13 replies to this topic

[At-Gh]

Hi all,

 

Does anyone know by any chance what the BRC -7 requirement is for Raw and Cooked product segregation?

If we have a same area to make raw product  and packing of cooked product at the same time ?

 

Thanks

Atessa

[Charles.C]

Hi all,

 

Does anyone know by any chance what the BRC -7 requirement is for Raw and Cooked product segregation?

If we have a same area to make raw product  and packing of cooked product at the same time ?

 

Thanks

Atessa

 

It is expected that newly built factories will employ full wall separation where high-risk facilities are required.

Afaik, there are a variety of associated requirements with respect to personnel, equipment also.

 

You may need a BRC Interpretation Guideline to find the meaning/significance of "newly". I had thought that the top line had been compulsory for many years with no exceptions, eg due to age. Apparently not.

 

One relatively quick solution to the wall constraint is to use prefab units of course.

[trubertq]

They must be segregated... end of, cooked product is a high risk area and raw product is a low risk area. The standard states:

 

" Where high risk areas are part of the manufacturing site, there shall be physical segregation between these areas and other parts of the site. segregation shall take into account the flow of product, nature of materials, equipment, personnel, waste, airflow, and air quality and utilities provision (including drains). The location of transfer points shall not compromise the segregation between high risk and other areas of the factory. Practices shall be  in place to minimise risk of product contamination (e.g. disinfection of materials on entry).

[Charles.C]

trubertq,

 

Thks for the sec. 4.3.5

 

It is expected that newly built factories will employ full wall separation where high-risk facilities are required.

 

The word "expected" was perhaps poorly chosen inasmuch as sec.4.3.5 uses "shall". "Required" seems more appropriate.

 

Curiously, the above phraseology is repeated identically for high-care products although the related sec.4.3.6 uses "should" due, presumably, to the additional stated option.

 

I daresay "expected" just happened to be handy at the time of BRC's drafting the standard.

 

"Newly" also pops up in another strange paragraph. i won't try to analyse/interpret this one.

Manufacturing units that are newly built or ‘commissioned’ must ensure that systems and procedures in place are compliant before an initial BRC audit is undertaken.

[At-Gh]

They must be segregated... end of, cooked product is a high risk area and raw product is a low risk area. The standard states:

 

" Where high risk areas are part of the manufacturing site, there shall be physical segregation between these areas and other parts of the site. segregation shall take into account the flow of product, nature of materials, equipment, personnel, waste, airflow, and air quality and utilities provision (including drains). The location of transfer points shall not compromise the segregation between high risk and other areas of the factory. Practices shall be  in place to minimise risk of product contamination (e.g. disinfection of materials on entry).

 

They must be segregated... end of, cooked product is a high risk area and raw product is a low risk area. The standard states:

 

" Where high risk areas are part of the manufacturing site, there shall be physical segregation between these areas and other parts of the site. segregation shall take into account the flow of product, nature of materials, equipment, personnel, waste, airflow, and air quality and utilities provision (including drains). The location of transfer points shall not compromise the segregation between high risk and other areas of the factory. Practices shall be  in place to minimise risk of product contamination (e.g. disinfection of materials on entry).

Hi and thanks for your reply.

Let me explain the procedure :) The cooked product I am talking about is not 100% cooked and it s par-backed. So there is no high care area as we are not selling the par-baked product as ready to eat.

Although par-backed product is 95% cooked but  we have next cooking/baking step ( in store or at home ) by costumer which can eliminate any microbiological hazard.

Both area is medium care , with exposed finished product . Just one product is frozen, and another one is par-baked .

[At-Gh]

trubertq,

 

Thks for the sec. 4.3.5

 

The word "expected" was perhaps poorly chosen inasmuch as sec.4.3.5 uses "shall". "Required" seems more appropriate.

 

Curiously, the above phraseology is repeated identically for high-care products although the related sec.4.3.6 uses "should" due, presumably, to the additional stated option.

 

I daresay "expected" just happened to be handy at the time of BRC's drafting the standard.

 

"Newly" also pops up in another strange paragraph. i won't try to analyse/interpret this one.

Yes, This one a bit confusing as both products at the same production area are not ready –to eat. No high care area. Just one is raw frozen, one is cooked frozen ! 

[Charles.C]

Hi Atessa,

 

Thank you for the expansions and Yes, the process details do have a few confusions.

 

Are you actually generating the parbaked product ("parbaked" seems similar to what I call "precooked"  but "more" cooked-baked )  yourself or is your total operation one of packing only ?

 

I was unable to find any usage of the term "medium care" in UK version - BRC7. (though i recall TESCO UK confusingly invented (or perhaps borrowed) it for their own FS system).

 

Australian version of  BRC7 perhaps ?

[Charles.C]

Hi atessa,

 

Yr OP is an excellent example of the benefit in understanding the process flow before interpreting its (Area) classification within the BRC Risk  Scheme.

 

I deduce you have 2 “independent” process lines in one Production area making different Items, X and Y.

I assume the packing step for both products is done after freezing, ie a 2-stage production process.

 

If so, there is  –

 

(1) One line which results in a frozen, raw, product X

(2) One line which results in a frozen, raw, parbaked product Y

 

IMEX, from a HACCP POV, a final packed product is either raw (= NRTE) or cooked (= RTE).

 (I appreciate that different localities may vary in terminology, particularly (and sometimes contentiously) from a labeling POV).

 

Accordingly, it seems to me that both (Production) lines and the subsequent Packaging Operation would then  yield (FrozenYYY) for steps 1-4  in Fig 6 of BRC7, ie a “classic” Low Risk Area scenario.

 

As far as the necessity for physical separation of the lines is concerned, one possible (HACCP) reason might be due to allergenic factors. An operational reason might be due to different temperature environments.

 

Based on yr previous posts, I anticipate that your own analysis/conclusion differs from the above so perhaps you could clarify the cause(s) of such difference.

[RG3]

Charles I'm sure Atessa meant medium care....please see this link posted by another fellow Aussie HarryPotterOZ...and I'll give Atessa the benefit of the doubt and say perhaps she has the same customer.

http://www.ifsqn.com...m-care/?p=86584

[Charles.C]

Charles I'm sure Atessa meant medium care....please see this link posted by another fellow Aussie HarryPotterOZ...and I'll give Atessa the benefit of the doubt and say perhaps she has the same customer.

http://www.ifsqn.com...m-care/?p=86584

 

Thanks for the link but do note that the other thread is (seemingly) unrelated to BRC.

[At-Gh]

One line (raw frozen pastry) has got BRC certificate and another line has to get another standard we call : CFMSR. The meaning of Medium and Base area have came from the mentioned standard which we need to follow in AUS for one of the huge supermarket in AUS .

I need to consider both mentioned standards for these 2 lines.

Many thanks for the information and your comprehensive reply.

[At-Gh]

Hi atessa,

 

Yr OP is an excellent example of the benefit in understanding the process flow before interpreting its (Area) classification within the BRC Risk  Scheme.

 

I deduce you have 2 “independent” process lines in one Production area making different Items, X and Y.

I assume the packing step for both products is done after freezing, ie a 2-stage production process.

 

If so, there is  –

 

(1) One line which results in a frozen, raw, product X

(2) One line which results in a frozen, raw, parbaked product Y

 

IMEX, from a HACCP POV, a final packed product is either raw (= NRTE) or cooked (= RTE).

 (I appreciate that different localities may vary in terminology, particularly (and sometimes contentiously) from a labeling POV).

 

Accordingly, it seems to me that both (Production) lines and the subsequent Packaging Operation would then  yield (FrozenYYY) for steps 1-4  in Fig 6 of BRC7, ie a “classic” Low Risk Area scenario.

 

As far as the necessity for physical separation of the lines is concerned, one possible (HACCP) reason might be due to allergenic factors. An operational reason might be due to different temperature environments.

 

Based on yr previous posts, I anticipate that your own analysis/conclusion differs from the above so perhaps you could clarify the cause(s) of such difference.

 

 

Charles I'm sure Atessa meant medium care....please see this link posted by another fellow Aussie HarryPotterOZ...and I'll give Atessa the benefit of the doubt and say perhaps she has the same customer.

http://www.ifsqn.com...m-care/?p=86584

 

 

Thanks for the link but do note that the other thread is (seemingly) unrelated to BRC.

One line (raw frozen pastry) has got BRC certificate and another line has to get another standard we call : CFMSR. The meaning of Medium and Base area have came from the mentioned standard which we need to follow in AUS for one of the huge supermarket in AUS .

I need to consider both mentioned standards for these 2 lines.

Many thanks for the information and your comprehensive reply.

[Tony-C]

Interesting discussion! If you look the appropriate Production Zone decision tree:

 

FIGURE 6 PRODUCTION ZONE DECISION TREE 1 – CHILLED AND FROZEN PRODUCTS

 

 BRC Global Standard for Food Safety Issue 7 UK Production Zone Decision Tree 1.jpg   154.61KB   0 downloads

Step 1 Are the final products stored ambient, chilled or frozen?

→ Chilled or frozen →

Step 2 Are products or ingredients within the area open to the environment (i.e. neither packaged nor fully enclosed in tanks or pipes etc.)?
→ Yes →
Step 3 Does the product support the growth of pathogens or the survival of pathogens, which could subsequently grow during the normal storage or use of the product unless stored chilled or frozen?
→ Yes →
Step 4 Does the area contain products which, on the basis of cooking instructions and known customer use*, undergo full cooking** prior to consumption?

→ Yes → Low-risk area – for example, raw meat, vegetables (e.g. potatoes), prepared meals containing raw protein, frozen pizza, unbaked frozen pies

* If the product is ready to eat or ready to heat, or on the basis of known customer use, is likely to be eaten without adequate cooking, then proceed to step 5.
** Thermal treatment equivalent to 70˚C for 2 minutes

So using the production zone decision tree your area would be defined as low risk unless the products on the basis of known customer use, is likely to be eaten without adequate cooking, then proceed to step 5.

It should be noted that where the product has cooking instructions for the consumer that are equivalent to a full cook, then the product may be considered as low risk. In these situations, the site is expected to have a full validation, which the auditor can refer to, demonstrating that the cooking instructions are appropriate and that the product will achieve the correct temperature/time when the cooking instructions are used.

 

Regards,

 

Tony
 

[Charles.C]

Hi Tony,

 

Well spotted asterisk(s). Some serious diligence-nailing underway by BRC.

 

Yr last paragraph is a notable elaboration of the “validation” content in BRC6. Not that it shouldn’t be available for all labeling instructions of course. Microwave validations must be operationally interesting.

 

I notice that no typical examples of  NRTE products commonly known to be at risk are provided. The caveat has echoes of an older thread here on the perils of cooks licking their dough bowls clean.

 

One wonders if this requirement is strictly maintained where local Regulatory requirements are not based on L.monocytogenes and where the D-value is (presumably) significantly lower. USA-Salmonella ?? A local  interpretation of  “Equivalent” perhaps ? Or perhaps the N.American version of BRC7 is "modified" ?

 

@ Adessa – As per the above I  presume you have detailed validation data for (presumably all ) your various categories of frozen raw pastries (filled?). And  that the (presumably mandatory) labeled cooking instructions do ensure that a thermal treatment equivalent to 70degC/2mins is achieved.

(the temperature location is nowhere specified, boo-boo BRC).

(I assume yr existing BRC certification for frozen raw pastry was based on Low Risk ?)