5 replies to this topic

[NasreenU]

the BRC version 6 issue mentions the aspect on defining production risk zones.

Our company refines edible oils. Our refining stage is a completely closed area from the receiving of the crude oil straight to dispatching. Oil is received via tankers and transferred via pipes in to production tanks, storage tanks etc hence it will fall under enclosed product area. There is no physical contact with the oil except at the last stage but this is monitored as it is a CCP of our HACCP study. We do use our raw materials such as Citric Acid, TBHQ etc during the refining stage but this gets added to the tanks. My question is: Do I consider that at point of addition of raw materials into the tanks as a risk zone and if my CCP has already been risk assessed do I need to indicate it that it is high risk?. How do you show on your process flow the Low/high-care/high risk area?

[GMO]

the BRC version 6 issue mentions the aspect on defining production risk zones.

Our company refines edible oils. Our refining stage is a completely closed area from the receiving of the crude oil straight to dispatching. Oil is received via tankers and transferred via pipes in to production tanks, storage tanks etc hence it will fall under enclosed product area. There is no physical contact with the oil except at the last stage but this is monitored as it is a CCP of our HACCP study. We do use our raw materials such as Citric Acid, TBHQ etc during the refining stage but this gets added to the tanks. My question is: Do I consider that at point of addition of raw materials into the tanks as a risk zone and if my CCP has already been risk assessed do I need to indicate it that it is high risk?. How do you show on your process flow the Low/high-care/high risk area?

I don't think any of your process is high risk because it would not support the growth of pathogens unless stored chilled or frozen so there's your first answer.

Secondly I think you've rightly identified the majority of your production line as an enclosed product area. The FAQ document has an interesting question which applies to this area:

http://www.brcglobal...2 11 1 12.docx

The comments on section 4.3.1 They refer to milk which would be a high risk product but that's a more extreme case than your considerations. Basically they say you need "additional precautions" when breaking into any of the lines and equipment for maintenance and I would adopt the same here but I would say when you break in or add ingredients it effectively becomes Low Risk.

So for your process flow where there are points you break in to the pipes, like adding ingredients I would highlight these in a different colour e.g. blue and have some key on the document. I'd also have a procedure for when maintenance or hygiene have to access the pipes.

As I understand it what you'd have to do then is make sure when you do access into the enclosed system you are following all of the low risk rules but when you don't you can follow the enclosed product rules. BUT, it might be easier to get everyone to follow the low risk rules all of the time to keep things simple.

[Charles.C]

Dear Nasreen,

My question is: Do I consider that at point of addition of raw materials into the tanks as a risk zone and if my CCP has already been risk assessed do I need to indicate it that it is high risk?.

It would hv usually been required in haccp to (already) risk assess (ie within the hazard analysis) any component input stages at the same time you decided on yr final CCPs ?? The method of assessment varies of course.

I deduce from yr post that you only have 1 CCP. What process activity was the CCP which you mention? IMEX, it is rather unusual for the last step to take this status, unless perhaps a metal detector or coding related ?.

Slight OT -

There is seemingly, to me, some kind of potential semantic collision that a production line may contain a haccp-determined "high risk" step (eg a CCP) although the complete production line is (BRC) zonally-classified as low risk. I am rather confused over this.

I also do not approve of the, IMO, likely interpretation of the BRC definition of "low risk area" that procedures like cooking diminish the importance of hygiene control of preceding process steps.

Rgds / Charles.C

[D-D]

We have similar products. Mostly they are handled in pipework and vessels though may also be moved around in drums and other containers. I have therefore prepared area diagrams showing the equipment layout and colour coded them so the entire area is "Enclosed Product Areas" and then I have put a different coloured spot to mark the points where they are filtered and packed off to designate "Low Risk Areas". I am hoping that is going to be sufficient.

[GMO]

Dear Nasreen,



It would hv usually been required in haccp to (already) risk assess (ie within the hazard analysis) any component input stages at the same time you decided on yr final CCPs ?? The method of assessment varies of course.

I deduce from yr post that you only have 1 CCP. What process activity was the CCP which you mention? IMEX, it is rather unusual for the last step to take this status, unless perhaps a metal detector or coding related ?.

Slight OT -

There is seemingly, to me, some kind of potential semantic collision that a production line may contain a haccp-determined "high risk" step (eg a CCP) although the complete production line is (BRC) zonally-classified as low risk. I am rather confused over this.

I also do not approve of the, IMO, likely interpretation of the BRC definition of "low risk area" that procedures like cooking diminish the importance of hygiene control of preceding process steps.

Rgds / Charles.C

I think when you've worked in chilled food high care and high risk areas, there is no confusion. The Chilled Food Association has been using the terms "high risk" and "high care" for some time and they are well understood in the industries where they are used. Just because an area is "low risk" does not make it no risk. The zoning is mainly around microbiological risks. I honestly don't see why people are getting into such a tizz about all of this. I agree there could be some confusion in the industries where there is a cross over, e.g. cheese packing but I don't think there could be any confusion here.

We talk about "risk" all the time in food, not just in food safety but in health and safety. Just because it's the same word, I don't see why people should get confused. I give people a bit more credit and intelligence than that.

[NasreenU]

Hi Charles.C

We have four different stages for refining of oils. All stages have undergone a risk assessment/hazard analysis. The CCP1 is in the last stage of deodorising as it is this point where we come into physical contact with the oil (polishing filter for foreign body) prior to this step the oil is subjected to high temp of about >250 degrees. So all raw materials used such as antioxidants, bleaching earth etc occurs in the first three stages of refining. hjowever the hazard analysis was done prior to the BRC v6 however with this new version I am quite confused on the whole low risk and enclosed production area.

Dear Nasreen,



It would hv usually been required in haccp to (already) risk assess (ie within the hazard analysis) any component input stages at the same time you decided on yr final CCPs ?? The method of assessment varies of course.

I deduce from yr post that you only have 1 CCP. What process activity was the CCP which you mention? IMEX, it is rather unusual for the last step to take this status, unless perhaps a metal detector or coding related ?.

Slight OT -

There is seemingly, to me, some kind of potential semantic collision that a production line may contain a haccp-determined "high risk" step (eg a CCP) although the complete production line is (BRC) zonally-classified as low risk. I am rather confused over this.

I also do not approve of the, IMO, likely interpretation of the BRC definition of "low risk area" that procedures like cooking diminish the importance of hygiene control of preceding process steps.

Rgds / Charles.C