22 replies to this topic

[TGC]

Hi

 

I am working for a company who are aiming towards their first BRC audit.

 

The nature of the business is cheese blending.  They buy in block cheese from suppliers, shred it and blend into different mixes i.e. 30% cheddar, 70% mozzarella and pack it into MAP 2kg bags for retail to pizzerias/cash and carry outlets etc.  No cooking involved.  Chilled storage for raw materials and finished product.

 

Would this site/process be classed as low risk? 

 

Also within this scenario, would you recomend that production operatives wear dedicated footwear within the production area?  Or would the same footwear worn outdoors be acceptable?

 

Thanks for you opinions.

[Simon]

Don't know much about cheese.

 

I would expect dedicated footwear in a food packaging plant, so in a food plant, even if low risk would be a definite yes from me.  

 

Regards,

Simon

[TGC]

Thanks Simon

 

I've worked in lots of fresh produce companies, and a shell egg production facility, all low risk.  We didn't have dedicated production footwear in those sites and it never got mentioned in BRC so wondering if it would be any different with the cheese site if it is also classed as low risk?

 

I'll see what other forum users say

[Charles.C]

Dear TGC,

 

One obvious answer would be to ask yr intended auditing company. From my (non-cheese) experiences, i can assure you that such enterprises will be only too willing to give you an opinion. And several others of course.

 

I think yr basic query has appeared before on this forum. Might try a little (cheese) searching. For example, this one illustrates yr OP may need a little more definition, process-wise -

 

http://www.ifsqn.com...ing/#entry56730

 

Rgds / Charles.C

[scppvjune]

Hello TGC

Please see attached file. It is really helpful especially produciton zone decision tree. From your scenario, I think it should be categorized as low risk.

For the footwear, it is depended upon risk assessment. If you think it is not necessary to provide / require specific footwear for production areas, you need to record your reasons why it is not necessary and ensure that there is no risk to cause any problem to your products.

Regards,

Attached Files

•  F048 - Understanding High care and High risk 3 28 5 12 Final1.pdf   597.65KB   44 downloads

[cazyncymru]

I would say that you were a high care area (block cheese is being opened and shredded) and if you use the attachment from scppvjune you can follow what you need.

Don't forget, you need to justify why you are high care.

caz

Edited by cazyncymru, 11 October 2013 - 10:54 AM.

[scppvjune]

Hello again,

Caz might be right since you mentioned that your products required to be stored in chilled storage for both raw material and finished product. Well, TGC, just used the production zone decision tree...you know your own product better than us anyway.

If it is high care, I think you need dedicated footwear or shoe covering as BRC requirement # 4.8.4.

Regards,

[George @ Safefood 360°]

Based on the guidance, if the cheese is hard cheese e.g. low moisture content, Aw it might be possible to say it is Low Risk. If you are handling even one soft cheese in the operation, I think you are into the High Risk category and all that goes with that. I think it is straight forward if you refer to BRC's guidance.

 

George

[Charles.C]

Dear All,

 

Similarly to recent posts, It appears that this product has created substantial discussion as to the risk logic of  BRC's low/high criteria. Certainly interesting if you have a mixture of soft/hard cheeses although, as per previous posts,  presumably process overridden. Two older threads below, there are others - 

 

 http://www.ifsqn.com...out/#entry47762

 

http://www.ifsqn.com...ory/#entry57443

 

Rgds / Charles.C

[TGC]

Hi Everyone

 

Thanks for your replies.  I had a reply from the CB - from my explanation of the process it falls into Category 7.  They advised me to follow the decision tree in the manual which I have done and the outcome is low risk.  The cheese blends are purely for pizza toppings and will always be cooked by the consumer prior to consumption.  It is all hard cheese - mozarella and cheddar, no soft cheese.

 

So..the footwear issue will not fall into Clause 4.8.4.  I suppose we will do a risk assessment and make a decision about that.

 

Thanks for all your feedback.

[TGC]

Dear All,

 

Similarly to recent posts, It appears that this product has created substantial discussion as to the risk logic of  BRC's low/high criteria. Certainly interesting if you have a mixture of soft/hard cheeses although, as per previous posts,  presumably process overridden. Two older threads below, there are others - 

 

 http://www.ifsqn.com...out/#entry47762

 

http://www.ifsqn.com...ory/#entry57443

 

Rgds / Charles.C

Read these thanks Charles - yes I can understand that if the process involves manufacturing the cheese it would be high risk.  The company I'm working for are buying in hard cheese from manufacturersand it is literally shredded and re-packed.  So low risk.

[Charles.C]

Dear TGC,

 

A few comments.

 

As I understand, yr Low Risk decision is based on the BRC tree.

Accordingly, I deduce this is a result of  one of 2 possible sequences –

 

(1) YES > NO > hard cheese

Or

(2) YES > YES > YES

 

If (1), I assume you can validate both (a) that  your Mozzarella is atypically categorised as a hard cheese  within the context of the BRC tree  and  (b) yr “NO” answer regarding any "safety" necessity for chilled storage. If otherwise, the conclusion will presumably change, eg see Category7 of the attachment in post #5 / BRC tree respectively)

 

If (2), this conclusion is IMO more understandable vis-a-vis the BRC tree logic and the validation will presumably depend on the appropriateness / legality of the specific labeling. I recall a retail seafood mix labeled as suitable for pizza topping. Unfortunately there was no mention on the package that the product was raw / would require “full” cooking. Not a good consumer result.

 

Perhaps you could inform which of (1) and (2) you are selecting. Or ?

 

As suggested elsewhere, some manufacturers / customers will probably disagree on either/both of the above options.

 

Rgds / Charles.C

[Tony-C]

Hi Everyone

 

Thanks for your replies.  I had a reply from the CB - from my explanation of the process it falls into Category 7.  They advised me to follow the decision tree in the manual which I have done and the outcome is low risk.  The cheese blends are purely for pizza toppings and will always be cooked by the consumer prior to consumption.  It is all hard cheese - mozarella and cheddar, no soft cheese.

 

So..the footwear issue will not fall into Clause 4.8.4.  I suppose we will do a risk assessment and make a decision about that.

 

Thanks for all your feedback.

 

Hi TGC,

 

I would expect more from the CB in terms of help.

 

From BRC Guidance:

'It should be recognised that some products considered as low risk ... will require high standards of microbiological control, similar to a high care areas, because spoilage organisms present a significant risk e.g ....mould on hard cheese'

 

Regards,

 

Tony

[TGC]

Dear TGC,

 

A few comments.

 

As I understand, yr Low Risk decision is based on the BRC tree.

Accordingly, I deduce this is a result of  one of 2 possible sequences –

 

(1) YES > NO > hard cheese

Or

(2) YES > YES > YES

 

If (1), I assume you can validate both (a) that  your Mozzarella is atypically categorised as a hard cheese  within the context of the BRC tree  and  (b) yr “NO” answer regarding any "safety" necessity for chilled storage. If otherwise, the conclusion will presumably change, eg see Category7 of the attachment in post #5 / BRC tree respectively)

 

If (2), this conclusion is IMO more understandable vis-a-vis the BRC tree logic and the validation will presumably depend on the appropriateness / legality of the specific labeling. I recall a retail seafood mix labeled as suitable for pizza topping. Unfortunately there was no mention on the package that the product was raw / would require “full” cooking. Not a good consumer result.

 

Perhaps you could inform which of (1) and (2) you are selecting. Or ?

 

As suggested elsewhere, some manufacturers / customers will probably disagree on either/both of the above options.

 

Rgds / Charles.C

Hi Charles

 

It would be;

 

Step 1 YES

Step 2 YES

Step 3 YES – LOW RISK area – the cheese will always be cooked prior to consumption, it is not intended to be eaten without cooking because it it purely intended for pizza topping, not cold sandwiches etc.

 

Do you think I am right with this?

 

Thanks

[cazyncymru]

Are the pizzas frozen or chilled?

[Charles.C]

Dear TGC,

 

Do you think I am right with this?

 

No doubting that chilled foods can offer complicated risk assessments.

 

Can you inform the labelling / heating instruction on the retail^# / non-retail product to be followed by the consumer? The relevance is emphasised by the (tiny) star in the decision tree, step3 green box.

 

Also note the "footnote" under the tree -

 

This decision tree provides a guide only to the categorisation of production zones and cannot take account of specific product characteristics (e.g. pH, aw) or the vulnerability of particular products to pathogens or spoilage which may result in exceptions. A detailed risk assessment should be undertaken where necessary to support the decision. Reference shall be made to the more  detailed explanations of product zones in the guideline.

 

This may reflect Tony's earlier quote. And Caz's query. Apparently the standard is both Quality and safety oriented, at least in certain aspects.

 

Additionally note the  intro text's  emphasis on the importance of Listeria. This is presumably  more relevant for soft cheeses like Mozzarella.

 

Rgds / Charles.C

 

 

# added - as per the OP -

 

pack it into MAP 2kg bags for retail to pizzerias/cash and carry outlets etc

[TGC]

Are the pizzas frozen or chilled?

Hi Caz

 

The cheese is bought by pizza shops/restaurants for them to put onto their pizzas - made fresh and then cooked before serving to customers.

[Tony-C]

Dear TGC,

 

Can you inform the labelling / heating instruction on the retail product to be followed by the consumer?

 

Rgds / Charles.C

 

It may not necessary be retail but your point is valid, the labelling on the cheese and product specification to confirm intended use seem fundamental to the assessment.

 

Regards,

 

Tony

Edited by Tony-C, 15 October 2013 - 05:20 PM.

[Charles.C]

Dear TGC,

 

Would like to expand on my preceding post and hopefully suggest one answer to yr OP.

 

IMO, the BRC tree for Zone Status (ZS) may not be fully appropriate to apply to yr product which, to my understanding, is intrinsically RTE when packed. Reasoning follows -

 

There are 3 possibilities for ZS - (a) low risk, (b) high care, © high risk.

Type (c) is clearly not possible from tree or text.

Type (a) is textually introduced  as intended for a situation where –

 

The significance to human health of microbiological contamination is reduced because the product is unsuitable for the growth of pathogens or is designed to undergo a later validated kill step that ensures the product is safe to eat.

 

IMO the key word in second possibility is “designed”. I think yr finished product does not match either of the above criteria. Additionally, it does not match any of the 4 bulleted categories within “Low Risk”.(although, if all the product is validatable as hard cheese, it might). The only caveat to this conclusion is that the 4 categories shown are not claimed to cover all possible circumstances.

 

(added later) - just to illustrate the (L.mono.) significance of soft/hard cheese, can refer to Pg11, 19 respectively of these documents -

 BRC_CFA_Micro_Criteria_Guidance_Ed_1.2.pdf   1.54MB   18 downloads

 BRC F048 page19.pdf   198.26KB   17 downloads

 

this 2003, QMRA shows some relative risk assessments including various categories of cheese, eg pgs 24 - 25.

 Listeria monocytogenes Main.pdf   380.54KB   13 downloads

 

Type (b) has 4 mandatory, bulleted requirements within “High Care”. I think yr product can match all these requirements. Also note that this zone is stated to include production of unpasteurized soft cheeses.

 

If yr labelling does show cooking requirements as per the decision tree, it could presumably be classified as low risk, for example if initially combined with a frozen, to-be-cooked pizza as mentioned in the tree. However I think that conclusion is not the BRC intention for current type of product so that the tree is slightly inappropriate in this case. Hence the existence of the BRC textual footnote perhaps.

 

So IMO, the appropriate ZS is High Care. Of course BRC, or other posters, may completely disagree.

 

Rgds / Charles.C

Edited by Charles.C, 18 October 2013 - 07:17 AM.
added file

[cazyncymru]

So IMO, the appropriate ZS is High Care. Of course BRC, or other posters, may completely disagree.
 
Rgds / Charles.C

I agree Charles

Caz x

[Charles.C]

Dear TGC,

 

I would like to thank you for posting yr OP and later comments. IMO you have generated a very interesting thread.  

 

As you can see, cheese items are likely to produce different conclusions as far as zoning is concerned, particularly due to type of cheese, actual process, specified usage and individual opinion.

Some published, quantitative microbiological risk analyses for cheeses can be equally difficult to interpret,  I hv seen analyses with up to 4-5 texture / compositional categories, each with varying (safety) risk factors.

 

I hope you are still following this thread and will inform yr eventual conclusion from a BRC point-of-view. It’s interesting to know.

 

Thanks and Rgds / Charles.C

[Ian R]

Dear TGC

I have been exactly where you are with a cheese plant that grated Cheddar/Mozzarella 70:30

We successfully argued the process was low risk due to the nature of cheese being a basically safe product.

 

A key factor was the CCPs in the HACCP.

If you have temperature control as a CCP then you automatically make the process high risk.

You have defined that the chilled temperature is essential for food safety.

 

But if the chilled temperature is a quality issue and therefore controlled on that basis then you are low risk.

 

You also have to look retailer requirements, if you supply own label. e.g. for M&S the process would be high risk

 

In the BRC decision tree cheese is low risk, but that is cheese manufacture you need show in your HACCP study that you have acknowledged the additional risks of grating and handling, the increased surface area etc.

 

If you can get your ducks in a row then cheese grating can be shown to be low risk.

 

And don't let them outside in their factory shoes

rgds

[Charles.C]

Dear IanR,

 

Thanks for the input.
 

 

In the BRC decision tree cheese is low risk

In my copy, it says hard cheese ?

the nature of cheese being a basically safe product.

I daresay the BRC tree's intended POV is that with respect to L.mono, and for certain consumers, both cheeses are considered  safe to eat. However, in general,  "hard" cheese is considered intrinsically  "safer" than "soft" cheese. I presume this is supported by epidemiological data. Most texts seem to agree with the BRC opinion.

 

BRC seem to feel that certain quality factors are also linked to the zoning status.

 

As you indicate, it is likely that some retailers will not agree with the Low Risk conclusion. I find it rather illogical myself from a conservative viewpoint of the materials involved.

 

Rgds / Charles.C

 

PS (added) Apologies, i forgot to add that you should be congratulated for demonstrating that BRC's tree / text  may not fully match their entire viewpoint in some cases. I hope TGC will take note.