problems and although we’ve touched on this subject a little, we’ve not written an article or a set of articles specifically on it.
So, I thought it was about time that we tackled it. If you’ve been involved in a recall of this sort, I’d really like to hear from you. It would be great to really bring these articles to life and feature some real life situations. Of course, I don’t want to share your name, or your companies name – that’s not important. What is important, is the details of what went wrong and how it was fixed.
It’s such as shame that businesses only take the time and put in the money needed to stop these recalls, when they’ve been affected by them already. Just the fine of a recall alone is about £50,000. Between us, it would be great, if we raise the awareness of how easy it is to get this wrong. That even large companies, who think they’ve got it all sorted, can be at risk.
So, please if you can share your story with me, I would really appreciate it. I hope you can trust me by now, to know that I won’t share anything that you don’t want me to.
Please drop me a note at my email address: firstname.lastname@example.org
If you have any other ideas about how you can manage change control of ingredients and packaging, we would love you to share them! Just pop your thoughts in the reply box below – you don’t need to share your name, so don’t be worried about that. Let’s help each other and share our experience and knowledge.