Global Standard for Packaging and Packaging Materials Issue 4 : February 2011

Transcription

1 Materials Issue 4 : February 2011 Company Name: Kingsway Printers Ltd Site name: Humberston Audit Category: Low Hygiene Risk BRC Site Code: Audit Result: CERTIFICATED Audit Grade: Audit Frequency : A 12 months A or B = 12 months C = 6 months Audit Start Date: Audit Finish Date: Re-audit Due Date: Previous Audit Date: Auditor Number (one only : team leader) Auditor Names Brian Peckett Scope Details Packaging Field: 02 - Paper 04 - Plastics Select a packaging field Select a packaging field Scope of Audit: Exclusions from Scope: The printing and conversion of self adhesive labels and commercial print 5.5 & 5.6. In line calibration and the calibration of measuring tools. Products in production at the time of the audit: Labels for Baby Beetroot, Mexican Style Paste, various salad products, also sundry blank stationery labels Company Profile Kingsway Printers is a family-owned company based in North East Lincolnshire. They print self-adhesive labels for the consumer products and food industries as well as commercial printing of business stationery. Originally established in 1972 the company moved to its present site in the early 90 s. They employ a total of 43 persons over a 2 shift, 5 day cycle. In all the site utilise 3 units, two of which are identical in size while the third has been extended to double its former size. The buildings are in excellent condition and have been fitted out specifically for the company s role of converting label-stock into printed labels. The processes in use are Flexography, Lithography and Digital press. Products may be supplied in both sheet and roll variations. Originally occupying two units the company has doubled its capacity by acquiring adjacent units built to the same high standard as the original site, and a very modern office block. Demand for additional capacity has required still further expansion by extending a unit to double its original size. Kingsway have installed waste reduction initiatives and lean practices including 5S initiatives. Management and workforce have combined effectively to develop and maintain a very efficient operating structure, which enables the company to be flexible in achieving its objectives to make the highest quality safe and legal products. The company has developed compliance systems in accordance with ISO 9001:2008 and the requirements of the BRC Global standard for Packaging and other Packaging Materials. P027 Issue: 4 Page 1 of 12 Report No: UK/BRC/145

2 Detail of Non Conformities Summary of Non-Conformity Raised No. No. Critical non-conformity 0 Major non-conformity 0 Major against statement of intent of a Fundamental clause 0 Minor non-conformity 0 Critical No. Requirement ref. Detail of Non-Conformity Proposed audit date Reviewed by Major against SOI of a Fundamental Clause No. Requirement ref. Detail of Non-Conformity Proposed audit date Reviewed by Major No. Requirement ref. Detail of Non-Conformity Corrective action taken (with consideration of root cause) Evidence provided Document Photograph Visit/Other Date signed off Reviewed by Minor No. Requirement ref. Detail of Non-Conformity Corrective action taken (with consideration of root cause) Evidence provided Document Photograph Visit/Other Date signed off Reviewed by P027 Issue: 4 Page 2 of 12 Report No: UK/BRC/145

3 Company Name : Kingsway Printers Ltd Company Details Site Name : Humberston Address : Kingsway House, Bradley s Corner, Wilton Road Industrial Estate, Humberston, North East Lincolnshire Country : United Kingdom Postcode : DN36 4BG Telephone : Fax : Company Representative Name: Richard Pullan rpullan@kingswayprinters.demon.co.uk Key Personnel Name/Job Title Note: the most senior operations manager on site should be listed first and be present at both opening & closing meetings Opening Meeting Present at Audit (x) Site Procedure Inspection Review Closing Meeting Gary Davies, Company Director X X X X Mike Goddard, Sales Director, X X Mick Klug, Factory Manager X X X David Cullum, Estimator/Internal Auditor X X Audit Duration Details On-site audit duration 12 Man Hours Duration of production facility audit 3 Man Hours Reasons for deviation from typical (12 hours) or expected on-site audit duration or typical (3 hours) site inspection duration. None Audit Duration per day Start time Finish time Day Day P027 Issue: 4 Page 3 of 12 Report No: UK/BRC/145

4 Detailed BRC Requirement No. REQUIREMENT Conforms, N or N/A Details 1 SENIOR MANAGEMENT COMMITMENT AND CONTINUAL IMPROVEMENT 1.1 Product Safety and Quality Management System The senior management shall commit the company to producing products to the specified quality and which are safe and legally compliant Management commitment and general responsibilities are defined in section 2.1 of the Company s BRC Technical manual. This is dated August 2011, it is at issue 7 and is authorised by Richard Pullan, the MD. The manual also contains a policy statement declaring that products are manufactured to the strictest hygiene regulations and comply with all product safety, legal and quality requirements. This is also signed approved by the MD. 1.2 Senior Management Commitment FUNDAMENTAL The company s senior management shall demonstrate that they are fully committed to the implementation of requirements of the Global Standard for Packaging and Packaging Materials. This shall include provision of adequate resources, effective communication and systems of management review to effect continual improvement. Opportunities for improvement shall be identified, implemented and fully documented The company s senior management shall ensure that product safety and quality objectives are measurable, established, documented, monitored and reviewed The company s senior management shall have a system in place to ensure that the company is kept informed of all relevant legislative, scientific and technical developments, and industry codes of practice applicable in the country manufacture and, where known, the country in which the packaging material will be sold. Management commitment was clearly demonstrated by their presence at the opening meeting and throughout the assessment. The site hold certification to ISO 9001:2008 and formal controls are well embedded. Management review meetings are held every month. Customer KPI s, objectives and targets are clearly defined. The last review was held this month, August. The requirements of the standard have been realised. Objectives are appropriate to business needs; they are documented, monitored and reviewed by the team. The team hold a monthly meeting to continually refine business objectives. Noted the commissioning of a new press by the defined deadline. The Senior team gather information through internet research, trade publications, trade associations, Supplier communications; they do not export their products but know the raw materials comply with European directives The company shall ensure that the materials manufactured comply with the relevant legislation (including any legislation concerning the use of recycled content) in the country of manufacture and in which the products are intended to be sold and/or ultimately used, where known The company s senior management shall ensure that nonconformities identified at the previous audit against the Standard are effectively actioned. Paper products, raw materials include glue and inks all technical data from suppliers held on file. The paper details are as defined as specifications by the suppliers who are very well known to the industry. No NCR were raised last assessment The company shall have a current, original copy of the Standard available on site. A current copy is held by the team.(version 4) P027 Issue: 4 Page 4 of 12 Report No: UK/BRC/145

5 1.2.6 Where the company is certificated to the Standard they shall ensure that recertification audits occur on or before the audit due date indicted on the certificate. 1.3 Organisational structure, responsibilities and management authority The organisational structure shall be clear, with defined responsibilities, and key staff shall be aware of their responsibilities with regard to packaging safety and quality Conforming, Gary Davies ensured that the assessment was conducted in plenty of time to comply with the requirements of the standard. An organogram is present as page 6 of the BRC technical manual. It adequately identifies the reporting structure; the supporting procedure also clearly indicates quality and safety responsibilities. It is approved by Senior Management and is dated August Management review Opportunities for continuous improvement of the product safety and quality programme shall be identified and effectively implemented through management reviews of the product safety system and results The management review process meets the requirements of the standard, continuous improvement initiatives are clearly in evidence. They are defined in the management review and progress meeting targets is continually monitored. An example is the acquisition, installation and final commissioning of the new printing press. 2 HAZARD AND RISK MANAGEMENT SSTEM 2.1 Hazard and risk management team The hazard and risk management system shall be managed by a multidisciplinary team competent in hazard and risk analysis The team are composed of Senior and other Managers. This includes the Directors and Factory Manager. 2.2 Hazard and Risk Analysis FUNDAMENTAL The company shall establish the effectiveness of its prerequisite programmes through a hazard and risk analysis and identify and implement any further risks to the safety and legality of products The scope of the hazard and risk analysis shall be clearly defined and shall cover all products and processes included within the intended scope of certification The hazard and risk analysis team shall maintain awareness of and take into account: historical and known hazards associated with specific processes, raw materials or end use of the product relevant codes of practice or recognised guidelines legislative requirements A full description of the packaging produced by product or product group and its intended use shall be documented. A thorough hazard analysis has been conducted and has been in effect for several years. This is reviewed at least once annually or when changes to machinery, products or processes are realised. The HACCP was revisited due to the installation of the new press and is dated August No additional hazards were introduced due to the new press. A series of prerequisite programs is in place and their operation and effectiveness is continually monitored. The scope is defined as The printing and conversion of self adhesive labels and commercial print The HACCP accurately reflects this and adequately covers all products and processes. The team are composed of experienced and highly motivated Senior Managers. Their knowledge of the organisation is unequalled. Their understanding of customer requirements is excellent. They have been a presence in printing for many years and are extremely knowledgeable concerning their industry. All products have their own unique specification. Every order results in a different specification. Every job has its own unique job bag. This contains details of the intended use of the products. P027 Issue: 4 Page 5 of 12 Report No: UK/BRC/145

6 2.2.4 A process flow diagram shall be prepared for each product, product group or process. This shall include each process step from the receipt of raw materials to despatch to the customer. The process flow shall as a guide include, as relevant: receipt and approval of art work receipt and preparation of raw materials such as additives, inks and adhesives each manufacturing process step the use of rework and post-consumer recycled materials any sub-contracted operations customer returns. The accuracy of the process flow shall be verified by the hazard and risk analysis team. Satisfactorily detailed flow charts present All process steps defined on flow charts PRP s, Detailed on table of hazards; 9 CCP s 17 prerequisites, includes receipt and approval of art work. Low risk stated, the paper is regarded as virgin material and does not come into contact with food. Process controls for product integrity. QM02 and QM12 No sub contracted processes. Quality Manual Part 2 Section QM 05 Control of Nonconforming Product and Corrective and Preventive action Process controls for product integrity. Procedures QM02 and QM12. Have been verified by the team. Internal audit procedure Part 2 QM 24 assesses the system and processes The hazard and risk analysis team shall identify and record all potential hazards that are reasonably expected to occur at each step in relation to the product and process The hazards considered shall include, where relevant: foreign objects chemical contamination (e.g. taint, odour, allergen, component transfer from inks, varnishes and glues) hazards that may have an impact on the functional of the final product in use The hazard and risk analysis team shall identify control measures necessary to prevent, eliminate or reduce each hazard to acceptable levels For each hazard that requires control, the control points shall be reviewed to evaluate if existing prerequisites are effective in providing control. Where greater controls are required to the prerequisite programmes, improvements shall be implemented to ensure control is achieved A review of the hazard and risk management system shall be carried out at least once per year and following any significant incidents or when any process changes. The review shall include a verification that the hazard and risk analysis plan is effective and may include a review of: complaints product failures recalls product withdrawals results of internal audits of prerequisite programmes 1. results from external third-party auditors. The HACCP has accurately identified the potential hazards at each step and risk assesses the likelihood of them being realised as harm. There are 9 CCP s in all with a robust system of prerequisite controls to back them up. We note that the team are well experienced regarding risk management as they have been guided for years by an industry expert. They consider chemical, physical and biological factors, as well as allergens and quality defects when conducting assessments. Measures are in place to ensure hazards are controlled. This is done by ensuring that the right materials are acquired and that well proven and monitored process controls are in place. Measures are in place to ensure all potential hazards are controlled. This is done by ensuring the program of prerequisites is functional via daily monitoring and periodic audits by those independent of the function. The HACCP is reviewed at least once annually or when changes to machinery or processes are made. The last review covered the prerequisites programs in operation on plant and the associated objectives due to the installation of a new printing press. No changes or recalls were considered necessary other than planned system tests. Internal and customer audits indicated satisfactory results, generally customer satisfaction appears high and complaint levels are low for the industry. 2.3 Exemption of requirements based on risk analysis The site has demonstrated adequate compliance with the requirements of this clause Clauses 5.5.and PRODUCT SAFET AND QUALIT MANAGEMENT SSTEM The site do not have in line measuring equipment or precise measuring tools requiring calibration, these requirements have been risk assessed and are defined as exclusions. This is usual in industries producing labels from web stocks. Their integrity is largely based on functionality and conformance is determined by the experience of skilled printers rather than reliance on testing tools. Precision testing tools on or off line are not required to safely assure the products. The request for exemptions is accepted by the Auditor 3.1 Product safety and quality manual P027 Issue: 4 Page 6 of 12 Report No: UK/BRC/145

7 The company shall have a manual that describes how the requirements of the Standard are met. These requirements shall be fully implemented, reviewed at appropriate planned intervals and improved where necessary The company quality manual is comprehensive and well proven. It has been continually refined since the days of BS It adequately describes the systems in operation on plant defining how they meet the standard. The manual is supported by the BRC technical manual that addresses clauses not covered by the ISO manual. All formal manuals/documents are reviewed at least once annually and findings are reported in the main review. 3.2 Customer focus and contract review The company shall ensure that customer needs and expectation with respect to quality and safety are identified and met, and that communication channels are clear The Company have excellent relationships with customers and communicate with them continuously. Reviews are undertaken with every order. This is part of the software system in operation on plant. This electronic system ensures accurate database recording and repeated order processes conducted in a structured way. 3.3 Internal audits FUNDAMENTAL The company shall establish through a programme of internal audits that the implementation of the requirements of the Standard are in place, appropriate and complied with Internal audits shall be planned and their scope and frequency shall be established in relation to the risks associated with the activity. Audits shall be scheduled so that all aspects of the Standard are audited at least annually Audits shall be conducted by personnel who are competent, and sufficiently independent from the department being audited to ensure impartiality. Audits are defined to take place twice annually. (We note that the plant is inspected daily by a management representative, although this is not recorded) The formal audits are conducted to an in depth checklist that covers all aspects of the combined ISO & BRC system. The HACCP indicated 9 CCP s supported by 17 prerequisites. These are continually assessed but this is only formally documented during the planned system of audit, this ensures complete recorded coverage at least once per annum. Audits are conducted by David Cullum as he is independent of production responsibilities. He is an estimator Deficiencies and details of non-conformities shall be notified to appropriate supervisory staff and corrective action implemented within a specified and appropriate time period The completion of corrective action shall be recorded and verified Conformity as well as non-conformity shall be clearly identified and verified within the internal audit report. 3.4 Supplier approval and performance monitoring The company shall ensure that suppliers of goods and services are operating in a manner that ensures that product quality and safety is not compromised and specifications can be achieved Subcontracting of production Subcontractors shall be effectively managed to prevent any risk of contamination or damage and ensure product is produced to specification. 3.6 Documentation control This is a relatively small organisation, deficiencies are immediately dealt with as they arise or are identified by audit or any other means. i.e. customer complaint or legislative change. Gary Davies and Mike Goddard have this responsibility. Examined corrective actions raised as a result of customer complaints. These largely focus of the variations and deficiencies of papers, rather than printing issues. An action tracker is used. This determined and defines immediate correct actions and long term corrective actions initiated following research. Audit reports clearly identify conformity and nonconformity. They are well formatted and the internal auditors have been formally trained by a professional organisation. The protocols for doing this are defined in the quality manual, in a section defined as Assessment of Suppliers. All suppliers are sent questionnaires and are graded. It should also be noted that there are relatively few suppliers all with a long history of proven reliability. Sub contracting operations are undertaken rarely. They are approved by questionnaires. This typically would be folding leaflets, with low hygiene implications. All sub contracted work is returned to this site for review before final despatch. P027 Issue: 4 Page 7 of 12 Report No: UK/BRC/145

8 Documentation essential to the management and control of product safety, legality and quality shall be relevant, controlled and available, as the correct version, to the appropriate personnel Documents are available in hard copy and in electronic format. Gary Davies and Mike Goddard respectively control all documentation. This documentation is suitable and sufficient to ensure safe and legal products are made and complies with the mandatory requirements of ISO 9001 and the BRC standard. Appropriately stringent control mechanisms are in place to ensure only pertinent copies are available. 3.7 Specifications FUNDAMENTAL Appropriate specifications shall exist for raw materials, intermediate and finished products, and any product or service that could affect the integrity of the finished product Specifications shall be suitably detailed, accurate and shall ensure compliance with relevant product safety and legislative requirements The company shall seek formal agreement of specifications with relevant parties. Where specifications are not formally agreed then the company shall be able to demonstrate that they have taken steps to put an agreement in place. Specifications are appropriately detailed. An example studied was: Job No A well known provider of stationary products. Total order quantity. 50,000 labels. To be printed on Semi Gloss paper. Size 67mm x 140 mm. Required by 28/08/2011. The substrate types, inks, varnishes etc are all specified and technical information is held by the team. If the customer requires them, food packaging statements are available based on supplier information. The delivery note also defines storage conditions such as humidity and temperature controls. This is conducted between sales and the customer discussed with and explained by Gary Davies. Specifications are always produced; production could not go ahead without a specification Trademarks for application on packaging materials shall, where appropriate, be formally agreed between relevant parties. 3.8 Record Keeping The company shall maintain records to demonstrate the effective control of product safety, legality and quality Agreed at the specification production stages, discussed with Gary Davies. Reject trademarked products. It is currently agreed by customers that any rejects will be sent to landfill for disposal. The chance that they would be intercepted for counterfeiting purposes is unlikely as they are all made for low value products such as pickle jar labels or labels for tubs of dried herbs. Records are appropriately detailed. They are held in job bags. The completed orders detail materials used. Product specifications. Ink and varnish types. Who made by and when, on what production machinery. Also sample copy of label held in bag. s of compliance determine safety and legality. 3.9 Traceability FUNDAMENTAL The company shall have a system in place to identify product batches and to trace and follow all raw materials through processing to the distribution of the finished product to the customer. Records shall be retrievable in a timely manner An appropriate system shall be in place to ensure that the customer can identify a product or production lot number for the product for the purposes of traceability The system shall be tested to ensure traceability can be determined from raw materials to the finished product and vice versa. This test shall take place at least annually. Traceability is assured through specifications. These are very detailed. Explained by Gary Davies. All purchased materials have unique identification; this is entered on production records during conversion and follows jobs through all stages to despatch. Product recall and traceability was tested on 30 th August 2011 with SOP 11174, delivery date 23/08/2011. Simulated test print fault, worked satisfactorily Complaint handling All complaints made by customers and consumers shall be recorded and investigated. Corrective actions where required shall be implemented and recorded Management of incidents, product withdrawals and recalls Just 5 complaints received this month to date. Any complaints are due to deviations in the property of materials supplied, particularly papers. This can only be passed on to them for comment. Example of an actual complaint due to process deviations. Image darker than specified. Not following system, new colour standards produced. P027 Issue: 4 Page 8 of 12 Report No: UK/BRC/145

9 The company shall have a plan and systems in place to effectively manage incidents and if required the withdrawal or recall of products, in order to ensure that all potential risks to the quality and hygiene and legality of products are controlled This is clearly defined in procedures, the ISO system and the BRC manual. Tests undertaken to ensure effective product recall just conducted. Successful trial from raw materials in to finished goods despatched. Also the company are preparing for FSC certification. This will ensure enhanced traceability. 4 SITE STANDARDS 4.1 External standards All grounds within the site shall be finished and maintained to an appropriate standard Building fabric and interiors 4.3 Utilities 4.4 Security The internal site, buildings and facilities shall be suitable for the intended purpose. All utilities to and within the production and storage areas shall be designed, constructed, maintained and monitored to effectively control the risk of product contamination Product cleanliness and integrity shall not be compromised by the location, construction and delivery of the utilities to and within the production and storage areas Product and process integrity shall be assured through appropriate site security provision Layout and Product Flow Premises and plant shall be logically designed, constructed and maintained Equipment 4.7 Maintenance Product safety, legality and quality shall be ensured through the use of appropriate equipment that shall be properly designed and maintained Proper maintenance and monitoring of all equipment critical to product safety, quality and legality shall ensure consistent high levels of product safety, functionality and quality Well maintained units built to a very high specification Fabric excellent, clean and cleanable inspected daily and well serviced by competent pest controllers. No temporary engineering observed. Cleaning records up to date and FB controls satisfactory. Products segregated in marked bays, the site is very well constructed and is satisfactorily maintained. Utilities delivered to machinery in a structured and safe manner that gives consideration to product flow. The site is secure and is lockable, every unit is continually manned and staff are trained to challenge strangers. Signing in protocols are in place and escorts are available to tour the plant. The plant was purpose built and is very well laid out. It is light, airy and clean, it is well maintained. Product flow is logical and does not in any way effect product safety and legality through congestion or contamination. Machinery is obviously well maintained. Daily check sheet used to log machine faults. Planned maintenance is clearly evident. Machines are serviced by operators but specialised services are conducted by machine makers, particularly with the new press and ancillaries. On each machine a designated person has the duty of ensuring that machinery is inspected, repairs necessary are identified and corrective actions and planned maintenance takes place. This is further supported by periodic servicing of machinery by the providers. P027 Issue: 4 Page 9 of 12 Report No: UK/BRC/145

10 4.8 Staff Facilities Staff facilities shall be sufficient to accommodate the required number of personnel, and designed and operated to minimise the risk of product contamination. Such facilities shall be kept in a good and clean condition Staff facilities are adequate and are being improved and refurbished. They have been moved due to the introduction of the new press in unit Housekeeping and Cleaning FUNDAMENTAL Housekeeping and cleaning systems shall be in place, which ensure that appropriate standards of cleanliness are maintained and that risk of contamination to the product is minimised. Housekeeping is first class; the plant is scrupulously clean throughout. The risk of contamination is very low. Machinery is in a commendable condition of repair and good order Good standards of housekeeping shall be maintained, which shall include a clean as you go policy. Clean as you policies are clearly evident throughout the plant The cleaning of production equipment and internal surfaces of storage and production facilities shall be effectively managed using cleaning schedules Cleaning chemicals shall be fit for purpose, suitably labelled, secured in closed containers and used in accordance with manufacturers instructions. Materials and equipment used for cleaning toilets shall be segregated from those used elsewhere. Internal surfaces and production facilities well cleaned and are tidy, no evidence of temporary engineering anywhere throughout the operation. All conforming as per COSHH regulations. Toilet cleaning equipment is well segregated and is locked away when not in use Waste and waste disposal Suitable facilities shall be in place for the storage and disposal of process and other waste Pest Control The company shall be responsible for minimising the risk of pest infestation on the site Transport, storage and distribution All waste contained in identified skips and bins. Paper waste is compacted and goes to landfill. Pest control is contracted to a reputable company who are members of a major trade association. Records are up to date, site plans are up to date, visits are as per schedule and recommended corrective actions have been implemented. The risk of contamination of raw materials and finished products shall be minimised whilst in transport, storage or distribution. Use contracted services. Have specified needs for hygiene controls in terms and conditions. All carriers vehicles are inspected prior to loading PRODUCT AND PROCESS CONTROL 5.1 Product Design and Development Product design and development processes shall be in place to ensure the production of safe and legal products to defined quality parameters. 5.2 Packaging Print Control The Company does not design and develop; this is done by art houses. They merely print as specified by customers and appropriate procedures are in place to ensure they manage this effectively. They have extremely good relationships with blue chip companies, many of which are part of the BRC. Increased confidence in the company's ability to produce safe and legal products is resulting in 10% growth per annum. P027 Issue: 4 Page 10 of 12 Report No: UK/BRC/145

11 Processes shall be in place to ensure that print quality meets agreed specifications and critical print content such as allergen/safety/legal information is fully legible and correctly printed Discussed with Gary Davies and Mike Goddard. The customers approve all original art works. Samples sent prior to production runs. This is part of the process control procedure and production will not go ahead unless all requirements have been fulfilled. Discussed this with Senior printers and was shown evidence for every job running. 5.3 Process Control FUNDAMENTAL The production process shall be controlled through effective quality assurance of operations to ensure packaging materials can be consistently produced to the quality specified by customers The company shall undertake a review of the manufacturing and, where applicable, printing process to identify critical manufacturing process control points that could affect the quality of the products produced For each critical manufacturing process control point, machine settings or process limits shall be established and documented the process specification Documented process checks shall be undertaken at start up, following adjustments to equipment, and periodically during production, to ensure products are consistently produced to the agreed quality specification A clearance procedure shall be in place to ensure that at start up, the line is clear of all previous work and production documents. ISO procedures have been developed over many years to ensure that processes are in place to ensure the quality, safety and legality of products. The systems in operation are similar to those used by others in the printing industry and have been well tried and tested. Processes are all subject to internal audits. Efficiencies are calculated continually. Quality standards are clearly defined and are monitored throughout production runs. Losses are identified and have to be accounted for. Make ready is a fundamental part of all printing. This is only undertaken by experienced printers under the scrutiny of the Senior printers. Continually checking output. Work Instructions define testing methods and frequencies. The usual tests are in place. Colour matching against customer approved samples. Reference to colour standards. Rub tests, bar code reading. All in operation. When job is finished the line is always cleared of all materials In the event of changes to product composition, processing methods or equipment, the company shall, where appropriate, re-establish process characteristics and validate product data to ensure product safety, legality and quality are achieved. Not likely. Changes to the composition of papers and inks are very rare and are only undertaken following extensive trials by the suppliers themselves. 5.4 Product inspection and analysis The company shall use appropriate procedures and facilities when undertaking or subcontracting inspection and analyses critical to product safety, legality and quality Do own testing do not send out products for analysis. This is done to well tried and tested methods used by printers worldwide. 5.5 In-line testing and measuring equipment 5.6 Calibration In-line measuring or product testing equipment, where used, shall be tested and maintained to ensure it is N/A effective in ensuring product safety integrity and quality N/A N/A Do not have any in line testing equipment Where specialist measuring is required to assess compliance with product safety and legality, the devices N/A shall be maintained and calibrated N/A N/A Do not calibrate, do not need to do specialist measuring. 5.7 Control of non-conforming product The company shall ensure that out-of-specification product is clearly identified, labelled and quarantined The procedure for dealing with nonconforming products is defined in the quality manual and in the BRC manual. Basically if it isn t good enough it is scrapped and remade. If it is a material or chemical that deviates it is returned to suppliers pending investigations and claims. P027 Issue: 4 Page 11 of 12 Report No: UK/BRC/145

12 5.8 Foreign body contamination control The company shall be able to demonstrate that effective controls are in place to ensure product is protected from contamination during production and storage Foreign body control Sharps Control Chemical and biological control Controls shall be in place to prevent contamination from chemical hazards The factory is in excellent condition, the work place very well controlled, foreign body controls are excellent, there is no evidence of temporary repairs anywhere on plant.. All conforming to the COSHH regs. Chemicals identified and put away when not in use. Colour coding and segregation of cleaning tools is practiced. 6 PERSONNEL 6.1 Training and competence FUNDAMENTAL The company shall ensure that all employees are adequately trained, instructed and supervised commensurate with their activity and are competent to undertake their job role All personnel, including temporary personnel, shall be appropriately trained prior to commencing work and adequately supervised throughout the working period The company shall routinely review the competencies of staff and provide relevant training as appropriate. Records of training shall be maintained. Training was done by David Cullum and is refreshed annually. Done at induction. Using internally designed modules based on the requirements of ISO and the BRC. Hygiene and foreign body controls as well as dress codes and jewellery policies are well defined and are adhered to as witnessed on the site tour. Competencies are performance indicated and all employees are assessed continually. Incompetence comes to light very quickly in printing as it is an exacting skill. 6.2 Access and movement of personnel 6.3 Personal hygiene The company shall ensure that access and movement of personnel, visitors and contractors shall not compromise product safety and quality The company s personal hygiene standards shall be documented and adopted by all personnel, including visitors to the production facility. These standards shall be developed with due regard for risk of product contamination Protective Clothing The risk of product contamination from clothing, hair or personal items shall be minimised The factory is laid out in zones with well defined walkways and bays. Damage to the quality and safety of raw materials or finished products is unlikely Appropriate controls and training in place. All employees observed were appropriately attired and were not wearing banned jewellery. Visitors are provided with coats and are asked to remove banned jewellery; a thorough health screening questionnaire is in place. Company provided work wear, risk assessed and adequate to the task. Not considered necessary to wear head covering, this has been risk assessed and is considered unnecessary. Complaints support this, there have been no hygiene complaints concerning body hair. P027 Issue: 4 Page 12 of 12 Report No: UK/BRC/145