24 replies to this topic

[Madam A. D-tor]

Dear All,


The new issue of BRC Food includes a decision tree to decide wether a department is low care, high care or high risk. The new issue also includes strict requirements regarding segregation and hygien for high care and high risk areas.

A lot of organisations, which do not have determined high care or high risk areas now are forced to do with the new issue of BRC.

Is your company forced to build high care/high risk area?
What are the expected costs/investments involved?

How do you motivate your decision, if you decide it is not high care/ high risk and the decision tree say it is? Auditors need to approve these motivations. What do you think is acceptable?

I already have a lot of cases of companies which do not have a high care/ high risk department right now, but will be forced to have one for issue 6. Some of them will leave BRC, due to major costs involved and the small risks involved.

Please share your experiences and opinions regarding the decision tree.

[Madam A. D-tor]

Hi all,

I see, this is a difficult issue. 142 people read this post, but no reaction yet.
I will give an example:
Several customers of me produces ready to heat snacks. e.g. chicken nuggets, onion rings, cheese pops etc.
The process is in general:
- preparation of filling in separate department;
- transport to form line in containers - put filling in filling machine with lift;
- form product - battering - (crumbing) - frying - (heat air oven): temp after heating > 72 °C;
the whole forming and frying line is in one area and is operated mostly by one person.
- transport to inline freezer;
- freezing - packing.

Would you say that high care starts after heating the products? So should the room where the forming-frying line is placed by separated in two rooms, where the second room is high risk area? The operator then should change his clothes a lot of time a day. For example when doing checks on product temperature, oil temperature and line speed. When there is an obstruction in the line after heating, the operator will not be able to fix this quick enough.
How about the room before the inline freezer? According the decision tree this is also high risk?
How about the freezer itself?
and how about the packing department after the freezer? Are these also high risk?

The products need to be heated before consumption, but no thorougly heating is needed. Only for taste. For some products it is not inlikely that consumers eat it, without proper heating.

[Charles Chew]

Dear Madam A. D-tor
I can understand the gravity of your concern with regards to high care areas (internal site standard requriements). I also agree with you that many companies will leave BRC as it appears to have become "financially inhibitive" and "impractical" to conform for most. We have recently just taken a company to BRC (Issue 5) certification and from my observation, Issue 6 has just "forced" our client from a food processor to embrace a standard revised for "pharmaceutical applications"

What will end up is a facility with multiple "buffer zones" supported by sub-changing-facilities to control "movements" which most current facilities are not designed for. That clearly means either renovate to conform or abandon with a review of your business objectives. In today's economically difficult world and under this circumstance - abandoning certification for alternative seems to be a viable option for corporate survival and business continuity.

The bigger question is whether making conformity requirements tougher will actually help reduce food poisonings. As a matter of fact, it has not been achieving that target of reducing food poisonings over the last few decades. In fact, food poisonings have increased. That being so, what is wrong?

[cazyncymru]

Dear All,


The new issue of BRC Food includes a decision tree to decide wether a department is low care, high care or high risk. The new issue also includes strict requirements regarding segregation and hygien for high care and high risk areas.

A lot of organisations, which do not have determined high care or high risk areas now are forced to do with the new issue of BRC.

Is your company forced to build high care/high risk area?
What are the expected costs/investments involved?

How do you motivate your decision, if you decide it is not high care/ high risk and the decision tree say it is? Auditors need to approve these motivations. What do you think is acceptable?

I already have a lot of cases of companies which do not have a high care/ high risk department right now, but will be forced to have one for issue 6. Some of them will leave BRC, due to major costs involved and the small risks involved.

Please share your experiences and opinions regarding the decision tree.

It's a very difficult subject, not made easier by the retailers insisting on their interpretation.

We make a chilled RTE food, and MY interpretation is that we should be a High Risk manufacturer. Yet some of our retailers call us a High Care manufacturer!!

Confused.com

Caz x

[gcse-fhp]

Hi Charles Chew
Your post is so refreshing to read. Perhaps we will start to redirect our thinking to what is going to produce real and desirable results for the food/product safety community. Your comments and questions that need to be seriously considered are:

In today's economically difficult world and under this circumstance - abandoning certification for alternative seems to be a viable option for corporate survival and business continuity.

The bigger question is whether making conformity requirements tougher will actually help reduce food poisonings. As a matter of fact, it has not been achieving that target of reducing food poisonings over the last few decades. In fact, food poisonings have increased. That being so, what is wrong?

The current confusion appears to be robbing us of the ability to think clearly about how we should proceed in our combined effort to protect the consumer from known and anticipated risks caused by food and health products. I will personally like this conversation to continue.

Edited by gcse-fhp, 24 December 2011 - 02:42 PM.

[Ken]

Having read this section several times, my conclusion is that it is poorly written - on the one had the retailers want us to complete a risk assessment and at the same time are eager to tell us the outcome of the risk assessment! - never understood the logic of this.

I have spoken to one of the certification bodies and they agreed that this section is ambiguous stating that we can expect more clarification in the gudelines.

One of my clients who consider themselves 'high care' and justifiably so, spoke to their certification body for guidance as they were concerned they may have to plan for a major investment as by the new standard, they were now considered high risk. The certification body were unable to give an answer!

My advice is to wait for the guidance document.

[Madam A. D-tor]

One of my clients who consider themselves 'high care' and justifiably so, spoke to their certification body for guidance as they were concerned they may have to plan for a major investment as by the new standard, they were now considered high risk. The certification body were unable to give an answer!
My advice is to wait for the guidance document.

Hi Ken,
Thanks!
This is exactly my problem! The guidance document is still not available and as a CB auditor, I do not have the answers, but... I do have to perform proper audits regarding this section in 2 weeks.
I do not want to give majors on this subject without ompletely understanding it.

One of my first BRC audits wil be with a producer of smoked fish. Both warm smoked and cold smoked fish is produced. According the decision tree (if I understand it right), these activities can no longer be conducted in the same room. Warm smoked fish is high risk and cold smoked fish is high care. The organisation does now only segregate the dirty department (from reception of fish, unpacking, filetting, salting). Staff in this area has separated staff facilities and different colour clothes. This always seems fine to me, but how do I justify this in issue 6?

[fstRicky]

An interesting sub-subject - the value of making the standards too stringent and therefore restraining - I am with Charles Chew and gcse-ftp on this one -where are we heading???

Some of the requirements is these standards will cause manufactures to revolt and look elsewhere (if they can) - after all it is an agreement between the retailer and the manufacturer. It is these kinds of demands that have caused the food industry to struggle in the area of a more universal standard. One thing I have also found out is the the interpretation by an Auditor can change the whole outcome of an audit.

The standards are good and started well - but looks like they have to keep adding things and making them more difficult to attain - like someone mentioned were are making food not pharmaceutical products.

R

[GMO]

Hi all,

I see, this is a difficult issue. 142 people read this post, but no reaction yet.
I will give an example:
Several customers of me produces ready to heat snacks. e.g. chicken nuggets, onion rings, cheese pops etc.
The process is in general:
- preparation of filling in separate department;
- transport to form line in containers - put filling in filling machine with lift;
- form product - battering - (crumbing) - frying - (heat air oven): temp after heating > 72 °C;
the whole forming and frying line is in one area and is operated mostly by one person.
- transport to inline freezer;
- freezing - packing.

Would you say that high care starts after heating the products? So should the room where the forming-frying line is placed by separated in two rooms, where the second room is high risk area? The operator then should change his clothes a lot of time a day. For example when doing checks on product temperature, oil temperature and line speed. When there is an obstruction in the line after heating, the operator will not be able to fix this quick enough.
How about the room before the inline freezer? According the decision tree this is also high risk?
How about the freezer itself?
and how about the packing department after the freezer? Are these also high risk?

The products need to be heated before consumption, but no thorougly heating is needed. Only for taste. For some products it is not inlikely that consumers eat it, without proper heating.

What annoys me is that it's not gone far enough! It specifically cites hard cheese as a low risk area product, however, I know of recalls associated with Listeria in hard cheese which would have been helped by segregation.

In your example, if the product is not then fully cooked, it is a high risk product. There is nothing different in that process to cooking chicken for a ready meal (which has been high risk for years.) I don't see any reason why these manufacturers should be able to get away without investing when others have; however, it does depend on what they're frying. I would think you'd be able to argue the case on onion rings. They just need the evidence to support it; e.g. water activity, contamination of the original ingredient, modelling of pathogen growth etc, etc.

[Ken]

Hi Ken,
Thanks!
This is exactly my problem! The guidance document is still not available and as a CB auditor, I do not have the answers, but... I do have to perform proper audits regarding this section in 2 weeks. I do not want to give majors on this subject without ompletely understanding it.

One of my first BRC audits wil be with a producer of smoked fish. Both warm smoked and cold smoked fish is produced. According the decision tree (if I understand it right), these activities can no longer be conducted in the same room. Warm smoked fish is high risk and cold smoked fish is high care. The organisation does now only segregate the dirty department (from reception of fish, unpacking, filetting, salting). Staff in this area has separated staff facilities and different colour clothes. This always seems fine to me, but how do I justify this in issue 6?

You need to get guidance from the certification body before your audit. If I were the auditee, I would not agree to the audit without proper guidance. Correct interpretation of the standard is essential as one major non conformance in this can cost your customer several hundred thousand pounds to make changes to their factory or potentially put them out of business. Very frustrating for the auditor and auditee, particularly if it was all down to a wrong interpretation by the auditor or an incomplete assessment by the technical team who I'm sure worked very hard to produce the new standard. (which despite this is a much needed improvement)

My interpretation is the design tree is ambiguous, - if you use the decision tree, you could still arrive at the answer 'yes' or 'no' which is why the guidelines are essential for both sides and to maintain credibility for the BRC

[GMO]

For info from personal experience, cold smoked fish is notorious for containing pathogens, particularly Listeria. Perhaps rather than work to meet the standard, you need to work to make things safe or ensure they are safe, then work the risk assessment route if you genuinely are convinced it's ok.

For example, as a pregnant woman as I was a couple of years back, I would have avoided cold smoked fish unless I was cooking it but would have eaten hot smoked fish...

[Madam A. D-tor]

For info from personal experience, cold smoked fish is notorious for containing pathogens, particularly Listeria. Perhaps rather than work to meet the standard, you need to work to make things safe or ensure they are safe, then work the risk assessment route if you genuinely are convinced it's ok.

Thanks for the info. I know Listeria is The problem for smoked salmon, This company does actually a good job with separate areas for handling and packing cold and warm smoked fish. However these are no high care/ high risks areas, with no cloth changing or disinfection of tools before entering. Areas are segregated by a central corridor. Also the warm and cold smoked fish is produced in the same smoking cabins (separated in time ofcourse) and cooled down in the same cooling room. Using the same rooms/lines/ in this case cabins, for high risk and other products is not allowed.
I have 3 fish smokers as customers. One of the others does actually have the same lay out. Also a central corridor to separate the several departments and different coloured clothes and separated staff rooms for dirty department. The third one is very small with only one smoking cabin and one packing/cutting room. This one wil not be fit to gain BRC iss 6.

For example, as a pregnant woman as I was a couple of years back, I would have avoided cold smoked fish unless I was cooking it but would have eaten hot smoked fish...

Exactly! just like you,I would say cold smoked fish is of higher risk as warm smoked fish. However, according the descision tree provided, the warm smoked fish is high risk and the cold smoked fish is high care. It is opposite of what I expect.
Another example: decision tree gives high risk for fully cooked ham and high care for filet americain (I do not know if this product is known in the UK. It is steak tartare with spices and sauce and is eaten without heating on sandwiches or toast). I would suspect it other way around and this really confused me. Now I am thinkinkg: the decision tree is for the area and not for the product, so if the product is fully cooked it will be more vulnarable for contamination from the area??? However cooked products are often less vulnerable because of lower Aw, dryer surface, salt%???? I just dont get it. I am feeling that I miss something to fully understand this decision tree.

For example, as a pregnant woman as I was a couple of years back, I would have avoided cold smoked fish unless I was cooking it but would have eaten hot smoked fish...

I do believe that Listeria in cold smoked salmon and raw milk cheeses is less of concern for the consumer group pregnant women, then other RTE meal with Listeria, because of the information provided to pregnant women. These do know (or at least they have been told) that they should not eat raw milk cheeses or smoked salmon.

[Madam A. D-tor]

I don't see any reason why these manufacturers should be able to get away without investing when others have

I think it is the other way: Why forcing manufacturers for big investments, where it is not needed?

In your example, if the product is not then fully cooked, it is a high risk product. There is nothing different in that process to cooking chicken for a ready meal (which has been high risk for years.)

Until now I have never consider production of frozen chicken nuggets as high risk. The product is fully cooked (fried) and directly frozen. -20 °C within 1 hour.
According BRC issue 5: high risk products are ready to (h)eat products which have a high risk for growth of pathogens. where and when, in this example should the pathogens grow?
Until now I considered ready to eat sandwiches, meal salads, not fully cooked/pasteurised meals (e.g. with one or more raw components), raw meat for direct consumption (filet americain, carpaccio, etc.) raw fish for direct consumption, etc. as high risk products. I have to change my way of thinking regarding to high care/ high risk and with me a lot of auditors in the Netherlands/Belgium.

[Ken]

I think it is the other way: Why forcing manufacturers for big investments, where it is not needed?

..... I have to change my way of thinking regarding to high care/ high risk and with me a lot of auditors in the Netherlands/Belgium.

I contribute to another group on 'Linkedin' and sent a message to BRC about the late arrival of the guidance notes:

'Sorry BRC but this is poor planning. BRC should be allowing sufficient time to ensure that guidelines and standards are published well before the audis are due to take place. Auditing to version 6 of the standard from July onwards would have been far more realistic and allow the proper training of auditors and familiarisation of the changes by auditees. We now have a situation of audits starting in Jan 2012 in the absence of clear interpretation guidelines - without this there cannot be proper training of auditors or good preparation by auditees'

Received the following response:

'Thank you for your feedback Ken. I have notified the Technical Director at BRC Global Standards, who will be in touch. Unfortunately the Guidelines take a substantial amount of time longer to write than the Standard and can only begin once that's finalised....'

My response to that was:

.........You are right that the guidelines do take a substantial amount of time to write after agreement of the standard. From other newsgroups, the main issue appears to be the 'Production Zone Decision Tree' which is ambiguous and guidance on this is essential for auditors and auditees as the there could be significant financial /investment implications for some existing BRC certificated companies. We need to make sure that the implied changes was the intention of those reviewing the standards and that auditors are confident in the interpretation of this - some feedback I have already received, suggests that some are not. (Despite this I still believe that the latest version is a significant improvement but the timing needs a rethink and in my opinion, the guidance must be available before audits to version 6 start)

I don't expect anything further until after the near year when people are back from holiday - but at least the concern is going to the right place.

Ken

[Ken]

I don't expect anything further until after the near year when people are back from holiday - but at least the concern is going to the right place.

Ken

Quicker than I thought but here is the official response - not sure I share their confidence though!

'To make you aware, there are numerous training courses providing information to sites run both by certification bodies and by the BRC.The BRC also provide an e-mail contact via the website or brcglobalstandards@brc.org.uk, and respond directly to any questions about interpretation of the Standard. Most other standard owners do not publish guidelines for their Standards and whilst we are pleased that these are valued these are not essential for preparation for Issue 6.

We have an international team of Trainers responsible for auditor training. All trainers have been trained by the BRC and trainers have to pass an exam before being allowed to undertake training. Most auditors have now been trained and there is emphasis on the production zones within the training. If following training auditors are still not clear about the high risk high care areas then this should be discussed with the trainer.

The Standard itself includes both the decision tree and a guideline to assist in interpretation. The emphasis of Issue 6 is on practical implementation of food safety and not increasing documentation and the emphasis of the audit has changed to ensure at least half of the audit time is spent in the factory and less time is spent reviewing documentation in the office.

Please don't hesitate to contact the BRC with any of your questions, at brcglobalstandards@brc.org.uk - you will get a reply shortly after. Please note, the BRC offices are closed for the holiday and reopens Tues 3rd Jan.'

[GMO]

Exactly! just like you,I would say cold smoked fish is of higher risk as warm smoked fish. However, according the descision tree provided, the warm smoked fish is high risk and the cold smoked fish is high care. It is opposite of what I expect.
Another example: decision tree gives high risk for fully cooked ham and high care for filet americain (I do not know if this product is known in the UK. It is steak tartare with spices and sauce and is eaten without heating on sandwiches or toast). I would suspect it other way around and this really confused me.

I think this is a confusion between what they mean by "high risk" and "high care". Your examples make perfect sense to me.

High risk is when you try as far as you can to eliminate microbiological risk. High care products don't have that risk eliminated, they are simply reducing the risks as far as they possibly can with the kind of product it is. High risk involves fully cooking things into an area, high care often involves things like washing vegetables into an area. IMO pregnant women should be advised not to eat any foods produced in an high care area including preprepared sandwiches, salads, ready meals with raw herbs, smoked salmon etc, etc. Bizarrely in the UK though pregnant women are only advised not to eat certain foods from these categories. Go figure!

If you look at p117 of the standard, BRC have put in a definintion of high risk and high care which might help.

Thanks for the posts Ken. I'm also very concerned on interpretation, particularly the 4 hourly checking of fridges when we fully cook everything which comes out of them. Thanks for the email address though. We will be pestering them in the two months until our audit. Eeeek!

I will certainly be challenging anything I believe to be an interpretation issue.

[QSDA]

Sorry to join in so late with this topic.

Am I missing something here, surely the standard should be written so that it does not need further interpretation, is it not the standard that we are auditted against not some nebulous interpretation. I also note that this additional document is charged for.

I have had non-conformaces which are against the interpretation document for issue 5, where the auditor agreed we were compliant with the standard but not the interpretation!


QSDA

[GMO]

Sorry to join in so late with this topic.

Am I missing something here, surely the standard should be written so that it does not need further interpretation, is it not the standard that we are auditted against not some nebulous interpretation. I also note that this additional document is charged for.

I have had non-conformaces which are against the interpretation document for issue 5, where the auditor agreed we were compliant with the standard but not the interpretation!


QSDA

I agree but I think the problem comes that it's a few people locked away in a room who come up with a standard and even putting it out to consultation will not capture every ambiguity. Once thousands of auditors, sites etc all get their hands on it, then the minutae gets examined.

As for the non conformance against the interpretation document? That's ridiculous. I could understand it if you could argue either way in the original standard and the guidance clarifies it but if the guidance has a different meaning, that's blooming ridiculous.

What I want to know is once the guidance document is published, if it becomes apparent some of the non conformities were incorrect, what then? Do you have grounds for appeal even if it's months later?

[Ken]

I agree but I think the problem comes that it's a few people locked away in a room who come up with a standard and even putting it out to consultation will not capture every ambiguity. Once thousands of auditors, sites etc all get their hands on it, then the minutae gets examined.

As for the non conformance against the interpretation document? That's ridiculous. I could understand it if you could argue either way in the original standard and the guidance clarifies it but if the guidance has a different meaning, that's blooming ridiculous.

What I want to know is once the guidance document is published, if it becomes apparent some of the non conformities were incorrect, what then? Do you have grounds for appeal even if it's months later?

Agreed, your auditor was incorrect - if you meet the requirements of the standard, then no non conformance can be raised. Guidance is exactly what it says in the name - it is there to guide the auditor and auditee in the interpretation of how you can meet the standard, if you choose a different way then the auditor cannot raise a non conformance providing you meet the standard. (As a separate issue, lets not forget that the purpose of a close out meeting is to AGREE non conformances against the standard. If i don't agree, I say so and give my reasons - my experience to date is that proving a logical reasonable explanation and objective evidence is given, I don't have any problems - it is often just a misinterpretation of information during the audit)

Going back to the issue of the 'Production Zone Decision Tree', version 6 of the standard clearly says that 'Reference shall be made to more detailed examinations of production zones in the guideline'. The guidelines have not been published but the auditors have been 'fully trained' (according to the BRC) and the auditee don't need any more information to meet the requirements of the standard (again according to BRC)!

I have concerns in that the decision tree is technically incomplete and ambiguous, specifically about 'high care' and 'high risk' where the distinction between chilled and frozen is not as clear as it first appears e.g there is no potential for growth of pathogens such as Listeria in a frozen ready to eat product whereas there is for an identical product which is distributed and sold chilled. This potentially puts a company previous considered 'high care' into 'high risk' who then has to consider substantial unplanned investment to meet all the high risk requirements such as filtered air or face a major non conformity in their audit and the commercial implications of this.

The BRC standard requires a company to complete a risk assessment through haccp and at the same time is telling the company the outcome of this risk assessment - possibly unintended but illogical.

I have a customer who faces this possibility, one CB I spoke to at a training session said they are not sure whether the company would be 'high care' (as it is now) or high risk (but anticipating that the guidance will assist in the interpretation) . My customers own CB wasn't able to give an answer and 2 months later has still not provided an answer despite reminders!

Off my soapbox now but I genuinely believe that this will cause problems for auditors and auditees in some (but not all) situations and was looking to the guidance to help in the interpretation.

Happy New Year everyone!

[Jens Therkelsen]

My company produces frozen ready made meals. We have been BRC certified since 2004 – grade A the last 3 years & IFS Higher Level. We had our last audit in October where we only had 4 minor NC’s. If we were audited to day we would fail big time because of this new decision tree.
Some background details:

Our products are heat treated, frozen (IQF) and packed. Our average microbiological standards are TVC < 1000 CFU/g, Coliforme <100 CFU/g no E-coli, no pathogens and so on… Based upon this fact our cooking instructions are designed so that the consumers obtain the most crisp surface as possible and not based upon obtaining the mentioned 700C for 2 minutes.

Following the decision tree we end up in the High Risk Area category. We cannot go that way due to the very stringent demands concerning High Risk Areas (lay out of drain systems, staff facilities and so on). The cost for rebuilding the plant would be more than 500.000 EUR…

This made me thinking - how can we avoid to rebuild the plant?

The answer is quit simple. We need to change our cooking instructions so that they will be based upon obtaining 700C for 2 minutes or a similar thermal equivalent.

So now we “only” need to test all our different product categories (100+) and redesign all our packaging material. The cost for this will be around 50.000 EUR and will this ensure our consumers a more safe product?

NO, our products were safe to begin with and they still are but we will have to use a lot of money if we want to continue to have our BRC certificate.

I know that all systems are undergoing a continues improvement but to my opinion have this new requirement not been considered thoroughly enough…

regards

[gcse-fhp]

So now we “only” need to test all our different product categories (100+) and redesign all our packaging material. The cost for this will be around 50.000 EUR and will this ensure our consumers a more safe product?

NO, our products were safe to begin with and they still are but we will have to use a lot of money if we want to continue to have our BRC certificate.

I know that all systems are undergoing a continues improvement but to my opinion have this new requirement not been considered thoroughly enough…

regards

Hi Jens,
This is quite an enigma, isn't it? Are more stringent and costly standards with little or no food safety assurance returns the answer? I know that the BRC and other similar standards are very useful to the industry. This begs the question: Can the stringency of these standards and the current auditing structure be re-evaluated and re-directed in a way that optimizes their usefulness rather than to cause what appears to be grief to those who must use them? I think this is possible.

The industry, from Farm to Fork, needs to do things that are radically different from what is being done today. First of all the focus needs to be right and the effort needs to be a joint one. Until this is the case, the industry worldwide will continue to be perplexed and plundered by its current ineffectiveness (numerous outbreaks) and inefficiencies (costly systems with little or no returns).

gcse-fhp

Edited by gcse-fhp, 10 January 2012 - 03:36 PM.

[Ken]

Jens

I was critical of this on the 'Official BRC GLobal Standards Group on LInkedin' - topic has since been deleted by BRC!

The points I raised and their response are still on this topic above.

Suggest you take BRC up on their offer and e-mail them direct at: brcglobalstandards@brc.org.uk

One point raised by one of my clients was which definition of high risk in the standard do you use!

The Glossary in appendix 9 on page 117 defines a high risk product is: “a chilled ready to eat / heat product”

Appendix 2 on page 96, section 2.3 defines defines one of the criteria for high risk products as 'requires chilling or freezing'. However, it also says 'potentially vulnerable to the growth of pathogens, particularly Listeria species'. If a product is frozen, it doesn't fit the criteria for high risk product. The wording in section 2.3 looks OK ....problem is this isn't reflected in the production zone decision tree.........confused!!!

Ken

[Charles.C]

Dear Jens Therkelsen / All,

Our products are heat treated, frozen (IQF) and packed. Our average microbiological standards are TVC < 1000 CFU/g, Coliforme <100 CFU/g no E-coli, no pathogens and so on… Based upon this fact our cooking instructions are designed so that the consumers obtain the most crisp surface as possible and not based upon obtaining the mentioned 700C for 2 minutes.

You do not mention yr actual products / process but for a RTE finished product, the above text seems to have a (scarily) limited microbiological meaning. The primary objective is usually food safety, not crispiness. Unless you mean your process is validatably equivalent or exceeds the 6D objective.

Regarding risk/care tree, I get the impression (haven't studied standard) that the specific “spanners in the works” are BRC’s introduction of a new (more stringent) decision procedure both in scope / associated process requirements (notably construction) for certain risk categories.

As far as ambiguities are concerned, surely the scientific issue comes down to the ability of BRC to validate their requirements with respect to food safety. Or is that too simplistic ? I recall that some "official" (EC publications) on these issues do also exist.

I’m afraid that it is wishful thinking that any standard is not going to have ambiguities and debatable interpretations. I am less sure as to where the strict responsibility lies for auditors to be competent to evaluate a factory against a given standard. A shared function ? Presumably the auditee’s expectation will not be ambiguous. BRC’s own opinion (fairly or otherwise) is apparently defined by an earlier post and appears somewhat escapist. Maybe they are now regretting their (innovatory?) publishing of guideline documents.

Rgds / Charles.C

[Madam A. D-tor]

For all members, which do not have seen the decision tree yet, I have attached it to this post.
It is an extract from the draft version, which was freely available on the BRC website.
If I do break some copyright rules, please delete this post immediately.
 decision tree.pdf   154.91KB   209 downloads

[Madam A. D-tor]

The answer is quit simple. We need to change our cooking instructions so that they will be based upon obtaining 700C for 2 minutes or a similar thermal equivalent.

Dear Jens,

i disagree with you. if i were your auditor, you would not come away with this change for the following reason:
1) if your product is intended to be heated in microwave, there is no way you can guarentee that the consumer will follow the instructions correctly and the product will be heated 2 minutes above 70 C.
2) this will definitely change your product in taste, and mouth sense. you probably get more complaints regarding these issues.
3) your product will still be needing high care areas and this is probably also an investment.

But if I was your audit, I also would agree with you that your product probably does not need high risk/high care area.



Please, can you tell me more about your products. Are it IQF frozen blocks in a bag or box or are these pasteurised meals, which were pasteurised in the consumer package?