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ISA Netherlands

p.a. Industrieweg 16
8131 VZ Wijhe
Nederland
Tel.: +31 (0)570 524 688
Fax.: +31 (0)570 524 453
BRC/IoP Global Standard
Food Packaging and Other Packaging Materials -
Version 2
Issue 2
Auditor: J . Quirijnen
2007-2228-BRC/IoP
This report shall not be reproduced in part without the permission of
ISACert The Netherlands
Page 1 of 26

of
Euro Pool System International BV
on
19 and 20 February 2007
Detailed Audit
Issue 2
Auditor: J . Quirijnen
2007-2228-BRC/IoP
This report shall not be reproduced in part without the permission of
ISACert The Netherlands
Page 1 of 26
Part 1 - Audit summary
Audit details
Auditor: Signature: Audit Date: Date of intial audit:
Repeat audit
J . Quirijnen 19 and 20 February
2007
18 and 28 September
2006
Country:
Belgi
Supplier name:
Euro Pool System International BV
Address, Postal Code, City:
Industrie zone 4, Broekooi 170, 1731 Zellik
Emailaddress:
valentine.vandermeer@europoolsystem.com
Scope of the Audit
Purchase, receiving, cleaning, storage and distribution of returnable
hard plastic crates intended for the direct and indirect storage of
food
Tel. Nr:
Fax. Nr.:
0032 2 464 9602
0032 2 464 96 01
Issue 2
Auditor: J . Quirijnen
2007-2228-BRC/IoP
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ISACert The Netherlands
Page 2 of 26
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food.
Present at Audit (X)
Name Function
Mr. L. Selleslags Chief Operational Officer
Category:
B
Mr. G. Luyts Operations Manager Benelux
Mr. L. Haaksman Technical services
Mrs. van der Meer Corporate Quality Manager
Mr. P. Thijs Depot manager Zellik
Mr. D. J anssen Operator
Mr. K. Wtavir Forklift truck driver / sorter
Mr. N. Bernaerts Process engineer
Mr. Komlan Operator
Audit started at
Date 2 9:00 h
Audit ended at
Date 2 15:30 h
Mr. D. Samaey Service provider
Audit started at
Date 1 9:00 h
Audit ended at
Date 1 13:30 h
Result of the Audit
International Supplier Auditing bv has established that the
processes of the Company on date 19 and 20 February 2007 for the
scope as stated above did fulfil the requirements for the BRC-IoP
Standard.
repeat audit
12 months
Previous Evaluation Grade B Evaluation Grade B
Issue 2
Auditor: J . Quirijnen
2007-2228-BRC/IoP
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ISACert The Netherlands
Page 2 of 26
Euro Pool System is a rental company for returnable packaging for fruit and vegetables and
other packed food products. The company is originated from three auctions. The head office of
Euro Pool System is located in Leidschendam, the Netherlands. In Zellik Euro Pool System
does has got a plant where dirty crates are cleaned and shipped to customers. In totally Euro
Pool Systems does have 40 clean installations all over Europe, which are all outsourced with
the exception of the cleaning location at Zellik. In totally Euro Pool Systems does have
approximately 100 employees. Per year 30 million crates are cleaned in Zellik and 400 million
in total in Europe. In Zellik the cleaning process is a 3 shift operation during 5 days / week. The
plant is 3 years old. The production organisation in Zellik is outsourced but the depot manager
and technicians are working for Euro Pool System. Euro Pool system does have 2 types of
crates, crates which can fold in and crates which are fixed. During the audit the cleaning of
foldable crates was carried out.
General Company Information
Issue 2
Auditor: J . Quirijnen
2007-2228-BRC/IoP
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Page 3 of 26 Issue 2
Auditor: J . Quirijnen
2007-2228-BRC/IoP
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Page 3 of 26
Dear reader,
Aim of the report:
This impression is based on:
1. Audit from a production day (s) (sample)
2. Assessment against the selected technical standard
3. The professional opinion of the auditor
The auditor can judge the non-conformities found as: critical, major or minor.
To gain the maximum benefit from this information, we advise you to read the following:
To obtain a reliable impression in how the supplier meets the production process controls,
concerning the specified requirements for product quality and food safety.
Weighing of the non-conformities is never totally objective and the auditor decides the
seriousness of non-conformity found.
Tips for the reader of this report
Issue 2
Auditor: J . Quirijnen
2007-2228-BRC/IoP
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Page 4 of 26
The ISA report contains:
Information about the auditee
The result of the audit
Summary of the non-conformities found
Improvement plan of the auditee to solve the found non-conformities
Detailed audit report with an overview of all the findings of the auditor
If there are any questions, please let us know.
Experience has taught us that every reader has there own ideas about scoring of a non-
conformance and the gravity of it. This will be due to culture, own experiences, education and
background.
The ISA Report gives transparency to the reader. The auditee prepares a corrective action
plan based on all the non-conformities found. You will find the corrective action plan after the
summary of performance in the audit report. Besides this corrective action plan, the auditee
must obtain objective evidence for solving those non-conformities. This objective evidence
must be send to ISA and will be judged by the auditor.
ISA wants to add confidence in the chain by creating transparency and working against high
standards.
Issue 2
Auditor: J . Quirijnen
2007-2228-BRC/IoP
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Page 4 of 26
ISA-Audit Report
Part 2 Summary of performance
Section of Standard
2 ORGANISATION:
3 HAZARD AND RISK MANAGEMENT SYSTEM:
4 TECHNICAL MANAGEMENT SYSTEM:
Euro Pool System has a organisation chart including descriptions of responsibilities. \The
quality policy includes product safety and hygiene aspects. Top management is clearly
involved. Responsibilities are defined. A covering during absence is organised. The
management review is carried out yearly and is including the evaluation of the HACCP system.
During the audit no non-conformities regarding organisation are established.
Euro Pool System does have implemented a HACCP system. The risk assessment is based on
a "likelihood x severity" system resulting into 4 possible risk categories. Euro Pool System did
not established CCP's but several "control points" relating to hygiene are part of the HACCP
system (pre requisite program), such as cleaning procedures, pest control and glass policy.
Verification is carried out. During internal audits "CCP's" are audited. During the audit no non-
conformities regard the hazard and risk management system were established.
The quality policy is clear and includes food safety and hygiene aspects. During the audit it
ti d th t thi li i d t d b th l Th Q lit l i ti l
Issue 2
Auditor: J . Quirijnen
2007-2228-BRC/IoP
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ISACert The Netherlands
Page 5 of 26
was noticed that this policy is understood by the personnel. The Quality manual is operational
and does include a cross reference list BRCIoP. Record keeping, document- and specification
control is conform requirements. A product recall procedure is available. Non conform product
is handled correctly. During the audit a traceability test was conducted; results were conform.
The process control of the rinsing of crates is highly automated and conform requirements.
Calibration on the conductivity equipment (concentration of cleaning detergent) is carried out.
Complaint procedures are implemented. The control of outsourced service providers is clear
and includes regular audits and other verification systems. Corrective actions are taken. A
monitoring on microbiological aspects is implemented as well as a visual verification system
based on DIN 10522. During the audit no non-conformities regarding the technical
management system were established.
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Auditor: J . Quirijnen
2007-2228-BRC/IoP
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The perimeter and grounds are well maintained. The City forbids Euro Pool System to remove
plants against the outer wall of a part of the factory but plants are kept as small as possible.
The product flow goes from dirty to clean and prevents cross contamination. The factory is only
a few years old and of a good standard. The preventive maintenance of equipment is
organised very well and is based on an inspection system carried out regularly by an external
company. Euro Pool System does not use food grade lubricants but during the audit it was
noticed that on one spot the risk of product contamination was possible. A clearance procedure
after maintenance is implemented. The house keeping and hygiene rules are clear and
implemented. The general hygiene of the factory is very high. Non conformities regarding a
broken door, lubricants and the labelling of cleaning chemicals were noticed.
Foreign body control is controlled well, due to the high hygiene standard of the factory. A glass
procedure is implemented and glass audits are recorded. The use of sharps is adequately
controlled. Chemicals are correctly stored. Pest control is outsourced and complies to the
standard. Transport is outsourced. During the audit no non-conformities regarding
contamination control are established.
7 PERSONNEL:
6 CONTAMINATION CONTROL:
Personnel enters the building via dedicated routes. Personnel facilities are adequately
designed and maintained. This includes toilets and hand washing facilities. The personnel
5 FACTORY STANDARDS:
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2007-2228-BRC/IoP
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g g p
hygiene rules includes demands on health / sickness, jewellery and other personal items.
Protective clothing is organised. Personnel washed protective clothing at home. Training on
hygiene is given out for all personnel and records of these training are being kept. During the
audit one non conformity regarding the hygiene rules for contractors was established.
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Auditor: J . Quirijnen
2007-2228-BRC/IoP
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MAJOR NON-CONFORMITIES
Foundation Level

Nr. Reference Level Requirement BRC-IOP Global Standard Clarification Date
MINOR NON-CONFORMITIES
AB Level
Nr. Reference Level Requirement BRC-IOP Global Standard Clarification Date
1
5.3.1 AB External walls shall be well maintained and
of sound construction.
N External door at the back of the factory
is broken. Door blocked with means of
pallets (but this is not 100 % closed).
E t t t l
ISA-Audit Report
Part 3 Non-conformities / Schedule of Action
CRITICAL NON-CONFORMITIES
No critical non-conformities were established
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Auditor: J . Quirijnen
2007-2228-BRC/IoP
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Page 7 of 26
Extra pest control measures
implemented. Other door at the back
was slightly damaged (small opening
under the door which could allow
mouse to enter the building).
2
5.5.10 AB Cleaning chemicals shall be fit for purpose,
suitably labelled, secured in closed
containers and used in accordance with
manufacturers' instructions.
N Close to the palletiser a white plastic
bottle without label detected. In the first
floor in the "storage area" a orange
extract stored for the removal of labels.
In the "dirty crate area" a red box with
brush detected. the content of this box
is not clear.
3
7.1.5 AB Contractors and visitors shall be made aware
of all hygiene procedures for the premises
and made especially aware of the
requirements of the areas they are visiting.
N External contractors do not sign in at
the entrance and therefore do not
receive the correct version of the
hygiene rules.
MINOR NON-CONFORMITIES
B Level
Nr. Reference Level Requirement BRC-IOP Global Standard Clarification Date
1
5.4.5 B A planned preventative maintenance
programme for plant and machinery shall be
in place and shall address the risks of
contamination.
Compressed air that comes into contact with
the product should be filtered to prevent any
contamination.
N At the grease points "kantelbakken" no
food grade lubricants are being used,
although a risk of product contamination
does exist at this point.
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2007-2228-BRC/IoP
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Issue 2
Auditor: J . Quirijnen
2007-2228-BRC/IoP
This report shall not be reproduced in part without the permission of
ISACert The Netherlands
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2007-2228-BRC/IoP
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Issue 2
Auditor: J . Quirijnen
2007-2228-BRC/IoP
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ISACert The Netherlands
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2007-2228-BRC/IoP
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Section
L
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Intention BRC
IOP
Version
2
Motivation
2
2.0
2.0.0 There shall be an organisational structure, which clearly
defines job function, responsibility and reporting
relationships of those staff whose activities affect the
implementation and compliance with the Standard.
Y Responsibilities are described in ORG 201. Seen
job description Corporate Quality manager.
2.1 AB The responsibility for the implementation and
maintenance of the principles contained in this standard
shall rest with the most senior on-site management
team
Y During the audit it was noticed that the senior
management team is fully involved in the
development, implementation and maintenance
of the quality system. This is demonstrated via
the quality policy GEN 120 dated 110706, signed
by the director as well as the involvement of the
management during the whole audit.
2.2 AB There shall be verifiable, written evidence that the team
acknowledges this responsibility, has assigned the
appropriate resources and given sufficient priority to the
continued compliance of the site with the Standard.
Y The involvement of the top management is
demonstrated by the quality policy. Also during
the audit the active involvement of the
management was clearly demonstrated
2.3 AB The control of the system implementing the Standard
shall rest with a suitably competent person (the
Y The Quality manager is responsible for the
implementation of the standard During the audit
Organisational structure
Part 4 Detailed Audit Findings
ORGANISATION
shall rest with a suitably competent person (the
designated manager). The designated manager shall
be able to draw from expertise of suitably competent
personnel either from within the company or from a third
party. The designated manager shall be sufficiently
senior to have direct operational responsibilities
compatible with the priority stated in 2.1 by the
management team.
responsibilities compatible with the priority stated in 2.1
by the management team.
implementation of the standard. . During the audit
it was sufficient demonstrated that she does have
the requested knowledge regarding HACCP /
general hygiene demands.
2.4 AB The designated manager shall have a designated
suitably competent deputy to provide support and cover
for absence.
Y During absence of the corporate quality manager
her responsibilities will be covered according the
descriptions in the "absence matrix".
2.5 AB A management review team consisting of relevant
operations managers, including the designated
manager, shall meet at a pre-determined frequency, to
ensure the effective maintenance of this Standard. This
team shall report compliance to the senior management
team. The management review team shall, identify
need for change and make recommendations on
appropriate action. There shall be verifiable evidence of
the proceedings of these meetings and the completion
of any actions arising.
Y Seen management review may 2006 about 2005.
The review of 2006 is being prepared. Review is
carried out yearly.
2.6 AB The senior management team shall ensure that
processes are in place to determine their customers'
needs and expectations, clearly define their
requirements and ensure that these requirements are
fulfilled.
Y Euro Pool system has a procedure implemented
to determine the needs and expectations of
customers.
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Auditor: J . Quirijnen
2007-2228-BRC/IoP
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Page 10 of 26
Section
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Intention BRC
IOP
Version
2
Motivation
3
3.0
3.0.0 The company shall keep recorded exemption to the
Standard under review. Production of satisfactory
documentation at subsequent evaluations shall lead to
continued acceptance of the exemptions
Y Seen cross reference chart dated 181006.
3.1.1 AB The company shall conduct a formal hazard analysis on
production processes considering microbiological,
foreign objects and chemical contamination, product
integrity, legality and defects critical to consumer safety.
The hazard analysis will be based on the range of uses
of the packaging products promoted by the company.
Y Seen hazard analysis GOH 406 risk analysis and
determination of CCP's and CP's. Euro Pool
System does note have CCP's identified. Only
CP's with relation to hygiene procedures are
identified.
3.1.2 AB Upon a request in writing from a customer, the
company shall conduct a supplementary hazard
analysis specific to a use of a product of the company
that is outside the promoted range os uses, and this
shall be specific to that use and for that customer only.
NA There is no customer with a specific request on
hazard analysis.
3.2 The Hazard analysis should incorporate the following
steps:
Y See items listed further.
3 2 1 AB Established a precise validated plan of process flow(s) Y Seen flowchart GOH 404 version 2
A formal hazard and risk management system shall be in place to ensure that all hazards to
HAZARD AND RISK MANAGEMENT SYSTEM
3.2.1 AB Established a precise, validated plan of process flow(s). Y Seen flow chart GOH 404 version 2.
3.2.2 AB Identify and record hazards associated with each
process step and the controls required.
Y Seen hazard analysis GOH 406.
3.2.3 AB Assess the risk level for each hazard based on the
likelihood of the occurrence and severity of outcome.
Y The risk assessment is based on likelihood and
severity, resulting in four risk categories.
3.2.4 AB Identify those steps witch are critical to the process
(critical process steps)
Y Euro Pool System does not have identified CCPs.
Several Control points relating to hygiene have
been established.
3.2.5 AB Decide which sections in 5, 6, and 7 are not applicable
to the company using hazard analysis, and document
the reasons for their exclusion.
Y Three items are declared not applicable and
motivated through the hazard analysis.
3.2.6 AB Confirm the process control and monitoring procedures
appropriate to the level of risk.
Y Validation procedure is available. Last validation
on may 2006.
3.2.7 AB Establish the documentation for all the procedures and
records necessary to maintain process control.
Y Documentation regarding HACCP system is
available. Registration of the control of "CP's"
regarding hygiene are seen during the audit.
3.2.8 AB The controls required by the hazard analysis shall be
regularly reviewed, verified and validated to ensure they
are still functioning efectively and to ensure that they
are still up to date and reflect current knowledge.
Y Verification procedure is available. Seen
verification of the HACCP system 2005.
Verification of 2006 is being developed (as part of
the management review).
3.3 AB Following the completion of this analysis, measures to
monitor the critical process steps shall be implemented,
maintained and reviewed.
NA Euro Pool Systems did not established CCP's.
For CCP's an operational program is established.
3.4 AB The hazard analysis, and resulting procedures, shall
have senior management commitment, and shall be
implemented through the company's documented
management systems.
Y During the audit is demonstrated that Euro Pool
System did implement the HACCP system.
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Auditor: J . Quirijnen
2007-2228-BRC/IoP
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Page 11 of 26
Section
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Intention BRC
IOP
Version
2
Motivation
3.5 AB Procedures relating to the monitoring of critical process
steps shall be included in internal audits against the
Standard (section 4.9).
Y Seen internal audit dated 121006 including e.g. .
hygiene.
4
4.0
4.0.0 This shall include all Quality and Hygiene systems
throughout the organisation's site(s).
Y The Quality management system is operational.
4.1
4.1.0 Senior management shall define the company's Quality
and Hygiene policy ensuring that it is documented,
implemented, maintained and communicated to all
employees.
Y The Quality mission statement and Quality policy,
code GEN 120, is dated 110706.
4.1.1 AB The policy shall state the company's intention to meet
its obligations to produce safe and legal products and
its responsibility to its customers.
Y The policy does mention the intention of Euro
Pool System to deliver safe and legal products.
4.1.2 AB The policy shall be understood by all supervisory and
relevant personnel and has been implemented
accordingly.
Y During interviews with the Depot manager and
the technical service manager, it is demonstrated
that the policy is understood.
4.1.3 AB The policy shall be communicated throughout the
company and regularly reviewed.
Y The Quality policy is yearly explained towards
personnel in a formalised meeting. Last
explanation has been carried out in J anuary
2007.
Technical Management Policy
TECHNICAL MANAGEMENT SYSTEM
Technical management system
4.2
4.2.0 The company shall have a manual that states its
commitment to Quality and Hygiene and has a scope
which covers the requirements of this Standard.
Y The Quality manual describes how the
requirements of the standard are being met.
4.2.1 AB A manual shall be maintained as an essential element
of demonstrating compliance with this Standard.
Y Seen cross reference list GOH 413.
4.3
4.3.0 The company shall maintain records to demonstrate the
effective control of product safety, legality and quality.
Y Euro Pool System does have a procedure for the
control of records.
4.3.1 AB Records shall be maintained in order to prove that
technical and hygiene procedures have been followed.
Records shall include as a minimum the following:
- Records supporting product compliance
- Training
- Cleaning schedules and cleaning records
- Instances of foreign-body contamination or other such
breakdown of sysstems
- Receipt and investigation of customer complaints
- Internal auditing
- Pest control reports and records
- Maintance and engineering work records
- Controle of non-production glass an brittle plastics
- Controle of blades and sharp objects
- Product recall (if applicable)
- Non-conforminf goods records
- Tracebility
Y During the audit Euro Pool System demonstrated
the control of all required records.
Quality Manual
Record Keeping
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Page 12 of 26
Section
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Intention BRC
IOP
Version
2
Motivation
4.4
4.4.0 The company shall establish and maintain documented
procedures to control all documents and data that relate
to the requirements of this Standard.
Y Procedure "document control, describes the
control of documents and data related to the
standard.
4.4.1 AB All documents in use shall be properly authorised and
be the current version.
Y Version control is electronically. After approval of
the management team and/or HACCP team
documents are published.
4.4.2 AB Documents shall be clearly legible, unambiguous and
sufficiently detailed to enable their correct application by
appropriate personnel and shall be readily accessible at
all times.
Y During the audit no non conformities are
established regarding the application of
documents. Documents are available for the
personnel.
4.4.3 AB All changes and amendments to documents critical to
product safety, legality or quality system procedure and
covered by the Standard's requirements shall be
recorded.
Y During the audit no deviations regarding the
control of documents are spotted. Seen
electronically control of versions.
4.4.4 AB A procedure shall be in place to ensure that obsolete
documentation is rescinded and, if appropriate,
replaced with a revised version.
Y Obsolete documents are removed by the head of
department .
4.4.5 AB Documentation and records shall be retained as defined
within the company quality manual, and the period of
record retention shall relate to the end use of the
packaging.
Y The retain period of document is related to the
shelf life of the packaging.
Documentation Control
4.5
4.5.0 The company shall ensure that appropriate
specifications exist for:
- raw material (including product packaging)
- intermediate product
- finished product
- any product or service which could affect the integrity
of the finished product.
Y During the audit Euro Pool System showed that
appropriate specifications exists.
4.5.1 AB Material specifications shall be maintained, which
ensures that the components or articles that come into
contact with food shall be suitable for their intended
use.
Y Seen specifications model 610 drawing BEKU-
27.12.06 and o4-BP-24-08; specification product
data 610 and technical datasheet "folding and
rigid reusable3 containers. Colours used
according 1935/2004. Specifications are conform
requirements.
4.5.2 AB Specifications shall be adequate, accurate and ensure
compliance with relevant safety and legislative
requirements.
Y Specification of " model 610 is accurate and
sufficient.
4.5.3 AB Specifications shall, where appropriate, be formally
agreed with relevant parties.
Y Above mentioned specification is formally
approved.
4.5.4 AB Trademarks for application on packaging materials
shall, where appropriate, be formally agreed with
relevant parties.
NA Euro Pool System does not have trademarks on
their crates.
4.5.5 AB The company shall operate a specification review
procedure.
Y Seen PRO 339.
4.6
4.6.0 The company shall have effective control of incidents in
order to ensure that all potential risks to the quality and
hygiene of products are controlled.
Y Euro Pool System did establish a procedure for
incidents and recalls.
Specifications
Management of Incidents and Product Recalls
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Page 13 of 26
Section
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Intention BRC
IOP
Version
2
Motivation
4.6.1 AB The company shall provide written guidance to relevant
staff regarding the type of event that would constitute
an 'incident' and a documented incident reporting
procedure shall be in place.
Y Seen PRO 337 130706 which includes guidance
to relevant staff regarding incidents.
4.6.2 AB Procedures shall exist to ensure that customers are
notified should an incident take place, which has
potentially contaminated the product that has been
delivered to the customer.
Y Procedure regarding the notification of customers
where part of the recall procedure.
4.6.3 AB An effective documented "Product Recall" procedure
shall be in place.
Y Seen PRO 337 130706.
4.6.4 AB Clear procedures for the control of out-of-specification,
non-conforming materials, including rejection,
acceptance by concession or, regarding an alternative
use, shall be in place and understood by all authorised
personnel.
Y A Procedure for the control of non conforming
materials was implemented.
4.6.5 AB Corrective actions shall be implemented to avoid
recurrence of the non-conformance and adequate
documentation of the action taken.
Y Corrective actions are part of above mentioned
procedure.
4.6.6 AB All non-conforming products shall be handled or
disposed of according to the nature of the problem
and/or specific requirements of the customer. The
method of disposal and/or destruction of trademarked
goods shall be agreed with the trademark holder.
Y During the audit is was demonstrated that non
conforming products are rejected out of the
process automatically and by the personnel.
Trademarks are not relevant for Euro Pool
System.
4.6.7 AB The company shall establish and maintain a
documented procedure to ensure that a product that
does not conform to requirements and could become a
hazard is prevented from unintended use.
NA Abuse of crated is described within the HACCP
system. Euro Pool System is not responsible for
this abuse.
4.7
4.7.0 A system shall be in place to trace and follow materials
through all stages, including purchasing, processing,
distribution and customers.
Y Euro Pool System does have a traceability
system implemented. During the audit a
traceability test was conducted on "M-bak '96-9".
Results conform requirements.
4.7.1 AB The company shall ensure that its suppliers have
appropriate traceability systems in place.
Y During audits at suppliers verification of tracking
and tracing takes place.
4.7.2 AB An appropriate system shall be in place to ensure the
customer can identify a product.
Y All crates are coded. This code relates towards
the "production" of the crates at the supplier.
4.8
4.8.0 Procedures shall be in place to ensure effective control
of all operations throughout the process relating to
critical product defects.
Y Euro Pool System could demonstrate the control
of all critical activities (CP's). Euro Pool System
does not have identified CCP's.
4.8.1 AB The company shall ensure that there are sufficient and
appropriate process controls to prevent the occurrence
of critical defects.
Y Euro Pool System does have sufficient and
adequate process control implementer in order
to prevent critical defects; e.g. non conforming
crates (damaged) are automatically sorted out,
cleaning process is automated with temperature
and concentration control of detergents.
PROCESS Control
Traceability
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2007-2228-BRC/IoP
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4.8.2 AB In order to prevent contamination, procedures shall be
in place to appropriately segregate raw materials, work
in progress and finished products.
Y Contamination risks are limited by the process
flow as well as through the implemented
procedures (e.g. cleaning procedures). Their is a
clear distinction between the area with dirty
crates and rinsed crates.
4.8.3 AB The company shall operate procedures that verify that
the processes and equipment used are capable of
consistently producing safe and legal products with the
desired quality characteristics.
Y Euro Pool System does have procedures to
confirm processes and equipment are capable of
producing safe and legal products within the
specified quality e.g. monitoring of bacteriological
results on crates, visually inspection of crates
according DIN 10522.
4.8.4 AB Measuring equipment used to monitor critical
manufacturing process points and the product's
compliance with relevant legal requirements, shall be
calibrated and where possible, traceable to a
recognised national standard.
Y There is a system for calibration of measuring
equipment. Only the conductivity measure
equipment is calibrated externally. Seen
calibration report dated. 170107.
4.8.5 AB Raw material monitoring of all incoming materials for
hygiene and technical criteria shall be specified.
Inspection method, frequency and procedures shall be
specified and documented.
Suppliers of incoming materials, as appropriate, shall
provide evidence of guarantees,
NA There is no control of incoming crates. They are
dirty and will be washed during the process.
certifications/declarations of analysis or certificates of
conformity.
4.8.6 AB Incoming goods shall, where appropriate, be subject to
checks to ensure that the integrity of the materials is not
compromised
NA There is no control of incoming crates. They are
dirty and will be washed during the process.
4.8.7 AB Non-conforming materials or returned products shall be
subject to inspection and positive release.
Y Together with the empty dirty crates also "non
conforming food" is returned. This food is directly
segregated and removed into a closed waste bin
several times a day.
4.9
4.9.0 The company shall audit those systems, procedures
and operations that are a requirement of the Standard.
Y During the audit Euro Pool System showed with
procedure PRO 326 that is has got an internal
audit system.
4.9.1 AB Nominated adequately trained personnel shall carry out
internal auditing at specified regular intervals.
A documented audit procedure shall be in place taht
will include the frequency of internal audits. Frequency
is based on hazard analysis. Where internal auditing
has indicated that corrective action is required, action
indicated and taken shall be documented.
Y Auditors are trained personnel. Audits are carried
out by the
4.9.2 AB Internal auditors shall be carried out by competent
auditors, who shall be independent of those personnel
having direct responsibility for the activity being audited.
Y Auditors are independent and trained.
4.9.3 AB Deficiencies and details of non-conformances shall be
notified to appropriate supervisory staff and corrective
action implemented within a specified and appropriate
time period.
Y Seen non conformity dated 220806, which was
communicated towards the appropriate
personnel. Seen corrective action.
Internal Audits
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2007-2228-BRC/IoP
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4.9.4 AB The management team shall review a summary of
audits and ensure corrective action has been taken.
Y Internal audit results are part of the management
review.
4.10
4.10.0 Monitoring, reviewing and taking action on complaints
shall be carried out as an essential part of an effective
quality system to prevent re-occurrence.
Y During the audit Euro Pool System could show
that she does have a system for the control of
complaints.
4.10.1 AB All complaints from external sources shall be recorded,
investigated and the results of the investigation
recorded. The management team shall review an
analysis of complaints to identify trends and the
corrective action required.
Y Seen overview 2nd half of 2006. Seen results of
investigation and corrective action on complaint
dated 121006. Seen corrective action 1107016.
4.10.2 AB Corrective actions shall be formulated and approved by
the designated manager who shall ensure that such
action is fully implemented and is effective in preventing
a recurrence
Y Above mentioned corrective actions are approved
by authorised personnel.
4.11
4.11.0 The company shall operate procedures for approval and
monitoring of its suppliers. This shall include transport,
warehousing and suppliers of materials and services to
the company where appropriate to this Standard.
Y Euro Pool systems does have a purchase
procedure which described the purchase of
products and services. PRO 338.
Complaint Procedure
Supplier Monitoring
4.11.1 AB The company shall evaluate and select suppliers based
on their ability to supply products in accordance with the
company's requirements. Criteria for selection,
evaluation and re-evaluation shall be established.
Records of the results of evaluation and any necessary
actions from the evaluation shall be maintained.
Y Above mentioned procedure mentions criteria for
selection, evaluation an re-evaluation. During the
audit supplier evaluations were demonstrated .
4.11.2 AB As part of hazard assessment, and where appropriate,
suppliers of materials shall be certified to this Standard.
Where this Standard is not implemented, the company
shall be responsible for ensuring their suppliers are
undertaking adequate technical practices which are
maintained, audited and documented.
Y Euro Pool systems does not ask for BRCIoP
standards for suppliers. Therefore suppliers are
monitored (score card) in order to verify adequate
technical practices.
4.12
4.12.0 Procedures shall be in place for the effective control of
sub-contractors.
Y Seen PRO 311 selecting suppliers of depot and
washing services RF 2.1.003.
4.12.1 AB Where any production processes are subcontracted,
the risks to the product from this process shall form part
of the hazard analysis. On the basis of the hazard
analysis it may be a requirement for the sub-contractor
to be certificated under this Standard.
Y Seen actual overview of depots. Euro Pool
System system uses a checklist to evaluate
depots RF 2.1.019. HACCP / Hygiene is a part of
this checklist.
4.12.2 AB Assessment of sub-contractors shall be undertaken by
a competent person who shall ensure technical
standards are appropriate, effectively audited and
documented.
Y Every quarter depots are verified by the sales
manager based on the depot checklist RF
2.1.019. Seen checklist depot "Valencia". Seen
corrective action 1910063.
Sub-contracting of Production
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2007-2228-BRC/IoP
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4.13
4.13.0 The company shall undertake or subcontract analyses
critical to product safety, legality and quality, using
appropriate procedures and facilities
Y Seen microbiological evaluations Analysis are
outsourced. Seen evaluations of the
effectiveness of cleaning of crates. Visual control
of 10 crates / day. Reference are available (DIN
standards).
4.13.1 AB Procedures shall be in place to ensure reliability of test
results.
NA Euro Pool System does not carry out themselves
specific tests.
4.13.2 AB Personnel undertaking analyses shall be suitably
qualified and/or trained and shall be competent to carry
out the analyses required.
NA Euro Pool System does not carry out specific
tests themselves .
4.13.3 AB Where the company undertakes or subcontracts
analyses critical to product safety or legal compositional
verification to a laboratory, the laboratory shall use
agreed and documented test methods and sampling
procedures.
Y The Analyses carried out at the external
laboratory are accredited.
4.13.4 AB Subcontracted laboratories shall be independently
accredited by a recognised or agreed competent body.
Y The external laboratory is accredited by an
agreed competent body.
4.13.5 AB Quality checks shall be carried out to demonstrate that
the product is within the tolerances laid down in the
agreed product specification.
Y During the process appropriate quality controls
are carried out in order to control products are
conforming specification. Seen control of
conductivity and control of temperature wash
Product Analysis
water.
5
5.1
5.1.0 All grounds within the site shall be finished and
maintained to an appropriate standard.
Y The grounds are well maintained and finished.
5.1.1 AB The external areas shall be kept in good order and free
from litter.
Y The grounds are well maintained and free of litter.
5.1.2 AB Where possible, a clean and unobstructed area shall be
provided along the external walls of buildings used for
production and/or storage.
Y A clean and unobstructed area is provided with
the exception of a part where some plants are
located. It is demonstrated by Euro Pool System
that the " City" does not allow the removal
5.1.3 B Where eating of food is allowed outside during breaks,
this shall be done in suitable designated areas with
appropriate control of waste.
NA personnel is not allowed to eat outside.
5.1.4 AB External silos, pipe work or other access points for
product and/or raw materials shall be appropriately
sealed so as to prevent pest entry.
Y During the audit no non conformities are
established regarding external silo's, pipe work
etc.
5.1.5 AB Drains shall be properly trapped or otherwise protected
so as to prevent entry of pests.
Y During the audit no deviations are spotted
regarding drains.
5.1.6 AB Where natural drainage is inadequate, external
drainage shall be installed.
Y During the audit no non conformities are seen
regarding natural drainage.
5.1.7 B External traffic routes shall be suitably surfaced. Y External traffic routes are surfaced.
5.1.8 AB Where external storage of raw materials is necessary
items shall be protected from contamination.
NA There is no external storage.
5.1.9 AB External storage of refuse shall be undertaken in
designated areas.
NA There is no external storage.
Perimeter and Grounds
FACTORY STANDARDS
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5.2
5.2.0 Premises and plant shall be designed, constructed and
maintained so as to control the risk of product
contamination.
Y Premises and plant are such constructed to
prevent the risk of contamination.
5.2.1 AB The process flow shall be such as to prevent cross-
contamination of the product.
Y The process flow is able to prevent cross
contamination. Dirty crates are completely
separated from the clean crates area.
5.2.2 B Work in progress shall be kept in designated areas and
adequately protected.
Y There are clear working procedures to prevent
contamination.
5.2.3 B Sorting or other activities involving the direct handling of
product shall take place in areas that have the same
standards as production areas.
Y Sorting activities takes place in area's who are
conform the hygiene standard.
5.2.4 AB Entry into production areas shall be via properly
designated entry routes and access points.
Y There is no "free access" to the production areas.
5.3
5.3.0 The fabric of the site, buildings and facilities shall be
suitable for the intended purpose.
Y Premises and plant are such constructed to
prevent the risk of contamination.
5.3.1 AB External walls shall be well maintained and of sound
construction.
N External door at the back of the factory is broken.
Door blocked with means of pallets (but this is not
100 % closed). Extra pest control measures
implemented. Other door at the back was slightly
damaged (small opening under the door which
could allowmouse to enter the building)
Building Fabric
Layout and Product Flow
could allow mouse to enter the building).
5.3.2 AB Suspended ceilings shall be accessible for inspection
and cleaning where required.
Y There was sufficient access to suspended
ceilings.
5.3.3 AB Suitable and sufficient lighting shall be provided so as
to permit effective inspection of product and effective
cleaning.
Y The lighting was sufficient.
5.3.4 AB Walls, floors, ceilings and pipe work shall be maintained
in good condition and shall be capable of being kept
clean.
Y Walls, floors, ceilings and pipe work are
constructed and in good order and are kept clean.
5.3.5 B Walls in production areas shall be suitably finished so
as to permit thorough and effective cleaning.
Y Walls in production areas are constructed and
maintained in such a way that effective cleaning
can be carried out.
5.3.6 AB All internal drain openings shall be suitably trapped or
otherwise protected against the entry of pests and
odour.
Y During the audit no non conformities regarding
internal drains are noticed.
5.3.7 AB Suitable and sufficient ventilation shall be provided. Y During the audit no exceeding condensation or
dust forming was noticed.
5.4
5.4.0 Equipment shall be suitably designed and maintained
for the intended purpose and shall be used so as to
minimise the risk of contamination of the product.
Y The equipments are fit for the intended purpose.
5.4.1 AB Equipment, including fixtures and fittings, shall be
maintained in such condition as to minimise the risk of
product contamination.
Y During the audit no non conformities where
noticed.
5.4.2 AB Wooden desks, chairs, tables and other items shall be
kept clean, in good condition and free from splinters or
other sources of physical contamination.
Y During the audit no non conformities where
noticed.
Maintenance of Equipment
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2007-2228-BRC/IoP
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5.4.3 B Wooden equipment including desks, chairs, tables, etc.
shall be properly sealed so as to enable them to be
effectively cleaned.
Y During the audit no wooden equipment without
"sealing" noticed.
5.4.4 AB Where open notice boards are present, loose
fastenings such as drawing pins and staples shall not
be used.
Y During the audit no non conformities where
noticed.
5.4.5 B A planned preventative maintenance programme for
plant and machinery shall be in place and shall address
the risks of contamination.
Compressed air that comes into contact with the
product should be filtered to prevent any contamination.
N At the grease points "kantelbakken" no food
grade lubricants are being used, although a risk
of product contamination does exist at this point.
5.4.6 AB Temporary 'engineering and modifications' using
adhesive tape, cardboard or similar materials shall not
be permitted, except in emergencies.
Y During the audit no non conformities where
noticed.
5.4.7 AB When temporary 'modifications' are made these shall
not become permanent and shall be properly monitored
and controlled.
Y During the audit no temporary modifications were
noticed.
5.4.8 AB Persons undertaking maintenance activities shall
comply with site hygiene requirements, including those
relating to protective clothing, hand washing and
personal hygiene generally.
Y During the audit the technical employee new the
hygiene requirements.
5 4 9 AB Contractors involved in maintenance or repair activities Y External technical personnel is under supervision 5.4.9 AB Contractors involved in maintenance or repair activities
shall be under the supervision of a nominated person.
Y External technical personnel is under supervision
of the internal technical personnel.
5.4.10 AB On completion of any maintenance work, machinery
and equipment shall be clean and free from
contamination hazards.
Y During the audit no non conformities were noticed
regarding cleaning of equipment after
maintenance.
5.4.11 B Maintenance work shall be followed by a documented
hygiene clearance procedure, which records that
contamination hazards have been removed from
machinery and equipment and/or controlled where there
is a risk to contamination to the product.
Y Euro Pool System does have implemented a
clearance procedure. Seen clearance registration
dated 081106.
5.4.12 AB Where appropriate, lights shall be protected from
breakage to minimise the risk of glass contamination.
Y Euro Pool System does have covered lights with
plastic covers.
5.4.13 B All lights shall be fully enclosed with protective covering.
Fluorescent tubes shall be protected by protective
covering or shatter-proof coatings
Y Euro Pool System does have covered lights with
plastic covers.
5.5
5.5.0 Housekeeping and Cleaning systems shall be in place,
which ensure that appropriate standards of hygiene are
maintained and that risks of contamination are
minimised.
Y Euro Pool Systems does have procedures and
equipment operation for cleaning activities.
5.5.1 AB Good standards of housekeeping shall be maintained
and include a "clean as you go" policy.
Y During the audit no non conformities where
noticed.
5.5.2 AB All internal surfaces of the buildings shall be kept free
from excessive dust, dirt and cobwebs.
Y During the audit no non conformities where
noticed.
5.5.3 AB All internal surfaces of buildings shall be subject to
documented scheduled cleaning.
Y There is a documented cleaning schedule for all
departments. This includes internal surfaces.
Housekeeping and Cleaning
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2007-2228-BRC/IoP
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5.5.4 AB Cleaning shall be undertaken in accordance with
documented cleaning schedules, which covers all areas
of the site with particular reference to production and
storage areas.
Y There is a documented cleaning schedule for all
departments.
5.5.5 AB Effective cleaning schedules shall be provided for all
equipment.
Y There is a documented cleaning schedule for all
equipment
5.5.6 AB Tools and other maintenance equipment shall be
cleared away after use and stored in designated areas
or lockers.
Y The used detergents are stored in a separate
closed area.
5.5.7 AB Workstations shall be kept in good order and potential
physical contamination hazards are properly controlled.
Y During the audit workstations where well
maintained.
5.5.8 B Workstations shall be provided with suitable storage for
stationery and loose items such as pens etc. Items
such as paper clips, staples etc shall not to be used.
Y On workstations storage facility were available for
loose items.
5.5.9 AB Records shall be kept to ensure the cleaning operations
are carried out in accordance with the cleaning
schedules.
Y Cleaning records were evaluated during the audit.
Seen cleaning registration; per department the
amount of hours is recorded which shows a
significant amount of hours spend on cleaning. In
practice the hygiene standard of the plant is very
high.
5 5 10 AB Cleaning chemicals shall be fit for purpose suitably N Close to the palletiser a white plastic bottle 5.5.10 AB Cleaning chemicals shall be fit for purpose, suitably
labelled, secured in closed containers and used in
accordance with manufacturers' instructions.
N Close to the palletiser a white plastic bottle
without label detected. In the first floor in the
"storage area" a orange extract stored for the
removal of labels. In the "dirty crate area" a red
box with brush detected. the content of this box is
not clear.
5.5.11 AB Materials and equipment used for cleaning toilets shall
be segregated from those used elsewhere.
Y Materials for the cleaning of toilets is stored
separately.
5.6
5.6.0 Suitable facilities shall be provided for the storage and
disposal of process and other waste.
Y Euro Pool System does have an operational
system for the control of waste.
5.6.1 AB Suitable and sufficient refuse and waste containers
shall be provided and thet shall be emptied at
appropriate frequencies and maintained in an
adequately clean condition.
Y Waste was sufficiently controlled.
5.6.2 AB Where agreed with the customer, suitable and sufficient
containers shall be provided for collection of
substandard trademarked materials. Where agreed
such materials shall be rendered unusable through a
destructive process. All materials disposed of shall be
recorded.
NA Euro Pool Systems does not have trademarks on
their crates.
5.6.3 AB If substandard trademarked materials are transferred to
a third party, that third party shall be in the business of
appropriate waste disposal and shall be provide records
of material destruction.
NA Euro Pool Systems does not have trademarks on
their crates.
5.6.4 AB Where appropriate, the third-party waste disposal
contractor shall be licensed
Y Waste removal is carried out by an licensed
contractor.
Waste and Waste Disposal
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2007-2228-BRC/IoP
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6.1
6.1.0 All practicable steps shall be taken to identify, avoid,
eliminate or minimise the risk of foreign-body
contamination.
Y There's a procedure implemented to prevent
product contamination.
6.1.1 AB Training shall be given to all relevant staff in the
avoidance and detection of foreign bodies.
Y During the audit Euro Pool System showed that
relevant training has been given.
6.1.2 AB A written policy and documented controls shall be in
place for:
- non-production glass
- brittle plastics
- all materials used in the construction, fixture and
fittings of the production area which could be confused
with packaging materials
Y A glass procedure was available which included
inspection of glass, hard plastic and materials
that could be confused with packaging materials.
6.1.3 AB There shall be no unnecessary glass or brittle plastic
which may pose a risk of contamination.
Y During the audit no unnecessary glass hard
plastic has been observed.
6.1.4 B All non-production glass or brittle plastics shall be
controlled and logged. All necessary non-production
glass and brittle plastics are recorded on a register and
checked for damage at an appropriate frequency. The
register shall be kept up to date as necessary.
Y Seen instruction glass and registration of glass
inspections No non conformities observed during
the audit.
Foreign Body Control.
CONTAMINATION CONTROL
6.1.5 B Where damage occurs that poses a risk of
contamination, a responsible person shall be placed in
charge of the clean-up operation and ensures that no
other area is allowed to become contaminated due the
breakage.
Y Euro Pool System has organised that after an
incident cleaning procedure are followed in order
to prevent further spread of contamination.
6.1.6 AB Any product that has become contaminated shall be
segregated and disposed of. A relevant quarantine
procedure applies after any incident.
Y A "on hold" procedure for contaminated product
could be shown.
6.1.7 AB All breakages that pose risk of product contamination
shall be recorded in an incident report.
Y Until now no incidents with glass have occurred.
6.1.8 AB There shall be a documented policy for the control of
the use of 'sharps'.
Y There is a procedure for the control of "sharps".
6.1.9 B All sharp cutting instruments shall be further controlled
as follows:
a) All sharp knives, blades, and instruments used in the
manufacture of packaging materials shall be suitably
controlled both into and out of the factory for use and
disposed of in a sealed container when no longer
usable.
b) No sharp object or loose tools shall be left on
machinery or equipment.
Y All sharp cutting instruments are being effective
controlled to prevent contamination.
6.1.10 AB Snap-off blade knives shall not be used. Y Snap-off blade knives are not used.
6.2
6.2.0 Controls shall be in place to prevent contamination from
any chemical or biological hazard.
Y There's a procedure implemented to prevent
product contamination.
6.2.1 AB Chemicals including cleaning materials, lubricants and
adhesives shall be so controlled as to prevent their
contamination of the product.
Y The facilities for the storage of chemicals are
adequate.
Chemical and Biological Control
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2007-2228-BRC/IoP
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6.2.2 B Where aseptic controls are required, then a complete
range of environmental controls (identified through
hazard analysis) may be necessary to prevent
microbiological contamination.
NA Aseptic controls are not required.
6.3
6.3.0 Controls shall be in place to prevent actual or potential
infestation and the resulting contamination from
rodents, flying and crawling insects, birds and other
pests.
Y Euro Pool System does have an operational
system for the control of pests.
6.3.1 AB A formalised preventive pest control programme shall
be maintained at manufacturing and storage facilities.
Y The pest control program does in include all
production and storage areas.
6.3.2 AB Effective precautions shall be in place to prevent pests
entering the premises.
Y During the audit no non conformities where
noticed.
6.3.3 AB Unless competent in-house expertise exists, a
competent pest control company shall be contracted to
carry out pest control systems. Written procedures and
activity documentation shall be maintained.
Y A contract with a specialised pest control
company could be shown.
6.3.4 AB Controls shall be documented on baiting points and
flying insect control devices. Flying insect control shall
not be positioned in areas where electrocuted insects
Y A detailed report of the pest control inspection
could be shown. Last inspection conducted
J anuary 2007.
Pest Control
p
can contaminate packaging materials.
y
6.3.5 AB In the event of infestation, immediate action shall be
taken in accordance with the procedures to eliminate
the hazard and the need for 'quarantine and qualify'
actions should be considered.
Y During the audit Euro Pool Systems showed that
corrective actions were taken. Seen corrective
actions regarding mouse activity in one corner of
the factory.
6.3.6 AB The building shall be suitably proofed against the entry
of all pests including the ducts and cable entry points.
Y During the audit no non conformities where
noticed.
6.4
6.4.0 The transport, storage and distribution of raw materials
and finished products shall be undertaken in such a
way as to minimise the risk of contamination.
Y Euro Pool System does have an operational
system to prevent contamination during transport,
storage and distribution.
6.4.1 AB All finished products shall be protected from
contamination during transit and storage by appropriate
external packaging.
Y During the audit no non conformities where
noticed.
6.4.2 B Materials transferred between premises during
production shall be similarly protected.
NA There are no materials transferred between
premises.
6.4.3 B All pallets should be checked and unacceptable pallets
discarded. Wooden pallets, which come into direct
contact with finished products or raw materials shall not
be allowed to contaminate the product.
Y Euro Pool System does have procedures for the
selection of unacceptable pallets. This is done
automatically. Broken pallets are taken out of the
system electronically / automatically.
6.4.4 AB Contracted transport, storage and distribution shall be
undertaken in such a way as to prevent raw materials or
product being exposed to the risk of contamination,
including taint or odour.
Y A procedure for the control of contracted
transport, was operational.
Transport, Storage and Distribution
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2007-2228-BRC/IoP
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6.4.5 B Contracted transport, storage and distribution shall
comply with written standards/specifications, which
ensure that product is not exposed to any risk of
contamination, including taint or odour.
Y Seen signed contracts 171006.
6.4.6 AB Vehicle drivers shall comply with site rules. Y A random check during the audit showed no non
conformities.
6.4.7 AB All vehicles used for deliveries ashall be kept clean and
in such a condition as to minimise the risk of product
contamination.
Y The inspected vehicles were fit for use.
6.4.8 B All company-owned vehicles used for deliveries shall be
included in the documented cleaning schedules.
NA Euro Pool System does not have company-
owned vehicles.
6.4.9 All delivery vehicles shall be subject to a hygiene
checking procedure before being loaded.
Y A random check during the audit showed no non
conformities.
6.4.10 AB Storage including off-site storage shall be controlled to
ensure no cross contamination from any other material
can occur. Where off-site storage is used the same
requirements apply as for on-site storage.
NA Euro Pool System does not have off-site storage
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7.1
7.1.0 The company shall ensure that access and movement Y Euro Pool Systemdid implement procedures to
Access and Movement of Personnel
PERSONNEL (Raw material handling, processing, preparation,
7.1.0 The company shall ensure that access and movement
of personnel, visitors and contractors shall not
compromise standards or product safety and ensure
compliance to the requirements of this section.
Y Euro Pool System did implement procedures to
prevent contamination by personnel, visitors and
contractors.
7.1.1 AB All personnel shall enter any part of the site through
designated entrances.
Y The personnel enters the site and building via
designated entrances.
7.1.2 AB Security shall be so maintained as to prevent the entry
of unauthorised persons to the premises.
Y There is no free entrance to site and buildings
7.1.3 AB If it is necessary to allow access between non-
production areas, personnel shall use designated
walkways provided there is adequate segregation from
materials.
NA There is only one building.
7.1.4 All facilities shall be designed and positioned so that
movement of personnel is by simple, logical routes.
Y The lay out of the building / process is to prevent
contamination.
7.1.5 AB Contractors and visitors shall be made aware of all
hygiene procedures for the premises and made
especially aware of the requirements of the areas they
are visiting.
N External contractors do not sign in at the entrance
and therefore do not receive the correct version
of the hygiene rules.
7.2
7.2.0 Staff facilities shall be designed and operated so as to
minimise the risk of product contamination.
Y Euro Pool System does have designed staff
facilities in such a matter as to prevent the risk of
product contamination.
7.2.1 AB Lockers shall be provided for all personnel who work in
raw-material handling, processing, preparation, packing
and storage areas.
Y Suitable locker rooms are available.
7.2.2 B Locker rooms shall be accessed without the need to
enter production areas unless appropriately segregated
walkways are in place.
Y Locker rooms gives direct access to the
production areas.
Locker Rooms
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Auditor: J . Quirijnen
2007-2228-BRC/IoP
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7.2.3 AB Eating, drinking and smoking shall not be allowed in
locker rooms.
Y Eating, smoking and drinking in locker rooms is
not allowed.
7.2.4 AB Facilities for visitors and contractors shall be such as to
enable compliance with the company's hygiene policy.
Y The facilities for visitors and contractors are
adequate.
7.2.5 B Company-issued protective clothing and personal
clothing shall not be stored in the same locker or locker
compartment.
Y Company clothing and personnel clothing are
segregated sufficiently.
7.3
7.3.0 Toilets and Hand washing facilities shall be adequate
and be maintained in a clean and hygienic condition.
Y The toilet at the entrance was in the beginning of
the morning very dirty. Re-checked at 12:00 h.
The toilet was cleaned and complied with the
demands.
7.3.1 AB Toilets shall be provided with hand-washing facilities
comprising basins with water available at a suitable
temperature.
Y Euro Pool System has provided for adequate
hand washing facilities.
7.3.2 AB Advisory signs shall be in place to prompt hand
washing. Adequate facilities for hand drying shall be
provided.
Y Advisory signs are in place at the hand washing
facilities.
7.3.3 AB All personnel, visitors and contractors shall wash their
hands prior to entering production areas, after using the
toilet, eating, smoking, drinking (unless drinking only
water in accordance with the conditions set out in
Y A random check during the audit showed no non
conformities.
Toilets and Hand-washing Facilities
water in accordance with the conditions set out in
section 7.4) and whenever otherwise necessary.
7.3.4 B Hand washing shall be carried out by all personnel
when entering a production area.
NA Hand washing when entering the production area
is not necessary. This is based on a risk
assessment.
7.3.5 B Hand-washing facilities shall be provided at the
entrance to production areas, outside localised eating
and drinking facilities, and elsewhere so that employees
have ready access during the course of their work.
Y Euro Pool System has provided for an adequate
hand wash facility at the entrance of the
production area (at the toilets and the locker
rooms).
7.4
7.4.0 Rest and break facilities shall be of a suitable standard
to promote good hygiene practices.
Y During the audit the Rest and break facilities were
under control.
7.4.1 AB All equipment and surfaces shall be clean, well
maintained and of suitable construction.
Eating (including the eating of confectionery and
chewing of gum or tobacco), drinking, and smoking
shall not be allowed in the production or packing areas.
If it is impractical for personnel to leave their work area,
local controlled facilities (such as a fully walled area
with hand-washing facilities if appropriate) shall be
provided.
Y A random check during the audit showed no non
conformities.
7.4.2 B Employers shall be provide facilities for adequate
storage of food and drink, including that brought from
home. Drinking of water from purpose-made dispensers
and/or by using only disposable conical cups may be
allowed provided it is confined to a designated area
away from equipment.
Y A random check during the audit showed no non
conformities.
Facilities for Eating, Drinking and the Use of Tobacco Products
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2007-2228-BRC/IoP
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7.4.3 AB Designated, enclosed and controlled smoking areas
shall be isolated from production areas to an extent that
ensures smoke cannot reach the product.
Sufficient extraction to the exterior of the building shall
be ensured. Adequate arrangements for dealing with
smokers' waste shall also be provided at smoking
facilities, both inside buildings and at exterior locations.
Facilities shall be available, with adequate reminders,
for hand washing after smoking.
Y Smoking is organised in the general hygiene
rules. Were smoking is prohibited, extraction to
the exterior is available.
7.4.4 AB Canteen and food waste shall be stored in suitably lined
and lidded containers.
Y A random check during the audit showed no non
conformities.
7.4.5 AB All food brought into manufacturing premises shall be
held in a controlled area which is kept in a clean and
hygienic state.
Y There are adequate storage faculties for food for
the personnel.
7.5
7.5.0 Illnesses or injuries likely to adversely affect product
safety shall be monitored and controlled.
Y Euro Pool System has procedures to prevent
product contamination by illness of injuries.
7.5.1 AB Personnel shall report if they are suffering from, or have
been in contact with any disease likely to be transmitted
through food, from infected wounds, skin complaints or
diarrhoea Employees and visitors suffering fromany of
Y The hygiene rules include mentioning of
diseases.
Personal Health
diarrhoea. Employees and visitors suffering from any of
the above shall be excluded from work involving contact
with food packaging as long as the symptoms persist.
7.5.2 B Visitors and contractors shall be required to fill in a
health questionnaire prior to being allowed into
production areas covered within the Standard.
Y During the audit the auditor was asked to fill in a
health questionnaire.
7.5.3 AB Minor injuries such as cuts shall be covered with
waterproof blue self-adhesive plasters incorporating a
metal detectable strip.
Y Euro Pool Systems gives detectable blue
plasters. They are stored at the office of the
manager of the depot.
7.6
7.6.0 The company shall have in place an effective policy for
the control of jewellery and personal items.
Y There is a policy regarding jewellery. Seen
"hygiene rules Zellik" 2.2.023iw.
7.6.1 AB J ewellery and wristwatches shall not be worn, unless for
ethnic, medical or religious reasons in which case these
are one piece or appropriately controlled to minimise
the risk of contamination.
Badges, pendants, brooches, jewellery with stones or
gems, or jewellery and other adornments liable to
breakage or contamination shall not be worn.
Y During the audit no non conformities were
noticed.
7.6.2 B Wristwatches shall not be worn. Y During the audit no non conformities were
noticed.
7.6.3 AB Company policy shall clearly specify the type of
jewellery allowed to be worn and the controls to be in
place to minimise the risk of contamination.
Y Company hygiene rules does specify the type of
jewellery allowed.
7.6.4 AB Rings and studs in exposed parts of the body such as
noses and eyebrows shall not be worn.
Y Rings and studs are not allowed.
Jewellery and Personal Items
Issue 2
Auditor: J . Quirijnen
2007-2228-BRC/IoP
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7.6.5 AB Procedures shall be in place to control the use of
personal medicines to minimise the risk of
contamination.
Y The use of medicines is organised in the
company hygiene rules.
7.6.6 B False nails and nail varnish shall not be used. Y False nails and nail varnish is not allowed.
7.7
7.7.0 Appropriate protective clothing shall be worn to
minimise the risk of product contamination.
Y During the audit protective clothing was worn by
personnel and contractors.
7.7.1 AB Appropriate protective clothing that cannot contaminate
the product shall be worn.
Y During the audit no non conformities were
noticed regarding clothing.
7.7.2 B The clothing shall have no external pockets on the
upper body garments, and be fitted with press-studs,
not sewn-on buttons. Changes of such clothing shall be
available at all times as required. Where appropriate,
snoods for beards and moustaches shall be worn.
Protective clothing worn in production areas shall
provide adequate covering of scalp hair and upper
torso. These garments shall not be worn to and from
home.
Y During the audit no non conformities were
noticed regarding clothing.
7.7.3 AB Self-care shall be permitted provided adequate controls
and appropriate guidelines are in place.
Y Euro Pool System did establish rules regarding
self care.
7.7.4 B Controlled laundering of clothing shall be carried out. A
system shall be in place to ensure the effectiveness of
l d i
NA Based on risk assessment Euro Pool System
concluded that controlled laundering is not
f th t f d t Aft i i /
Protective Clothing
laundering process. necessary for the type of products. After rinsing /
cleaning of crates personnel does not touch the
crates anymore (fully automated process).
7.7.5 AB Clean and dirty clothing shall be segregated and
controlled to prevent cross contamination.
Y Clean and dirty clothing is segregated.
7.8
7.8.0 The company shall ensure that all employees are
adequately trained, instructed and supervised
commensurate with their activity.
Y Euro Pool System could demonstrate that
personnel is trained, instructed adequately.
7.8.1 AB All personnel including temporary personnel and
contractors shall be appropriately trained prior to
commencing work and adequately supervised
throughout the working period. Induction training shall
include the company hygiene rules.
Y During the audit no non conformities regarding
training / instruction of temporary personnel and
contractors was noticed.
7.8.2 B All personnel shall be provided with formal basic
hygiene training commensurate with their activity, and
where appropriate further in-depth training shall take
place.
Y A random check during the audit showed that all
operators did received a basic hygiene instruction
in J anuary 2007.
7.8.3 AB Records of training shall be kept for all current and
recent employees.
Y Records of training are available. Seen training
records of basic hygiene training and personnel
safety training of J anuary 2007.
7.8.4 AB A programme of refresher hygiene training shall be in
place.
Y There was a programme of refresher hygiene
training in place.
Training Raw-materials Handling, Preparation, Processing, Packing and Storage
Issue 2
Auditor: J . Quirijnen
2007-2228-BRC/IoP
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