BRC 1.1.12 - Recurring Nonconformity
we just had a BRC audit with NC:
1.1.12 The root cause of non-conformity identified at previous audit have been recurrence as clause 4.7.1
Can you help me with the corrective action?
Hi, What was the original NC?
Hi, What was the original NC?
Yes, details would be helpful...
Try to give the exact wording on the NC so that we can troubleshoot. Sometimes it can be a bit tricky.
Cheers!
Root cause: due care by technical staff on this equipment ,maintenance electric box equipment
Sorry
NC: 4.7.1 Electric box at production not in good maintenance, it was not closed after used.
Correction: maintenace the electric box at production in good condition, it closed.
Proposed preventive action plan: Checking all equipment operation on production area, maintenace the electric box at production to fitting. Tranning technical staff on equipment management.
Root cause: Due care by technical staff on this equipment maintenance electric box equipment.
Presumably the unit was found in a similar condition this audit as well?
Hence moving the NC to 1.1.12: The site's senior management shall ensure that the root causes of any non-conformities against the Standard identified at the previous audit have been effectively addressed to prevent recurrence.
If this is a near-exact repeat of the previous NC then it would be very difficult to argue that the original preventative action worked. You may need to provide more detail on this - for example, was the the electric box added to your routine inspection schedule, preventative maintenance schedule, and/or cleaning schedule (as applicable)?
If not, then it looks like it very much should be.
If it was, then presumably these haven't been followed correctly, in which case there is an argument that further training and supervision is needed for the maintenance operators and perhaps also for their supervisors/manager (whoever has oversight of this team and should be checking/reporting these actions as closed / chasing them up).
Given that your NC this time has fallen into the Senior Management Commitment section, I very much suspect that elements of your corrective and preventative actions will need to sit in this area. Is performance on maintenance / routine fabrication, hygiene and internal audits / audit non-conformances included in your senior management review process?
If yes, then you may want to consider revising how this is done, as it missed this.
If no, then definitely look to include it.
Given that this got missed internally ahead of the audit despite being a previous NC, I'd also look at how much time senior managers spend (or don't spend) on the factory floor - for example you could schedule the site's most senior quality/food safety manager to perform one in two/three/four (probably a higher frequency to start with) of your routine hygiene/fabrication audits so they're demonstrably closer to what is happening in production. Potentially they should be accompanied by whoever is in charge of facilities/operations - obviously the facilities/ops person can't audit themselves, but it would afford an opportunity for them to see where their team need to make improvements, as this information doesn't seem to be being communicated upwards correctly at present.
Internally you possibly also want to look at how information is - or possibly isn't - being fed upwards from the staff on the floor to senior management. This might not directly form part of your corrective/preventative actions (given that the NC is against a Senior Management clause), but the finding does potentially imply that there could be improvement here.
Hi khanhhuyen,
As per pHruit’s post, this is a reflection of lack of Senior Management Commitment.
BRCGS Global Standard Food Safety Issue 9 Clause 1.1.12 Guidance states:
If effective corrective or preventive action has not been introduced (e.g. it has been ineffective at preventing recurrence), a non-conformity may be raised against this clause, in addition to a non-conformity against the clause that has the recurring issue.
The auditor could have considered non-compliance with management commitment to continual improvement and developing and improving a food safety culture as it a clear failure to meet a fundamental requirement:
1.1 Senior management commitment and continual improvement
Fundamental
The site’s senior management shall demonstrate that they are fully committed to the implementation of the requirements of the Global Standard Food Safety and to processes which facilitate continual improvement of food safety, quality management, and the site’s food safety and quality culture.
There should have been corrective action, root cause analysis and preventive action, all of which have failed or not been followed through.
Your corrective & preventive actions this time need to reflect improvements to senior management commitment as well as the maintenance issue.
Also, my advice to you and anyone else is to go and check all the previous certification audit non-conformances have not recurred immediately prior to your next certification audit yourself.
Kind regards,
Tony
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Also, my advice to you and anyone else is to go and check all the previous certification audit non-conformances have not recurred immediately prior to your next certification audit yourself.
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^ I would second this. Review the last few audits for that CB and any other audits in the last year (some like too see what other auditors have caught) and make sure you're not repeating any of the non-conformances or noted deviations.
It is worth reminding the department or operational leaders what issues were observed in their areas too.