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#26 Charles.C

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Posted 13 December 2016 - 10:20 AM

Hi Polin,

 

Time may have somewhat changed certain aspects. It's sometimes preferable to start from the most recent threads.

 

You mentioned auditor, any particular FS Standard ?


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#27 Polin

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Posted 13 December 2016 - 10:29 AM

Hi Polin,

 

Time may have somewhat changed certain aspects. It's sometimes preferable to start from the most recent threads.

 

You mentioned auditor, any particular FS Standard ?

 

Charles,

 

thank you very much for your prompt answer. 

 

We have ISO 9001, 22000 and BRC/IoP.

 

Thank you in advance

Polin 


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#28 Charles.C

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Posted 13 December 2016 - 10:52 AM

Charles,

 

thank you very much for your prompt answer. 

 

We have ISO 9001, 22000 and BRC/IoP.

 

Thank you in advance

Polin 

 

Thanks. I deduce you must have encountered/(audit) answered several of yr queries in Post 25 already.

 

I suggest yr queries may easier be responded to (if possible) in the context of BRC since less generic (and haccp-weird) than ISO22000.

 

(i note you have posted other related (presumably BRC-oriented) queries, eg -

 

http://www.ifsqn.com...nt/#entry107109

http://www.ifsqn.com...ng/#entry106740

 

Some of yr micro.queries basically relate to "Specifications" for Products vis-a-vis Hygiene. Do you have such specs, eg for TVC, coliform ?

 

Other queries clearly relate to GMP/HACCP, and particularly BRC's interpretation. As already discussed, generic opinions may well differ (rightly or wrongly :smile:)


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Charles.C


#29 Polin

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Posted 13 December 2016 - 11:19 AM

Thanks. I deduce you must have encountered/(audit) answered several of yr queries in Post 25 already.

 

I suggest yr queries may easier be responded to (if possible) in the context of BRC since less generic (and haccp-weird) than ISO22000.

 

(i note you have posted other related (presumably BRC-oriented) queries, eg -

 

http://www.ifsqn.com...nt/#entry107109

http://www.ifsqn.com...ng/#entry106740

 

Some of yr micro.queries basically relate to "Specifications" for Products vis-a-vis Hygiene. Do you have such specs, eg for TVC, coliform ?

 

Other queries clearly relate to GMP/HACCP, and particularly BRC's interpretation. As already discussed, generic opinions may well differ (rightly or wrongly :smile:)

 

Do you mean "focusing" on BRC requirements (as it is more exacting) ?

 

We have not specify to our product specification the maximum amount of TVC or coliforms. We have a general acknowledgment TVC, not over 10 cfu/cm2. 

 

Thank you in advance

Polin


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#30 Charles.C

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Posted 13 December 2016 - 11:34 AM

Do you mean "focusing" on BRC requirements (as it is more exacting) ?

 

BRC is relatively Prescriptive, ie offers more explicit requirements albeit usually not quantitative. Makes BRC discussion easier than ISO which specifies requirements in "general" terms..

 

We have not specify to our product specification the maximum amount of TVC or coliforms. We have a general acknowledgment TVC, not over 10 cfu/cm2. 

Some published specs. (paper/plastic) are available in older (ca, 2010-2012) thread. TVC, coliform,Y&M IIRC.

 

Thank you in advance

Polin

 

Hi Pollin,

 

See "red".


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Charles.C


#31 Charles.C

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Posted 13 December 2016 - 11:45 AM

addendum -

 

see this post and work back from the link included (and the sub-links in linked posts) -

 

http://www.ifsqn.com...ilm/#entry96422


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Charles.C


#32 Polin

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Posted 13 December 2016 - 01:49 PM

addendum -

 

see this post and work back from the link included (and the sub-links in linked posts) -

 

http://www.ifsqn.com...ilm/#entry96422

 

Thank you very much!! 

 

are very helpful and interesting.

 

Regarding our microbiological controls do you think that the external annually check of total plate count is ok or we should add the internal swabbing too?

 

Thank you in advance

 

Polin


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#33 Charles.C

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Posted 13 December 2016 - 03:09 PM

Thank you very much!! 

 

are very helpful and interesting.

 

Regarding our microbiological controls do you think that the external annually check of total plate count is ok or we should add the internal swabbing too?

 

Thank you in advance

 

Polin

 

Hi Polin,

 

My direct expertise is mainly with Food processing. Other posters here in Packaging should have better experience regarding yr audit queries.

 

Is yr finished product in direct contact with food, ie High Risk ?

The necessity for doing any micro.sampling of potential product contact surfaces has been discussed here before (for BRC i think) with, from memory, a variety of opinions ranging from zero to intensive and depending on LR/HR.

 

IMEX a sampling frequency of 1x per year is usually regarded as of dubious value unless you have historical data to verify the frequency (or other justifications).

The usual approach to Verification is to initially oversample, eg monthly frequency (in duplicate), for a certain period of time, eg 6 months. Then if data is fully compliant with specification, can reduce frequency somewhat (or vice-versa). Then repeat the exercise. This is a standard procedure, eg see the quote and last pdf file attached in this post -

http://www.ifsqn.com...ers/#entry87841

(the minimum frequency depends on the results and perhaps the BRC standard's text)


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Charles.C


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#34 Charles.C

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Posted 13 December 2016 - 10:59 PM

addendum -

 

Yr original Operational Query was –

We are converters of flexible food packaging films. To be more specific we print, laminate, slitting and bag making flexible packaging for foods.

Our operators wear working uniforms (tshirt, trouser, shoes) which they should remove upon completion of their shift. Also they have specific instruction for the cloth washing. 

what do you think about our procedure?

 

As already noted, LR/HR is (risk) relevant. I  suggest you analyse yr “Procedure” within the context of BRC Packaging Standard sec.6.5, eg does a t-shirt comply with clause 6.5.3 ?

IYO, does yr "Procedure" comply ? if not, why not ?

Compared to Food, IMO, BRC Packaging is (rightly or wrongly) significantly less demanding, eg the word “Appropriate”, omission of Validation of laundering process.

Regardless, one should presumably have some confidence in BRC’s competence/experience to devise a valid/effective/diligent, Safety-related Standard. Yes? So, if yr auditor was satisfied ...........  :mellow:


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Charles.C


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#35 Polin

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Posted 14 December 2016 - 07:43 AM

Charles,

 

thank you very much for your time and your quotes   :smile:

 

 

Polin

 

 

addendum -

 

Yr original Operational Query was –

 

As already noted, LR/HR is (risk) relevant. I  suggest you analyse yr “Procedure” within the context of BRC Packaging Standard sec.6.5, eg does a t-shirt comply with clause 6.5.3 ?

IYO, does yr "Procedure" comply ? if not, why not ?

Compared to Food, IMO, BRC Packaging is (rightly or wrongly) significantly less demanding, eg the word “Appropriate”, omission of Validation of laundering process.

Regardless, one should presumably have some confidence in BRC’s competence/experience to devise a valid/effective/diligent, Safety-related Standard. Yes? So, if yr auditor was satisfied ...........  :mellow:

 

 

Hi Polin,

 

My direct expertise is mainly with Food processing. Other posters here in Packaging should have better experience regarding yr audit queries.

 

Is yr finished product in direct contact with food, ie High Risk ?

The necessity for doing any micro.sampling of potential product contact surfaces has been discussed here before (for BRC i think) with, from memory, a variety of opinions ranging from zero to intensive and depending on LR/HR.

 

IMEX a sampling frequency of 1x per year is usually regarded as of dubious value unless you have historical data to verify the frequency (or other justifications).

The usual approach to Verification is to initially oversample, eg monthly frequency (in duplicate), for a certain period of time, eg 6 months. Then if data is fully compliant with specification, can reduce frequency somewhat (or vice-versa). Then repeat the exercise. This is a standard procedure, eg see the quote and last pdf file attached in this post -

http://www.ifsqn.com...ers/#entry87841

(the minimum frequency depends on the results and perhaps the BRC standard's text)


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