In this article we’re going to cover the changes in the incident, recall and withdrawal section of BRC Packaging Issue 6.
The incidents, recall and withdrawal section is split into two distinct groups:
- Emergency situations
- Product withdrawal and recall
The main part of the incident, recall and withdrawal that’s changed is the emergency situation section.
Although an assessment of risk to the safety of the product must take place during or following an emergency situation, product incidents mainly sit within the product withdrawal and recall group. Emergency situations focuses primarily on safety of the site and the business.
In order to deal with emergency situations, your BRC auditor will be looking for contingency plans to deal with different types of emergency.
The main aim of having a contingency is to ensure that we meet customer expectations. For customers who rely on your product, being in a situation where you cannot supply to them is obviously not something they would wish to have to be faced with.
The aim of emergency planning is to ensure that where an incident does occur, you have agreed plans in place which detail what you would do. This ensures that the impact on the customer is minimised.
What is an emergency situation?
An emergency situations is:
“An incident which puts the safety of the personnel, the site or the business at risk and may impact the sites ability to produce product which meets customer specification.”
We can build on the examples provided by BRC standard of emergency situations:
- Disruption to site services, e.g. water, electric, gas
- Disruption to contracted services such as transport or storage
- Disruption to site services such as refrigeration
- Staff availability
- Events such as fire, flood or other natural disasters
- Malicious contamination
- Cyber security attacks
The impact on the site from any one of the issues listed above could be massive. Having a clearly laid out plan for each of them that pose a significant risk to your site is essential, to make sure that your site can deal with them effectively and minimise the impact on both your business and your customer.
Health and safety of personnel is a key part of dealing with emergency situations, and therefore it is important to make sure that procedures to meet H&S requirements are combined – so that the site just has one emergency plan, agreed by senior management.
What should an emergency plan look like?
The first thing to do when setting up, or assessing a current plan is to establish which emergency situations will be covered in the plan. To do this, an incident team will be needed, in order to ensure that all the emergency situations defined, meet all of the sites requirements (including health and safety, and environment).
The incident team must include a member from each site function. For smaller sites it is acceptable for one person to wear many hats, as long as all the functions are represented.
The team must cover:
- Contracted services
- Site services
- Health & safety
Once the team has been established, they must agree which emergency situations pose a significant threat to the site.
Once this list has been agreed, a plan must be established for each.
Each emergency situation should take into consideration:
What would this emergency situation look like?
Defining this and documenting it, will help the team to visualise what that would feel like. This will help them to put together a plan which will be effective in a real-life situation.
What would the consequences of this situation be?
What impact would this have on personnel, the site, production, dispatch, transportation and the customer? Making a list of these consequences, will help to establish what contingency plans are required.
What is the contingency plan?
For each consequence, what would you do? What could you do to minimise the impact? Let’s look at a couple of examples.
If there was an issue with the water supply, how long could the site continue with the water available? (this may differ depending on what the water issue is, if it’s a micro problem with the water, or if it’s just lack of supply, which is why it’s important to make sure you define the issue well) Is it possible to contract the services of a temporary water supply? If so, can you set up such an agreement with a supplier, so it’s ready to go in the case of such an emergency?
If you are a site that produces frozen product and the on-site freezing facility went down, what would you do? Do you have a back-up freezer? If you do, how long would it take to get it up and running? Does the back-up allow you to produce at the same capacity? Do you need to contract the services of an external freezing company?
For all contingency plans, a clear communication plan is required. A ‘communication plan’ may sound fancy or complicated, but it just means:
- Who is going to do what?
- Who is responsible for instigating the incident team in an emergency situation?
- Who is responsible for organising key elements of the contingency plan?
So, for our examples above – who is responsible for speaking to the temporary water supplier, or the external freezer company? And if that person is off that day, who will do it in their absence?
The communication plan would also need to include the contact details for those who are responsible for speaking to the suppliers, and also, the contact details of the suppliers themselves. You may also need to include key pieces of information from the agreement, such as customer reference numbers or account numbers.
To recall or not to recall?
Where an emergency situation occurs, an assessment needs to take place to establish if the product has been effected. And, if needed a recall should also be implemented. This is a new requirement in the BRC Standard, so it needs writing into your procedure.
Also make sure that everyone that is listed in the contingency plans is aware of their responsibilities. Once you have the procedure and responsibilities documented, you need to train out the contingency plans as well as the recall and withdrawal process.
Once the contingency plans are in place, it is important to make sure that they work. Testing of emergency situations is not a specified requirement of BRC, as it only states that the recall procedure should be tested. However, it’s a good idea to incorporate an emergency situation into a product withdrawal or recall test, to get the most out of it.
We've tagged this article as: Management of incidents withdrawal and recall
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