Note from the author:
BRC released a position statement in May 2015, to expand the time that sites are allowed to implement the agents and brokers requirement of clause 220.127.116.11. What this means is you don’t need to fully comply with this clause until June 2016. What you need to have done before you have your V7 audit though is request from any agents or brokers you use, for them to provide you with the information you need to complete your supplier monitoring. Make sure you do this formally, such as by email, so you can show the auditor. BRC have done this to allow agents and brokers to catch up with the changes themselves, and so, as manufacturers you are not penalised for this.
6.2 Labelling & Pack Control Part 2
6.2.2 Documented checks of the production line shall be carried out before commencing production and following changes of product. These shall ensure that lines have been suitably cleared and are ready for production. Documented checks shall be carried out at product changes to ensure all products and packaging from the previous production have been removed from the line before changing to the next production.
This clause hasn’t changed so I won’t go into too much detail. Essentially it requires that you must check and document that the line is clear of previous product and packaging before the next run commences.
Although you would think that the checks only cover packaging (given that it is within the ‘Labelling & Pack Control’ section!) the interpretation guide says that these checks must also include checks that the line is clean and that its set up in line with CCP and quality parameters. It goes as far as to say that if equipment hasn’t been used for some time it must be disinfected. Make sure your checks and procedures cover all this.
The clause says previous product and packaging. So you need to ensure that your documented check includes product too. This is to ensure that once the line was set up with the new packaging, that product from the last run is not accidentally put back on the line, which again would mean wrong product in pack.
6.2.3 Documented procedures shall be in place to ensure that products are packed into the correct packaging and correctly labelled. These shall include checks:
at the start of packing
during the packing run
when changing batches of packaging materials
at the end of each production run.
The checks shall also include verification of any printing carried out at the packing stage including, as appropriate:
country of origin.
This clause now has additional information to clarify exactly what is required. It’s basically split into requirements for 1. frequency and 2. Types of checks.
The standard defines frequency of the checks in that they should be at the start and end of the run, but it’s up to you to define the frequency during the run (in between). This should be based on your throughput, the higher the throughput the more frequent the checks should be, because the greater the quantity of product at risk. However, if you have very short runs you may find that there isn’t time to carry out a check in between, but you still must carry out start and end of run checks. This way you’re confirming that the whole run was correct. You must also define the frequency of the check that would occur in between, even if you know you won’t use it. This is so that if you ever were to do a very long run, you would have a procedure in place (defined frequency) to capture this.
Remember to include in your procedure that “changing batches of packaging materials” doesn’t just mean when you change the packaging to move from one product to another checks must take place, but it also means that checks must occur if you start a new reel of film, box of ‘u cards’ etc. – this way you are confirming any new packaging added to the line was correct.
It has been been known for a box of different printed packaging to get mixed up either on your site or at your suppliers, so it’s essential to make sure each new box/reel etc is checked.
When carrying out audits of your packaging suppliers make sure that they do these checks too (as in, that they check that all previous packaging is removed from the line before they start a new run). It has been known for example, that in a box of printed pots that one or two pots are different in the box, as the line wasn’t clear ad they got mixed in accidentally. This mistake by your packaging supplier, means when your packing your product, even if you’ve done everything right, that one or two products will have the wrong packaging. It’s impossible for you to do anything about this once you’ve put mixed packaging on your line (unless you have an automated way of checking every single piece of packaging), you’ll only realise there was a mistake when you get a complaint.
2. Types of checks
Although there are checks defined in the clause, you need to make sure that they cover all of your products. The checks need to cover 2 main points:
- That the pre-printed packaging that you are using is correct
- That any printing that occurs on the line is correct – so this means you need to have a check for all the types of information printed.
If your printing covers more than the examples listed in the clause and it effects food safety or legality, you must include it in your checks. Go through all your on site printing and make sure each type is covered.
Checking the site printed information
The biggest problem with these sort of checks and why they go wrong so often is that it is human nature to see what you want to see, and it’s really hard to keep concentration when doing the same checks over and over. Make it harder for your operators to get it wrong – ways in which you could do this are:
- Provide the operator with a controlled document that gives them the correct information for the run they are doing, so they can compare. Try to lay out the information in the same way as it’s printed – so they can compare the two (a bit like spot the difference).
- Get them to write the right answer (from the controlled document) and then in the next column or row get them to write down what they have printed on the packaging- then get them to compare the two and confirm they are correct. This way if they are different, and shown side by side, it’s harder for them to not notice it.
- Create a team culture in which another team member checks the first operators checks as a secondary verification. You must ensure that the second operator also has the controlled document to check against and doesn’t just verify what the first operator has written – but they must check the print themselves. You could take this one step further and create a team bonus scheme, so that perhaps weekly or monthly if the team works together and no mistakes are made they get an incentive. The most obvious form of incentive could be a monetary bonus scheme, or it could be vouchers or bonus points towards a team day/night out. Or even bonus points so that at the end of a set period (such as a year) they win something, which could be as simple as getting the best parking spaces in the car park.
- Psychology research shows that one of the main causes for human error in manufacturing industry is repetition, so trying to reduce this is key to helping operators get it right. Try to work out a plan of swapping roles regularly, perhaps even a change in environment to carry out checks which is quiet away from the line may help – this obviously depends on your process and whether you have the luxury of space, but try to think of things to make the environment a bit more interesting/stimulating to work in.
- I would strongly recommend you get your operators involved in the review process, I’m sure they will have some amazing ideas about how to make it work better, as after all they do it every day! Plus involving them will mean they take ownership of the system, as it will be partly be theirs and so, they’ll believe in it.
Checking the pre-printed information
In order for the operator to be able to check that the packaging is correct, you can ask them to check the brand, the title and the barcode (if the particular piece of packaging has a barcode). To help with this you could provide a laminated piece of packaging for them to visually compare to. Even better if the packaging is flat and you can get the packaging printed on a laminate sheet – and ask the operator to actually put the laminate over the packaging to check it’s the same. When checking bar codes get the operator to actually write the bar code number down – but think about how much of the bar code you really need them to confirm, bar codes are long and numbers are not easy to check. Your bar codes will be made up on GSI codes, product made in the UK for example will always contain the company prefix numbers 501-509. So it would be advisable to take this into consideration when working out what you want the operator to check.
Asking someone to check something and write it down, when that ‘something’ never changes trains their brain to go on autopilot, rather than thinking about what they are doing (which you obviously don’t want). It’s only my opinion, but I’ve used this theory in all the work I’ve done and I can promise you it works – number one rule is make sure you only ask operators to check and record things that may change. If it can’t change, it shouldn’t be included.
Ok, so that’s it for this fortnight. It’s your turn now – check your frequency of your checks to make sure they comply and that they are aligned with your throughput. Check that all the pre-printed packaging you are using is included. Make sure that you’re not asking your operators to check repetitive information that won’t change and that you’re doing all you can to make it easy for them to get it right. Don’t forget to include those that do the job (they’re so valuable!) and then put all of this in your procedure and train it out to your team.
I’d love to know what you found useful here, so I can do more of what you like to make this newsletter better for you. Do you find most useful:
1. Explanation of the actual BRC clauses
2. My recommendations on how to put it into practice
3. Tips on what not to do
4. All of the above!
I need to finish the last clause of 6.2 in the next newsletter but I’ve got room to start another subject too. So out of the major changes to V7, which would you prefer:
- Reducing the exposure to food fraud (Section 5.4)
- Supply chain Traceability (Section 3.9)
- Supplier & Raw Material Approval & Performance Monitoring, including agents and brokers (Section 3.5)
- Customer Focus (Section 3.12)
- Management of Surplus Food Products (Section 4.13)
- A review of the changes to product zones (high care/high risk and the new ambient high care) (Section 4.3)
As always (I will keep asking you this, as I truly believe one day someone will ask the first question and then we’ll be away – I want this to be a learning and sharing forum, so please don’t keep queries to yourself!), please let me know if you have any questions or problems you’d like me to answer, using the comments below, or if you’d rather do it privately use Kassy.firstname.lastname@example.org. Also, if you have any suggestions about how you manage this section on your site and what works well for you, please share it with everyone else using the comments section below.
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