7 replies to this topic

[Dairy]

Hi All
This is my first post - likely of many! I wanted to enquire as to how others are managing the new BRC Rev6 requirement for High risk areas (4.8.5) to have dedicated area shoes. While this is not an issue for employees it will be an issue for contractors/visitors to areas. I see in BRC's FAQ document that they are adamant about the requirement. Do you think that some thing like this would be acceptable:
They are rubber soled, cotton topped and supplied by our laundry contractor to pharma and med device company's so one would imagine that they should be sufficient. I've also posed the query to BRC so hopefully they will get back soon.
As I'm writing - does anyone have any comment on the term "Commercially Sterile" detailed in clause 7.4.4 of the BRC standard?

[GMO]

Personally I wouldn't agree with using them in high risk. They may be posh overshoes but that's basically what they are. IMO why not have some additional wellies for visitors?

As a guideline, IME of high risk, footwear is normally wellies because they are easy to clean and high risk tends to have a lot of wet cleaning. How will you clean something with a fabric upper?

I would suggest pharmaceutical companies might think these are acceptable because their processes are more dry?

[Dairy]

Thanks for your comment - I should have explained our process is dry - dry powders, dry cleaning via vacuum etc. Does this change your opinion?

[GMO]

I'd be interested on how you'd identified your area as high risk? If it's high risk it undergoes a heat process equivalent to 70 degrees for 2 mins right? But can also support the growth of pathogens if present yes? So what is the powder?

If dry cleaning is acceptable in your process, I have big doubts it's really high risk.

[Dairy]

I'd be interested on how you'd identified your area as high risk? If it's high risk it undergoes a heat process equivalent to 70 degrees for 2 mins right? But can also support the growth of pathogens if present yes? So what is the powder?

If dry cleaning is acceptable in your process, I have big doubts it's really high risk.

GMO I really value your insight - we followed the Decision Tree detailed within BRC pg 97. We manufacture a variety of milk powders and also have a butter plant. I'm pretty new to this industry having spent all my working life in pharma and to me I personally find it strange that we have come up with this decision but I'm still learning and definately willing to listen to logic and make changes. I've done a little research and the Aw values of all of our powders would put them outside of the range that would support microbial pathogen growth (according to lit searchs I have done) so IMO we could say "no" at decision step 2 and make bag off areas low risk. The area could potentially be considered low risk but we would have to meet "High Care" garbing requirements to keep our customers happy.. Dry cleaning in the powder bag off areas works well and environmental monitoring shows no problems - we definately do not want to add moisture to the area.

The butter area is another story - I can't see any other categorisation other than "High Risk" - It doesn't undergo any further cooking and naturally is subject to pasteurisation - we are introducing wellies for visitors in this area and new area specific overcoats.

[GMO]

GMO I really value your insight - we followed the Decision Tree detailed within BRC pg 97. We manufacture a variety of milk powders and also have a butter plant. I'm pretty new to this industry having spent all my working life in pharma and to me I personally find it strange that we have come up with this decision but I'm still learning and definately willing to listen to logic and make changes. I've done a little research and the Aw values of all of our powders would put them outside of the range that would support microbial pathogen growth (according to lit searchs I have done) so IMO we could say "no" at decision step 2 and make bag off areas low risk. The area could potentially be considered low risk but we would have to meet "High Care" garbing requirements to keep our customers happy.. Dry cleaning in the powder bag off areas works well and environmental monitoring shows no problems - we definately do not want to add moisture to the area.

The butter area is another story - I can't see any other categorisation other than "High Risk" - It doesn't undergo any further cooking and naturally is subject to pasteurisation - we are introducing wellies for visitors in this area and new area specific overcoats.

But hang on, does butter support pathogen growth? I don't think so? Having visited a butter plant, I can tell you at least one big manufacturer doesn't think it's high risk or high care!

With the powder as well, is the process not enclosed? Could it not be an enclosed product area?

IMO there are differences in what your customer wants and what BRC thinks is necessary. Customers are wrong sometimes. I think you're going to give yourself major headaches here. I would suggest you assign the area as low risk for BRC and write a procedure just for BRC stating that it is low risk (or enclosed) by their criteria but additional controls have been put in place as requested by your customers.

[Charles.C]

Dear Dairy,

By focusing on this area, BRC have intruded into a (historically/geographically) vexed area of terminologies and interpretations. The current round of audits may soon reveal the degree of vexedness. Personally, I have always tended to the opinion that any retail RTE food is automatically “high risk” for “consumption-based” reasons, if nothing else. And the process which goes with it. Such views are now clearly obsolete.

I presume yr milk product is shelf stable.

You might find it interesting to search/review the extended discussions here on two other products submitted (retorted pouch goods/(?)). Both were manufacturer declared (ambient) shelf stable which seemed to evaluate as low risk / BRC context. One major query (to my eyes) was as to the (BRC?) logic of making this assessment seemingly cover the whole production facility.

As previous post, the question for butter will presumably be the significance of storing “chilled’ in the context of safety/non-safety. A sort of related discussion recently came up here regarding the use of MAP for chilled frozen goods. Concluded non-safety therefore not in (traditional) haccp scope. So presumably BRC low risk ? I predict such conclusions will not gel with a lot of other opinions.

Another thread here already duplicated yr comment re. customer/brc with respect to “high care” evaluations. More compromises on the way presumably.

Soon to be a BRC guidelines feature no doubt.

Rgds / Charles.C

[Dairy]

~Thanks for all the insights! I'm going back to the drawing board!