8 replies to this topic

[it_rains_inside]

Hello all,

 

27 days to BRC and counting.... EEKK!!

 

Just looking for some interpretation here: 4.11.1: Documented cleaning procedures shall be in place and maintained for the building, plant and all equipment. Cleaning procedures shall as a minimum include the: ... blah blah blah .... frequency of cleaning

 

no more or less.. just "frequency of cleaning". I checked the ever so helpful interpretation guide.... "Frequency of cleaning" 

 

So is this the minimum , maximum, or recommended frequency of cleaning. Or possibly the actual frequency of cleaning??

This was brought up on an internal audit back in January, and I still haven't figured out how to close this one out.

 

Currently we have a check box in the upper-corner that has : REASON FOR CLEANING: Scheduled Sanitation (or Sterilization depending on the Doc in question), Maintenance Work, Extended Shut-down, or Other. And we date the day the operation was completed.

 

Any thoughts??? Recommendations??

 

Thanks!!!!

[Tony-C]

BRC requires a frequency on cleaning 'based on risk' so high risk may be daily, medium weekly, low monthly for example.

 

A lot of people use a matrix summary for this including things like:

Area to be Cleaned
Frequency
Chemical/Dosage
Cleaning Equipment/Tools
Procedure
Records
Responsibility for Cleaning
Responsibility for Checking

 

The matrix can then be used to generate a checklist/record if you don't have one.

 

Regards,

 

Tony

[Charles.C]

Dear it rains inside,

 

As per previous post, a precise mathematical solution is rarely expected.

 

The frequency inevitably depends on yr process, ie what is being cleaned ? This is unknown.

 

IMEX, any specified frequencies can, at least initially, be guessed, or, put  more impressively, via  (intuitive) Risk Assessment.

 

The usual approach IMEX is to be conservative, validate/verify, then relax/tighten depending on results. In many cases, the appropriate interval between "cleaning/sanitising"  is approx.  "commonsense" in respect to the activity / practical limitations / "cleanliness" requirements.

 

IIRC, I posted a formal RA/SOP/template borrowed from another "BRC-compliant" source using the above logic somewhile back, ca. 2012. Unfortunately couldn't find it yet, will check my archives.

 

Rgds / Charles.C

 

PS - I presume you are doing some Va/Ve, eg atp/micro.data ? Eyes ?

 

PPS - a related ealier thread, I daresay there are others -

 

http://www.ifsqn.com...for-validation/

[it_rains_inside]

We are considered a low-risk facility, we are an aseptic high-acid juice/ smoothie manufacturer. We currently sterilize equipment at start-up, CIP mid-week, and sterilize or water-flush systems at a flavor change (depending on what we are switching to). Any allergens being run get a full 5-log CIP after, and we do a full CIP again on anything that ran at shut-down. There are not specific times that we clean, generally our production schedule dictates. We have SOPs for each operation, and like I stated earlier, they have on each of them "Reason for Cleaning" I just didn't know if that would qualify as "frequency of cleaning" We have a scheduling SOP that details all of this, but the standard states "Cleaning procedures shall as a minimum include: ..." so i was thinking this "frequency" had to be on each SSOP (??)

 

I am thinking a RA is in order, just to be on the safe side - more than likely using past practice as means of verification.

 

@Charles - to your "PS" Yes, we do lots of Va/Ve! We physically verify cleanliness, run our own micro, titrate rinses, and also run full diagnostics on rinse water as a final measure. 

 

Thank you both for your help!

[Charles.C]

Dear it rains inside,

 

Thks for the expansion. Interesting process.

 

I'm rather surprised about the "low risk" category (= non-thermal process?).

 

I noted the word "sterilize". Do you mean SIP as compared to CIP ? (I'm curious as to the quantitative difference?)

 

"allergens being run get a full 5-log CIP" - How do you validate ? (I'm only familiar with respect tp pathogen reduction)

 

There are not specific times

I presume you mean the interval is related to variable process runs or shift periods. This IMEX is OK but may need to be formalised (which perhaps it is in yr SOP).

 

"Reason for Cleaning" I just didn't know if that would qualify as "frequency of cleaning"

Probably not as stated.

 

IMO you need to implement Tony's matrix proposal and then justify the stated interval(s) via a (hopefully) generic  RA/Va-Ve. (ie justify by satisfactory results)(+ refs if such exist which probably do not )

(The SOP which I referred previously, from memory, did simply, textually,  that.)( analogous to a validation SOP for the calibration intervals of measuring devices.)

 

Rgds / Charles.C

[fgjuadi]

On my SSOPs I have a section titled "Frequency" before the procedure, and a Frequency column on my Master Cleaning Schedule

[Taste Maker]

I believe that basically if it gets soiled daily, it should be cleaned daily. Also, it would depend on the risk as well. You cannot over clean but, can certainly under clean. For example, the floors at our plant become covered with flour every day if we are producing our normal volume. Whereas the tops of the sky lights may only become "dirty" on a monthly basis. Food contact surfaces if containing allergens need to be cleaned between non-allergen containing products. Again, it depends on how you schedule runs and route traffic through the facility as well. If it is a hazard or "may" result in the contamination of food through not cleaning then, determine the "need" and hence the frequency.

[FSQNNow]

Frequency depends on your risk assessment, as included in your HACCP.

Please also look that you have a solid environmental monitoring program and maybe also a pathogen environmental monitoring program in place.

This can also help to give you early warnings.

 

Benchmarks:

Look for information of Kraft: 7 steps of wet sanitization http://www.kraftsupp...g.asp?listno=12

Look for information of General Mills: 

also http://www.agfoodsaf...-Prevention.pdf

also http://www.aibonline.../5Guideance.pdf

also http://www.ilsi.org/...resentation.pdf

[SharonF]

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