Does BRCGS Clause 3.11.4 Apply to Incidents Involving Products Excluded from Audit Scope?

Is this clause triggered if it is related to product specifically excluded from the BRCGS audit scope?

3.11.4 - In the event of a significant food safety, authenticity or legality incident, including a product recall, regulatory food safety non-conformity (e.g. a regulatory enforcement notice) or food safety-related withdrawal, the certification body issuing the current certificate for the site against this Standard shall be notified within 3 working days. The company shall then provide sufficient information to enable the certification body to assess any effects of the incident on the ongoing validity of the current certificate within 21 calendar days. As a minimum, this shall include corrective action, root cause analysis and a preventive action plan.

Yes, as the facility is certified not the product

Yes, as the facility is certified not the product

That's what I say too...

Yes, in agreement with others.

Here's a fun twist on this. You all remember when a large mid-west egg producer some years back got into a big problem with excessive chicken waste and ended up with a massive recall.

Now. they had something like 15 locations with some bring SQF certified - not this one however.

Well. news media catches wind that the company is SQF certified and contacts SQFI directly. of course SQF has no idea about the situation because as I mentioned this location was not SQF certified - thus NO notification... but it did create a very big debacle.

In that case it was suggested that even if a location is not SQF but others in the same company are that a notification be made anyway, explaining the situation and make not that this particular facility is not SQF certified.

Hi Marshenko,

I think you already know the answer, BRCGS Global Standard Food Safety Issue 9 section 3.11.4 Guidance refers to ‘all’ and ‘any’ several times, making it quite clear:

Guidance on Notification of recalls to the certification body

Where there is a significant incident related to product safety, authenticity or legality the site manufacturing or processing the implicated product is required to notify their certification body of the situation. The types of situation that should be notified include:

• all product recalls

• any situation where the regulatory authority insists on action (e.g. an enforcement notice) due to product safety or legality concerns

• legal proceedings with respect to product safety or legality

• adverse media attention relating to product safety

• any food safety incident with the potential to harm a consumer

• any food safety-related product withdrawal (it is worth noting that only product safety- related withdrawals need to be notified to the certification body; other types of product withdrawal, such as those related to product quality, do not need to be notified).

The aim of this notification is to ensure that the integrity of the certificate is maintained by allowing the certification body to assess whether the incident affects the certification status of the site.

Kind regards,

Tony

CB notified.

Yes, as the facility is certified not the product

Second question, and tagged Scampi specifically even though they are located in Canada.

United States.

Frozen raw seafood product sold to customer in Q1 2024.

Customer pulls a single sample to test after having been in customer's possession for 3 months, sample tests positive for salmonella spp.

Is product considered adulterated?

Customer is removing product from their "stores"

Would we be responsible for doing the same based off of their single, non-composite sample?

Most people would investigate and test a number of samples before withdrawing a product.

Most people would investigate and test a number of samples before withdrawing a product.

Which makes sense  :spoton:

I've sent four samples already, +CoA from supplier.