Section 5.6 of the Standard requires the site to identify and undertake product inspection and testing. This is split into 2 areas – tests that are critical to the product safety or legality of the product, and other routine tests that are of value to the business.
However, during the Covid-19 there may be a number of reasons why the normal schedules and tests completed should be reviewed. These include:
- Accredited laboratories may be busier than normal, offering a reduced service due to staff availability or refusing work that does not relate to the current crisis.
- Staff at the manufacturing site may be reduce or be deployed to maximise production
- Production schedules may have changed with a reduced range of products being produced
- New raw material suppliers or supply chains introducing new or changing risk
Obviously, to manage these changes effectively requires a planned approach. BRCGS recommend the following:
- Review testing schedules – now is a key time to review the scheduled tests - identify the tests that are critical to product safety and legality – the very definition of these is that there is a need to maintain the appropriate schedule, unless the product is not being manufactured or the raw material is no longer being used.
- Obviously if production of a specific product is temporarily suspended (or the use of a specific raw material stopped) then there is no requirement to continue tests on these products until production/use recommences.
- Talk to contract laboratories – also a key preparatory activity – understand any limitations to their normal services and if necessary, review the implications of this for the site’s products and processes. Do you receive regular updates from your contract laboratories? Many are providing customers with service updates, in addition to additional recommendations and useful information. If the preferred provider is unable to provide a service for a critical test are other service providers available?
- Where tests are not critical to safety or integrity, review whether there is a business need for them to be completed during the crisis or whether re-scheduling is a sensible option.
- Raw material risk assessment (clause 18.104.22.168), supplier approval (section 3.5.1 and especially clauses 22.214.171.124 and 126.96.36.199), HACCP processes (section 2) and vulnerability assessment (section 5.4) should be used to identify any new risks that could/will be introduced by changes to raw materials or supply chains. Do any of the controls for these new risks include testing, if so have the tests been arranged/scheduled?
- Keep the review process up to date – situations are likely to continue to evolve, for example, changes to raw materials, and an ongoing assessment process is likely to be required.
- Don’t forget to review the results! When we are busy, it is very easy to forget. However, there is little point in completing a test if its significance is not understood and where necessary, acted upon. This is of course, is the whole purpose of clause 188.8.131.52.