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BRC GSFS v7 - 4.8.5 - Environmental Monitoring for Footwear Control

BRC 4.8.5 Footwear Control

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#1 scheff

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Posted 23 January 2018 - 01:00 PM

Hi all, 

 

After reading the forum for a number of years now the time has come for my first post.

 

Apologies if I have duplicated anything but I ran a search and didn't find anything previously posted about my question.

 

I have a question regarding 4.8.5 - Environmental Monitoring for Footwear Control.

 

The standard says that:

 

"There shall be an effective control of footwear to prevent the introduction of pathogens into high-care areas. This may be by a controlled change of footwear before entering the area or by the use of controlled and managed boot-wash facilities.

 

A programme of environmental monitoring shall be established to assess the effectiveness of footwear controls."

 

​What do others have in place to comply with this requirement?  What would be environmental testing that could assess the effectiveness of footwear controls?


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#2 GMO

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Posted 23 January 2018 - 07:32 PM

Have captive footwear and periodically, (e.g. once a month) take a couple of swabs of footwear soles for Listeria.  Job done.


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#3 scheff

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Posted 24 January 2018 - 04:38 PM

We do have captive footwear procedures in place.  Dedicated footwear for High Care area.

 

Would testing for Listeria alone cover the requirement?

 

"There shall be an effective control of footwear to prevent the introduction of pathogens into high-care areas"

 

Although not specific the above extract from the requirement would suggest that all pathogens should be tested for?


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#4 GMO

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Posted 24 January 2018 - 04:47 PM

We do have captive footwear procedures in place.  Dedicated footwear for High Care area.

 

Would testing for Listeria alone cover the requirement?

 

"There shall be an effective control of footwear to prevent the introduction of pathogens into high-care areas"

 

Although not specific the above extract from the requirement would suggest that all pathogens should be tested for?

 

It would depend on what your site processes.  So for example if you have raw chicken in low risk and cooked chicken in high care you may also want to consider Salmonellae I guess but Listeria is the most common one to test for in most factories.


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#5 scheff

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Posted 26 January 2018 - 02:50 PM

Anyone else have any thoughts on this?  I'm still struggling to come up with something that satisfies the requirement.


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#6 GMO

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Posted 26 January 2018 - 06:25 PM

What kind of product do you process?  What pathogens you swab for will be dependent on that.

 


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#7 scheff

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Posted 29 January 2018 - 09:00 AM

We produce frozen ready meals.  Cook>Rapid Chill>Chilled Portioning>Freezing.

 

We have a Listeria swabbing schedule in place.  Mainly covering food contact surfaces but also including less frequent testing on environment (walls, floors etc.)


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#8 GMO

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Posted 29 January 2018 - 10:27 AM

I would always have a rigorous environmental monitoring plan of the environment too but that's just me. 

I suppose I would question if you only monitor for Listeria as an environmental pathogen, why would you want to swab for anything else on wellies?  What else concerns you?  I would still say Listeria is your prime concern and as long as you can justify that, I've never had BRC question why we don't swab for other pathogens.  The whole point of barrier control is really to keep Listeria out and perhaps in your factory, Salmonellae.

 

What other pathogens are you thinking about swabbing for?


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#9 scheff

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Posted 29 January 2018 - 10:49 AM

As the requirement doesn't specify pathogens to test for and is generic to all

 

"There shall be an effective control of footwear to prevent the introduction of pathogens into high-care areas"

 

There could be an argument to say that all pathogens should be tested for.  This could lead to a complicated schedule covering a number of different pathogens in different areas each week / month which would become expensive to complete.

 

​We have never been questioned on it in an audit but my colleague has raised it in an internal audit and, quite rightly IMO, questioned if we have:

 

"A programme of environmental monitoring shall be established to assess the effectiveness of footwear controls"

 

to demonstrate:

 

"There shall be an effective control of footwear to prevent the introduction of pathogens into high-care areas"

 

I suppose really I am confident in the footwear controls that we have in place but not so confident that testing only for Listeria as sufficient to demonstrate that these controls are effective. But then I also don't want to set up an expensive, complicated swabbing plan if it is not really required.


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#10 GMO

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Posted 29 January 2018 - 02:01 PM

I would say there is a good argument for saying Listeria is a representative pathogen; i.e. in your plant if Listeria is absent, it's likely Salmonellae, Campylobacter etc is too.  This is because outside of high care and high risk areas Listeria is ubiquitous in the environment not just in raw foods.

 

I really think you're getting massively hung up on the detail here. 


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#11 scheff

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Posted 29 January 2018 - 02:12 PM

I really think you're getting massively hung up on the detail here. 

 

I agree. I am going over the top on the detail.  Because it's been raised in an internal audit I just want to make sure that I fully cover all angles (especially as if this internal audit is looked at by an auditor it will bring focus to this point).

 

 

I would say there is a good argument for saying Listeria is a representative pathogen; i.e. in your plant if Listeria is absent, it's likely Salmonellae, Campylobacter etc is too.  This is because outside of high care and high risk areas Listeria is ubiquitous in the environment not just in raw foods.

 

When you look at it like that, again, I agree.  Maybe I could just put into our Listeria swabbing procedures that if Listeria is detected then as a precaution the recheck will include testing for other pathogens.


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#12 TrevorLarson

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Posted 17 February 2018 - 07:06 PM

The requirement: “There shall be an effective control of footwear to prevent the introduction of pathogens into high-care areas. This may be by a controlled change of footwear before entering the area or by the use of controlled and managed boot-wash facilities,” refers to controls like designated footwear for the high-risk area only, and within the ante-room use a bench or barrier system segregating the boot change-over. A boot wash or footbath with their own strict controls can be used.

 

The purpose of environmental monitoring is to test the effectiveness of cleaning and sanitation of footwear, floors and drains, etc. in which case a full battery of tests is not normally required. From experience I find that total counts are normally requested with Listeria as a specified organism (due to the recent 80 deaths due to Listeria in this part of the world). Frequency can be based on risk with hand monitoring more important than boot monitoring


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