Writing up BRC audit non-conformance

G

glade

I'm sorry this is so basic, but struggling to get my head round this.

In my internal audit for British Retail Consortium Global Standard for Packaging and Packaging Materials, I have found that statements in the quality manual regarding cleaning/maintenance are no longer carried out.

How do I write up the finding? Do I reference our quality manual requirement, or some clause in the BRC standard.

e.g.

Requirement: Quality Manual Section 5.7 - Maintainence shall be performed blah blah...
Finding: Maintainence is not carried out in accordance to section 5.7
Clause: QM 5.7

OR

Requirement: BRC (some clause relating to document control?)
Finding: Controlled documents are not being followed

Because

If i look at BRC section 4.9 we do actually do things which meet the requirements, just it is now different to the processes in own documented procedures.
 
B

Boingo-boingo

I'm sorry this is so basic, but struggling to get my head round this.

In my internal audit for British Retail Consortium Global Standard for Packaging and Packaging Materials, I have found that statements in the quality manual regarding cleaning/maintenance are no longer carried out.

How do I write up the finding? Do I reference our quality manual requirement, or some clause in the BRC standard.

e.g.

Requirement: Quality Manual Section 5.7 - Maintainence shall be performed blah blah...
Finding: Maintainence is not carried out in accordance to section 5.7
Clause: QM 5.7

OR

Requirement: BRC (some clause relating to document control?)
Finding: Controlled documents are not being followed

Because

If i look at BRC section 4.9 we do actually do things which meet the requirements, just it is now different to the processes in own documented procedures.
Based on what you describe, you need to report the finding as a nonconformity against the organization's own requirement contained in the quality manual. After all, you mentioned that the actual practice would be in compliance with the BRC standard requirements, but not in compliance against your own manual requirements.

Disclaimer: I am not well versed with the BRC standards. But I do know quality systems and auditing.
 
G

glade

Thank-you - its what i thought.

A non-conformance against one of the audit criteria - in this case the requirements of QM section 5.7

(Just writing it out helps!)
 

AndyN

Moved On
Be careful to report the facts, just the facts. Also, don't overlook what is effective. Anyone can report "They weren't following procedures", but that's not helpful! Was the procedure out of date compare to what had to be done? Did the people find a more effective/efficient way to do the work?

You have to help management identify what to fix - the document (easy) or the activity (no so easy)

Also, be very specific. It reads like no maintenance was being performed. Is that true? Or was it only one area/machine etc. There may be a good reason, but you can't "condemn" the whole process from just one observation
 
B

Boingo-boingo

Also, be very specific. It reads like no maintenance was being performed. Is that true? Or was it only one area/machine etc. There may be a good reason, but you can't "condemn" the whole process from just one observation
A careful read of the original message identifies that cleaning (in addition to maintenance) wasn't being done, in accordance with the organization's self imposed requirements.

A single instance of unsanitary condition could have severe consequences, in terms of food safety for a large number of consumers. While we must present the findings in a fair and factual manner, food safety is a risky business and we should not overlook the importance of identifying isolated situations which could lead to problems.
 

AndyN

Moved On
Yes, indeed they may not have been carried out - but an effective auditor presents more information. As you correctly suggest a single instance might be a problem, but again, we can't play the "what if scenario" on audit findings... The actual audit report text mentions maintenance NOT cleaning, BTW, so clearly there's room for more accurate reporting!

Too many auditors stick to conformance reporting, without doing the correct thing and evaluating the effects of what's going on - external auditors do it all the time, because they are under time limitations. Internal auditors don't have this limitation as much and need to evaluate the impacts and risks of what's going on here. I can't - and I doubt if you can either - identify the risks of this maintenance activity not (apparently) being performed. I'm suggesting the auditor dig deeper...
 
B

Boingo-boingo

The actual audit report text mentions maintenance NOT cleaning, BTW, so clearly there's room for more accurate reporting
What actual audit report? There was no report. There were two proposed finding statements. As for the actual scenario, the OP reported
In my internal audit for British Retail Consortium Global Standard for Packaging and Packaging Materials, I have found that statements in the quality manual regarding cleaning/maintenance are no longer carried out.
 

AndyN

Moved On
I consider an NC statement (as the example was posted) to be a "report" in general terms...

I read a requirement for "cleaning/maintenance", (from the QM) not what was observed, which is apparently maintenance not being performed...

This is, to my way of thinking, an important point of accurate reporting of the situation. Being accurate is half the "battle" when presenting audit reports to management, to enlist their support for action. It's certainly not clear to me, remote from the situation (which is *the* acid test of a good nc statement) exactly what is or isn't being implemented... If I were a member of management, there'd be doubt in my mind as to what needed fixing: maintenance, cleaning or both...
 
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B

Boingo-boingo

I read a requirement for "cleaning/maintenance", (from the QM) not what was observed, which is apparently maintenance not being performed
Interesting. When I read
In my internal audit for British Retail Consortium Global Standard for Packaging and Packaging Materials, I have found that statements in the quality manual regarding cleaning/maintenance are no longer carried out.
I read that there are requirements for cleaning (as well as maintenance) are not being performed any longer (no longer carried out). So, in my estimation we have a classic case of cleaning requirements not being complied with. And, as cleaning has a clear impact on food safety, the auditor must report it as a nonconformity citing the proper clauses of the quality manual.
 
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