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[filipa]

Hello,

I work in a factory. We manufacture Tomato based products. Our system/process is closed, no product is exposed during the process (only in the filling can line, some seconds, before the seaming).

In our Hygiene Policy, we don't need to change the protective clothing in specified areas (canten, smoking areas,...), because we have no risk. And, some people need to work inside and outside the production areas (the evaportaors are outside).

We never have problems in the BRC audits, because the auditors undestand that we don't have the designated high-risk and low-risk areas... My problem now is that in this news standards I think that I need to do a Risk assessment to confirm it...

Anyone can explain me if it is true, and how can I do it??
Anyone have an example?

Many thanks for your help,
Filipa

[Madam A. D-tor]

Dear Filipa,

In chapter 7.5: protective clothing, there are a lot of references to risk assessments.

First of all: As you do not have a high risk area, all the requirements referring to these areas, will be indicated as N/A. (I would do so, when I perform an audit at your site)

The risk assessments are not very hard and you can include these in your HACCP-analyses. Like you already included the prerequisite programms.

Example:
hazard: contamination by beard or moustache hair by employees.
measure: the process is closed. employees working with open products wear beardsnoods.
risk: occurence X effect (look at your complaints for the occurence; maybe you have sieves in line and you have found hairs there, include these to motivate your occurence)
decision tree: you probably know that already. Maybe, there is a next process step)
Make sure you can motivate why this is no risk in your factory. Use objective information.

7.5.6: You need to have hair nets, which contain all scalp hair. This has changed and it is not langer possible to exclude this requirement by a risk assessment, as it was in issue 4. It seems quite rare. Especially in closed processes and for example in fruit and vegetable companies (no cutting or processing)

I hope this helps you. Good luck with your FSMS.