Captive foot wear program non-existent
Hello all,
This is my second post. At my facility where I am attempting for the first time to get things in alignment with BRC standards, there is currently no captive foot wear program. All indications being we will not be initiating such a program either. We do have High and Low risk areas. All other BRC requirements revolving around protective clothing are satisfactory to the Standard. Workers wear their own shoes and we have foot foamers (on timers spraying a foaming sanitizer) at every entry point to the production area. We do not have adequate facilities to provide a captive foot wear program. Should I attempt to justify through risk analysis, the absence of this program and use of foaming sanitizing devises as "our" way of addressing the issue?
I appreciate everybody's time and help with this matter,
Sincerely,
Alex Duckworth
The Standard clearly says; Clause 4.8.5 - Dedicated Footwear shall be provided to be worn in the high-risk area and Clause 4.3.6 - There shall be physical segregation between high-risk and other parts of the site. I can tell you we had to spend a little over $100,000.00 to get our boot room up to par, purchase boots, boot racks and a new boot wash machine. We use the Boot wash as the segregation between high risk room and boot room. I believe you could risk assess the washing and segregation issue, just make sure you do a lot of micro test and I mean a lot and you will need to show that there is always foam at each entrance. You should also have a very good back up plan if the foamers stop working (bucket with chemical and a brush) I'm not so sure you can risk assess the high risk dedicated footwear issue. The high risk boot should never go outside or any other unauthorized place for that matter. Hopefully someone with a lot more BRC knowledge can help with that.
I think a risk assessment may be pointless here. The objective of food safety is to reduce the risk of hazards to an acceptable level. A risk assessment which cuts across the obvious logic of a dedicated footwear setup will only open a debate with the auditor and pressure on you to 'prove' that a replacement control system achieves the same level of protection. Ultimately it will come down to the auditors assessment and I suspect he/she will not run with it. The fact you have high and low risk separation is evidence enough to an auditor that dedicated foot wear is also required, otherwise why introduce separation in the first place.
Good luck with your audit, in the end if resources are slow coming you may just have to run with it in order to get the non-conformance and action it afterwards. Just make sure your superiors are clearly informed of this perspective in advance of the audit and when you go knocking on their door in the future looking for resources for other issues - you may find they simply take your word for it :)
George
Hi
I'm afraid a risk analysis will not be of help with this clause.
Where a clause says "should" you can use a risk analysis to justify why you don't need to meet the exact requirements.
But where a clause says "shall" it means you have to meet the requirements as set out in the clause.
Instead of "shall' read "must"
rdgs
Proving -"Micro-testing" shoes would be acceptable by auditors?