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Does the attached risk assessment meet BRC 7 requirements?


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#1 jannel

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Posted 24 May 2016 - 06:21 AM

Could somebody help me if the attached risk assessment matrix is passable for BRC 7 requirement?

 

Your help will be highly appreciated. Thanks!

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#2 Charles.C

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Posted 24 May 2016 - 07:10 AM

Could somebody help me if the attached risk assessment matrix is passable for BRC 7 requirement?

 

Your help will be highly appreciated. Thanks!

 

Hi jannel,

 

Is this clause 3.4.4 ?

 

The requirements may also depend on the product / process / associated (BRC) Risk zone status. Pls inform


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Charles.C


#3 jannel

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Posted 25 May 2016 - 09:26 AM

yass.. this is based on clause 3.4.4.. The whole plant is classified as low-risk, our product is cooking oil and the zones in direct contact with food and is in open areas have the most frequent cleaning and audits. For corrections kindly notify.. Thank you so much!


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#4 trubertq

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Posted 25 May 2016 - 11:24 AM

You need to be carrying out Hygiene audits at least once per month in open product areas.It's not immediately clear from your document that you are doing that, probably because you have cleaning and audit in the same section.  for example: Do you clean Landing daily  or audit daily?

 

The risk assessment for cleaning looks good to me. I presume that " operational shutdown" means it can only be cleaned when the plant is shut down? Is this a closed system? If so how often is it cleaned? I think you'd need to put in a maximum time that would pass before it would be cleaned, if you know what I mean.

 

Hope this helps


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#5 Charles.C

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Posted 25 May 2016 - 01:08 PM

Hi jannel,

 

As I understand this clause essentially requires a program of GMP audits/inpections.

 

BRC have as usual made life difficult by inserting their “risk-based”  irritant for the inspection frequency.

 

(1) If using the Zoning approach, I would have thought it more logical to allocate the hygiene/fabrication inspection frequencies in yr table directly from the Zoning, ie sort of analogous (but likely different frequencies, etc)  to the 4-zone system in attachment below (eg see pgs 19, 31).

(2) I think “hygiene”** would include items like employee hands, pest control, waste disposal, lights, doors, drains, jewelry, hairnets, etc

(3) Some of your risk results seem questionable,  eg - the consequence from failure to clean the floor in Zone 1(direct food contact) is less than in Zone 4 (non-food contact) ? Why ?

** No idea what BRC's  "housekeeping" includes ! (And, as usual, nowhere defined by BRC, has its own semi-category 4.11 but never expanded)

 

Other related threads, eg –

 

http://www.ifsqn.com...ns-requirement/

 

http://www.ifsqn.com...-of-clause-344/

 

Attached File  pathogen environmental monitoring.pdf   819.06KB   112 downloads


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Charles.C


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#6 trubertq

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Posted 25 May 2016 - 03:30 PM

Housekeeping Charles, is something the eludes men most of the time.


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#7 Wowie

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Posted 25 May 2016 - 04:18 PM

Housekeeping Charles, is something the eludes men most of the time.

:roflmao:

 

 

Housekeeping, in our book, is general cleanliness and proper storage of tools, equipment, etc. Examples of things commonly identified as "general housekeeping" include "trash pallets" where broken down combos are kept until banding being stored in the cooler, pallet scraps in the corners, untidy offices and work stations, etc.


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#8 Charles.C

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Posted 25 May 2016 - 06:56 PM

RATHER OT

 

Hi All,

 

The House seems to be growing. but is it a BRC House ?

 

Attached File  SOP__Housekeeping+Audit.pdf   618.19KB   107 downloads
Attached File  CONTAMINATION AND GOOD HOUSEKEEPING.ppt   969KB   93 downloads

 

https://www.ccohs.ca...rams/house.html


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#9 jannel

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Posted 25 May 2016 - 10:00 PM

We have monthly GMP internal audit. We also have daily cleaning and inspection for the areas scheduled as daily. For operational shutdown, this actually depends on the volume of supply one to two weeks production days perhaps then shut down for cleaning the closed systems.


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#10 jannel

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Posted 25 May 2016 - 10:21 PM

Thanks for the replies. I think I misunderstood hygiene frequency audits, that it mainly focuses on cleaning excluding the personnel as well as pest control. But we have a third party for our pest control, do we need to still include it in hygiene frequency audits? Some Areas classified under Zone 1 have less severity compared to others because the flow of our raw material is from open to partly closed (under-processed) and closed system (finish products). Our product also doesn't support bacterial growth.


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#11 jannel

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Posted 25 May 2016 - 11:53 PM

I mean, some zones classified under zone 1 will still undergo a kill step (CCP) . These zones are in contact with our raw materials (that goes several processing), so compared to other zones after the kill-step (refinery), there severity is low.


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#12 Charles.C

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Posted 25 May 2016 - 11:55 PM

Thanks for the replies. I think I misunderstood hygiene frequency audits, that it mainly focuses on cleaning excluding the personnel as well as pest control. But we have a third party for our pest control, do we need to still include it in hygiene frequency audits? Some Areas classified under Zone 1 have less severity compared to others because the flow of our raw material is from open to partly closed (under-processed) and closed system (finish products). Our product also doesn't support bacterial growth.

 

Hi jannel,

 

Cleaning/sanitizing is particularly carried out to prevent/minimise "contamination", eg - 

 

http://www.foodsafet...ood-processing/

 

Have a look at the GMP audit attachment in one of the threads i linked previously (Post 5).


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Charles.C


#13 Charles.C

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Posted 26 May 2016 - 12:08 AM

I mean, some zones classified under zone 1 will still undergo a kill step (CCP) . These zones are in contact with our raw materials (that goes several processing), so compared to other zones after the kill-step (refinery), there severity is low.

 

This is the reason why meaningful  (risk) zoning requires a knowledge of the flowchart.

 

There may be some confusion regarding  the terms probability, severity and risk. For a given microbial hazard, a kill step typically "eliminates" the "likelihood of occurrence" ( = probability) of the hazard in the end product, not its severity if it does occur (ignoring LD50 aspects).


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Charles.C


#14 Charles.C

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Posted 26 May 2016 - 02:21 PM

Hi jannel,

 

A few more comments –

 

(1) For clause 3.4.4, I liked the Zonal approach (ie contamination risk for the final product) for directly predicting location inspection frequencies. Together with standard-compliant frequencies such as per yr document.

One advantage of this procedure is that it is sort of validatable by analogy to the methodology used in pathogen env. monitoring.

If there is a “kill” step (refining?), it is likely that the Zoning /  risk of contamination from a microbial POV will be highest contamination significance for stages post “kill”.

 

(2) For clause 4.11.2 and assuming that the necessity for cleaning is correlatable  to the Zoning Grade, IMO the zone scheme is also usable to directly predict cleaning frequencies (and presumably methods as required by the clause).

 

(3) As an alternative to (2), I also liked the sections  in yr document involving 5-step Probability (P) and 5-step severity (S) for determining cleaning frequencies. This is providing you can justify the data  for P/S in yr Table and correlate to the matrix (also depends on the flowchart). I don’t personally think the Zonal scheme is necessary to be included in this procedure but it’s ok if convenient for the P/S calculation step and correlates/justifies with the numbers.

 

(4) It is also relevant from a contamination POV as to whether microbial species can even survive (in addition to "not grow") in yr product ?

 

(5) I'm not familiar with this product/process but i think, from memory, that  refined edible(?) oils are historically/intrinsically very safe products which suggests that you should not need a highly technical risk evaluation procedure from BRC's POV.


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Charles.C


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