13 replies to this topic

[SaltSafety]

Can anyone advise me on risk assessments for BRC?
We are a food grade salt facility and therefore have very few processes and ingredients. When following a typical risk assessment matrix, the likelihood of anything having much affect on final product is very small, resulting in risk scores in the low and moderate catagories.
For instance, when risk assessing hairnet usage, there are very few areas of open product where a hair could contaminate finished product. And, the actual food safety consequence for a hair in a bag of salt is minor; nearly insignificant. Therefore, the risk would be considered low.
On the other hand, I think you would be hard pressed to find any food facility, or a BRC auditor, that would consider it ok to be without hairnets in areas of open product.

[Foodworker]

With respect to this particular point about scalp hair (7.5.6), full covering with a hair net or similar is mandatory for the BRC, you do not have the option of not wearing them.

In various clauses, the Standard uses the phrase "based on risk assessment" or similar wording. It is only in these cases that you can apply the principles of liklihood and severity to determine whether you need to do something.

By way of example, the next clause 7.5.7 says "Based on risk assement, snoods for beards and moustaches shall be worn...". In this case if you can demonstrate that the likelihood of beard hair contamination is low and that the consequences of contamination are not severe, then you don't need to wear them.

You do of course need to document your justifications.

It is useful to go through the Standard and highlight those clauses where it gives you the option of a risk assessment and ensure that you have a documented justification if you do not do what the clause requires. The auditor will expect to see these justifications and that they are kept under review.

[Simon]

Packaging manufacturers need to wear hairnets under BRC, even bald ones. So I think a salt facility would need to. Hair is not a significant food safety hazard, but quality issue / customer being repulsed...certainly.

[Charles.C]

Dear All,

In basic hygiene situations, I would hv thought that a xreference to a "recognised" GMP text ought to be a sufficient (proven) risk assessment. Why re-invent the wheel ?

Rgds / Charles.C

[Madam A. D-tor]

Dear All,

In basic hygiene situations, I would hv thought that a xreference to a "recognised" GMP text ought to be a sufficient (proven) risk assessment. Why re-invent the wheel ?

Rgds / Charles.C

Hello Charles,

You do not have to re-invent the wheel. You only need to make demonstrable that you know that there is a wheel and that the wheel is applicable to your situation. Justification is only needed when things are not conform these general GMP standards.
And not always documented justifcation is needed. E.g. 4.2.4: Based on risk assessment, procedures shall be in place to ensure the secure storage of all materials ....... As an auditor, I do not need to see a documented risk assessment on this issue. I can see the procedures on site and can understand the risks that are involved. If contamination hazards are not covered by a procedure I will ask to the risk assessment and if relevant raise a CAR.

BTW only for the following GMP based items a justification based on risk assessment is allowed: documentation of jewellry policy, hand cleaning frequency, laundering (if not by approved contracted laundry) and snoods for beards/moustaches. All the other GMPs are required just as these are and no justification or risk assessment is needed.

[Foodworker]

That was a good clear explanation Madam A.D-Tor.

The BRC Standard uses the phrase about risk assessment far too many times in circumstances where common sense should apply, and as I am sure you know, it is even worse in their other standards.

Your example about the secure storage is a good one. No company in their right mind would deliberately store materials in an unsecure way. If they are unsecure a CAR should be raised regardless of a risk assessment, as the risk assessment in this case would be inherently flawed if it concluded that unsafe storage is acceptable.

[SaltSafety]

I guess my question is, while BRC has a requirement for hairnets, can a risk assessment show that they are only required in areas of "open" product or raw materials?

With respect to this particular point about scalp hair (7.5.6), full covering with a hair net or similar is mandatory for the BRC, you do not have the option of not wearing them.

In various clauses, the Standard uses the phrase "based on risk assessment" or similar wording. It is only in these cases that you can apply the principles of liklihood and severity to determine whether you need to do something.

By way of example, the next clause 7.5.7 says "Based on risk assement, snoods for beards and moustaches shall be worn...". In this case if you can demonstrate that the likelihood of beard hair contamination is low and that the consequences of contamination are not severe, then you don't need to wear them.

You do of course need to document your justifications.

It is useful to go through the Standard and highlight those clauses where it gives you the option of a risk assessment and ensure that you have a documented justification if you do not do what the clause requires. The auditor will expect to see these justifications and that they are kept under review.

[Madam A. D-tor]

And not always documented justifcation is needed. E.g. 4.2.4: Based on risk assessment, procedures shall be in place to ensure the secure storage of all materials ....... As an auditor, I do not need to see a documented risk assessment on this issue. I can see the procedures on site and can understand the risks that are involved. If contamination hazards are not covered by a procedure I will ask to the risk assessment and if relevant raise a CAR.

Unfortunately I have to come back on my own approach of risk assessment. today I have been told (in training) that all risk assessments should be demonstrable available and therefore documented.
Personly I do not agree with the BRC, but They make the rules, which I as an auditor has to confirm to.

I am sorry that I misled you all.

[GMO]

Unfortunately I have to come back on my own approach of risk assessment. today I have been told (in training) that all risk assessments should be demonstrable available and therefore documented.
Personly I do not agree with the BRC, but They make the rules, which I as an auditor has to confirm to.

I am sorry that I misled you all.

Interesting. In my last factory I decided to come up with a "risk assessment" document where every clause which stated this I had done a formal risk assessment, however, in my new factory I was thinking I'd gone too far, possibly being a bit anal again and would probably put something smaller into the FSQ Manual. Now I'm thinking perhaps BRC are as anally retentive as I am and so need to think "pedant, pedant, pedant" at every turn. Fortunately being a pedantic perfectionist comes easily...

[Charles.C]

Dear Madam A.D-tor / Foodworker,

I suspect the reason for some of the documentation requirements just mentioned is related to the claimed usability of a BRC certification for "due diligence" purposes. "Hearsay" is not a very effective defence according to my watching many TV dramas.

Not that I'm disagreeing with previous "risk assessment" comments. BRC have simply gone overboard with prescriptiveness. Blame it on GFSI is another possibility.

The highly condensed, tabulated approach suggested/illustrated by Baron in another thread is maybe a pragmatic counter-attack (328 dwls so far ).

( http://www.ifsqn.com...dpost__p__37537 )

Rgds / Charles.C

[D-D]

With respect to this particular point about scalp hair (7.5.6), full covering with a hair net or similar is mandatory for the BRC, you do not have the option of not wearing them.

Just wondering if you could elaborate a little please? We process essential oils and concentrated flavours, usually in closed systems and everything is filtered at point of packing into drums, jerrycans etc. We require operators to wear hair nets only in one specific area where flavours are dispersed on carriers such as salt for use in savoury snacks or soup seasonings etc as this is a more 'open' process. Everywhere else soft hats are worn. I would not say that they fully contain hair but as stated, closed processes. Do you think this is adequate? Thanks in advance.

[Madam A. D-tor]

I suspect the reason for some of the documentation requirements just mentioned is related to the claimed usability of a BRC certification for "due diligence"

You are probably right for 100%.
.

IThe highly condensed, tabulated approach suggested/illustrated by Baron in another thread is maybe a pragmatic counter-attack

I have understand that all documented justification is good (can be single line within a policy or a part of the HACCP-analyse), as long as the auditor approves it.

[Madam A. D-tor]

Just wondering if you could elaborate a little please? We process essential oils and concentrated flavours, usually in closed systems and everything is filtered at point of packing into drums, jerrycans etc. We require operators to wear hair nets only in one specific area where flavours are dispersed on carriers such as salt for use in savoury snacks or soup seasonings etc as this is a more 'open' process. Everywhere else soft hats are worn. I would not say that they fully contain hair but as stated, closed processes. Do you think this is adequate? Thanks in advance.

What foodwoker means is that BRC issue 5 does not accept risk assessment regarding hairnets. You just have to wear them, whether this is appropriate or not.
Compare the text of issue 4, where it was allowed to do risk assessment and not wearing hairnets, to the text of issue 5.

Issue 4: 6.4.4: All hair, where appropriate, is fully contained to prevent product contamination and hairnets or mobhats are single use.
Issue 5: 7.5.6: All scalp hair shall be fully contained to prevent product contamination.

There is no way to escape anymore.

[Madam A. D-tor]

BTW: I see that there is no requirement anymore to use disposables