I asked for some advice from BRC on the following (copied from my original mail):
Section 5.2.8 - equipment or area cleaning procedures shall be designed to remove or reduce to acceptable levels any potential cross contamination by allergens. The cleaning methods shall be validated. How can I validate this in a bakery? We can't use general all purpose "allergen" swabs because we are a bakery and so all of our products contain wheat and gluten. We also cannot have a dedicated set of mixers, trays or a dedicated oven. Much of our equipment is not designed to be wet cleaned (as it isn't in any bakery because otherwise it would damage the surface causing a foreign body issue.) I'd welcome any ideas!
This is the response:
5.2.8 – This clause is applicable to those products that do not contain an allergen or where an allergen is used intermittently. For example, if you were making gluten free bread having been making bread containing gluten, then you would need to clean down equipment. Alternatively if you were using egg or milk in any of the products then you would also need to perform a full clean in order to ensure that no proteinaceous materials were present.
So he's completely ignored my question for one which was "how" and completely tried to kill the UK baking industry. This means every time we use an improver containing a very small percentage of egg, milk or soya and then move to a product which does not contain any of these allergens, I have to do a FULL CLEAN, yes, you read it right, A FULL CLEAN before changing over.
So presumably I need to ensure the mixers, dividers, moulders, trays, ovens... That's about 3 hours work between each batch. Now, hang on, some of these items can only be dry cleaned! Oh joy! Also what about the risk of using wet cleaning with open product nearby? I would argue there is a tiny risk of carry over of an allergen from simply clearing down the machine (we don't use nuts or sesame btw) but a huge risk of chemical contamination if they get out the cleaning stuff!
I've been very pro BRC in the past but this stuff is just ridiculous. Don't get me started on the idiotic response on my questions on chiller monitoring.
Edited by GMO, 09 January 2012 - 12:16 PM.