8 replies to this topic

[Charles Chew]

The use of wooden tools simply cannot be replaced by those modern stainless steel fabrics. Industries where articulation of the hands is needed to shape the product under process.

BRC-Food 3.7.7 states that "The use of wood ................shall where appropriate, be eliminated.

Well it is not appropriate in a fair number of instances and generally covering a lot of traditional industries. What would the Food Auditor say about this, I wonder?

It does affect a lot of people in the traditional industries who may be looking at BRC-FOOD as a standard and as such your response would benefit a whole lot of people out there.

Shall it be pragmatic or dogmatic?

Cheers
Charles Chew

[Franco]

BRC-Food 3.7.7 states that "The use of wood ................shall where appropriate, be eliminated. Shall it be pragmatic or dogmatic?

I would expect rationale for wood usage and a process validation

[Simon]

I think you had problems adding a poll Charles; I deleted it if you want to try again; or you could let me know the question and answers and I will do it for you.

In the Standard the keywords are "where appropriate"; in my opinion this provides some scope for pragmatism. A good auditor would make observations and ask questions, which may include:

What is the likelihood and severity of contamination from wood?
How well is wood controlled?
What is the physical condition of the wood?
How possible is it to replace the wood?
Is there a long term programme of wood replacement?

Like Franco says I would expect the client to have at least considered these sorts of things.

Regards,
Simon

[Charles Chew]

I think you had problems adding a poll Charles;

That was an error - pease ignore.

What is the likelihood and severity of contamination from wood?

Certainly, a risk assessment would have been done. I was just wondering what would be the view of the technical reviewer even if a risk assessment had been done and given the fact that these "wooden untensils" are subject to regular documented revews.

I say this because no alternative fabrics are available and differences in opinion with regards to its apparent safety to food hygiene always exist between operators and reviewers.

Indeed, how auditable is a food safety system even though a HACCP Plan's risk assessment follows closely to the Codex's decision tree is itself a manner of risk interpretation by the HACCP Team Leader and its members versus than of the reviewer?

Can it be deem that the Decision Tree was improperly used - could well be a matter of risk interpretations? Or should the technical reviewer support its objection that fundamentals were wrong . Any which way goes - all are humans and not all reviewers intepret technical issues homogeneuosly.

Goes to show how dynamic a FSS is.

Charles Chew

[Simon]

Hello Charles,

As the old sage Jim Wade says 'Management Systems requirements are not really Standards at all'. In the case of ISO 9001:2000 because it's designed to be used across many industries it must be very generic. Even when a Standard is designed specifically for a particular industry like the BRC Food Standard it still must be generic because there are many processes within the food chain and many subordinate product types for which the Standard is applied.

Unlike a specification for the curvature of a banana or the size of a potato which can be agreed (by the EU ), documented, measured and fruits or vegetables passed or failed without discourse; the generic (non-specific) nature of management systems leaves them open to interpretation by both implementers and reviewers. That's why we debate the meaning and practical application of their clauses on these discussion forums.

Certainly, a risk assessment would have been done. I was just wondering what would be the view of the technical reviewer even if a risk assessment had been done and given the fact that these "wooden utensils" are subject to regular documented reviews.

The ongoing relationship between Client and Auditor should be one of shared learning and improvement and the solutions implemented to meet the requirements of a Standard should (where possible) be mutually agreed and be a balance between risk and control. In determining the ‘real risk' and ‘required control' we should use amongst many others things the text of the Standard and a good measure of ‘common sense' to determine the ‘where appropriate'.

Without knowing all the intricate details of your particular case Charles it would be very difficult for anyone to give you a technical judgement.

For interest can you tell us what the wooden utensils are and why they cannot be replaced - do they add to the flavour of the food? Try pragmatising that to an auditor.

Regards,
Simon

[Charles Chew]

Management Systems requirements are not really Standards at all

Bravo!.........and I believe that is the way it should be.

what the wooden utensils are and why they cannot be replaced - do they add to the flavour of the food?

Well, the problem has not quite arrived yet although smartly and (should rightfully be) circumvented through alternative fabrics whenever available however, indications from previous audit experiences appear to suggest that reviewers generally tend to take a staunch view on this issue - i.e. phohibited!

However, if you are familiar with production of certain "soy-based vegetarian products" that have to be pre-shaped by workers prior to the cooking process, utensils such as a "wooden rooling pin" is used to shape the pre-cooked products which is wet and smooth (sometimes slippery). Now, can you imagine a stainless steel rolling pin to do this job ...........can't roll it mate!

Worse - the "soy skins" are obtained from a "cooling process" derived from bathing the liquid soy on a FLAT stainless steel bath tank with wooden panels on its side walls. Well some suggested "Teflon Coatings On the Side Wall" - which was a good idea.......but has anyone ever thought that the teflon coat is more toxic than the "woody flavour"

Well, what do you think Its a project I am about to start but although I have the answer to circumvent it again, I would like to know what Saferpakers think about issues like this.

CHarles Chew

[Simon]

I'm sure the wood if in good condition and clean would be of negligible risk, but then again I'm not an BRC Food Auditor.

Regards,
Simon

[Charles Chew]

but then again I'm not an BRC Food Auditor.

Simon,

This is precisely the reason why a potential possibility of such "non-conformity" may occur is being posted here for comments.

I have already asked comments from food auditors on this and it is the very reason why I do not want comments from food auditors but rather comments from the REAL PEOPLE who are directly INVOLVED in the daily operation of such an industry so that this FORUM can represent a cross section opinion of such situations.

Well, you have given your opinion and appreciated for that regardless of whether you are a food auditor or not........and that should be the spirit of our forum - giving opinions representating a practical and fair view of the subject w/o fear or favour.

I'm sure the wood if in good condition and clean would be of negligible risk

Yes! We are on the same page.
Cheers
Charles CHew

[yorkshire]

Dear Charles,

I assume we are hust looking at the foreign body risk here as there is a subsequent cooking stage (plus wood has been proved to have anti microbial properties in butchers' blocks).

I would ask the following questions:

Has wood been found in the final product?
Have damages to the wood been noted?
Will a subsequent stage remove the wood?
How frequently are you willing to inspect the wood?
How much product are you willing to destroy / quarantine if the wood is found to be damaged?

The IFS has the same clause as the BRC and, despite having a machine that uses alot of wood, have had no problems with auditors.

This reminds me of when we had our HACCP team trained and they sat their exam (RIPHH?). One of the main questions was about a small scale cheese (I think) producer who's mixer breaks. He has a wooden paddle made while he is waiting for the machine to be fixed. One of our engineers wrote a long section about how if the paddle was made by a craftsman, from hardwood, regularly inspected, etc... that this would be OK. Unfortunately the examining board thought this was the wrong answer and failed him.

The moral of the story is that auditors / food safety experts tend not to like wood.