11 replies to this topic

[gregi86]

Hi there,

 

I am looking for a professional advice here with pointing out to BRC Food Safety standards booklet / official literature please....

 

We have had an unanounced BRC audit at our company.

 

The auditor has found in our main engineers workshop a milk in a cupboard where were teas and coffees stored. He has said that because the milk was not refrigerated we / engineers could contaninate food production areas and marked it as a minor non conformance. Of course our technical department has overreacted and banned all teas and coffees in there. After discussions only one type of tea and one type of coffee was allowed and no sweets....

 

I can understand the issue with milk not being refrigerated which could have been easily resolved as use powdered milk end off....

 

My questions are:

 

1. Is there a standard / rule / requirement how many separations (doors, curtains) are required between areas where eating can be allowed (ie. sweets and being allowed to have as many types of non alcoholic drinks i.e. juice, coffe & tea of own choice as wanted)...?
2. what is classed as a production area??? Are corridors classed as production area? I.e. from our workshops changing room you are entering a part of warehouse/corridor...  Could this be classed as a further separation?
3. how could we oppose to an auditor like this in a professional manner so he cannot do us for something else just for the sake of it?

 

Many thanks for all your advice and comments, looking forward to it.

 

Regards

[Snookie]

Hi Greg,

 

  to the forum.  While I am not an expert on BRC, based on your processes and what your making would most likely determine whether this is a problem or not.  Unrefrigerated milk is definitely not good and a health safety risk at least to the employee, but the tea and coffee could be a risk to your product as well.  A risk assessment based on your environment, your product and your processes would need to be done to determine if it is acceptable for these items to used outside of a break room.  The risk assessment is what would show the auditor that it is acceptable. 

Edited by Snookie, 16 January 2015 - 10:36 PM.

[mgourley]

This is the thing about BRC that drives me nuts. I get it that sugary beverages in an office trashcan (bin) MIGHT be a pest attractant. How often are the trashcans emptied (risk assessment). Is it a risk to your product if a line supervisor enjoys a coffee with sugar in his/her enclosed office in a production area?

Should we just retrofit all manufacturing facilities to include hermetically sealed bubbles where NO possibility of ANY bad things have NO POSSIBILITY of occurring?

 

At a previous job, anything that was not "water in a sealed and properly labeled" container was banned from use in process area offices or transport through production areas. 

 

I can't find a single thing in Issue 6 or 7 that requires this.

 

Marshall

[mgourley]

Sorry for the rant, but the auditor does have a point. Is milk listed as an allergen at your facility?

If your products do not contain milk, what controls do you have in place to ensure that the milk in the shop does not make it's way into your product?

 

Back in the day, i used to really like my own small fridge and microwave, in my office, well away from the production line.

 

Marshall

[gregi86]

Sorry for the rant, but the auditor does have a point. Is milk listed as an allergen at your facility?

If your products do not contain milk, what controls do you have in place to ensure that the milk in the shop does not make it's way into your product?

 

Back in the day, i used to really like my own small fridge and microwave, in my office, well away from the production line.

 

Marshall

 

Sorry for the rant, but the auditor does have a point. Is milk listed as an allergen at your facility?

If your products do not contain milk, what controls do you have in place to ensure that the milk in the shop does not make it's way into your product?

 

Back in the day, i used to really like my own small fridge and microwave, in my office, well away from the production line.

 

Marshall

 

 

This is the thing about BRC that drives me nuts. I get it that sugary beverages in an office trashcan (bin) MIGHT be a pest attractant. How often are the trashcans emptied (risk assessment). Is it a risk to your product if a line supervisor enjoys a coffee with sugar in his/her enclosed office in a production area?

Should we just retrofit all manufacturing facilities to include hermetically sealed bubbles where NO possibility of ANY bad things have NO POSSIBILITY of occurring?

 

At a previous job, anything that was not "water in a sealed and properly labeled" container was banned from use in process area offices or transport through production areas. 

 

I can't find a single thing in Issue 6 or 7 that requires this.

 

Marshall

 

 

Hi Greg,

 

  to the forum.  While I am not an expert on BRC, based on your processes and what your making would most likely determine whether this is a problem or not.  Unrefrigerated milk is definitely not good and a health safety risk at least to the employee, but the tea and coffee could be a risk to your product as well.  A risk assessment based on your environment, your product and your processes would need to be done to determine if it is acceptable for these items to used outside of a break room.  The risk assessment is what would show the auditor that it is acceptable. 

 

Thank you all for taking a time and replying to my questions.

 

I have to say that the risk assessment was and is not in place. This will be probably the first thing we will look at.

 

To answer your concerns snooky milk is not listed as an allergent as it is used in low risk as wel as in hi risk areas.

 

The auditor was looking at the worst case scenario rather than reasonably forseable out come.

[Charles.C]

Dear greigi,

 

Bit difficult to comment because product/process/layout unknown.

 

If a low risk process area*, drinks confined to room, and no direct interface between workshop and production area I would say nitpicking.*

 

(1) afaik (not studied v7) – NO. It always theoretically comes back to risk assessment / cross-contamination. Sec. 4.3 (v6) acts as a generic catch-all for audit purposes.

 

IMEX, a room where food is consumed  should have no direct interface to any production area. The usual first subversions are from  the Production Manager and Engineers.

 

Having said all the above, it is by no means unheard of to see a communal water fountain close to a production area entry curtain for the benefit of workers. And be routinely ignored by auditors to the disgust of,  forever complaining, QA personnel.

 

(2) Areas traversed by Product (the arrival/exit areas may be somewhat ambiguous).

(3) Elaborated thread 24241.

 

* just noticed HR/LR areas comment previous post. This complicates the analysis.

 

Rgds / Charles.C

[Simon]

If there is a communal canteen available personally I would have no eating or drinking in any factory / warehouse work area or joining manager office.

For one it is clear and easier to manage and because it is "fair" it is culturally positive.

 

If engineers can drink tea and coffee no doubt the odd biscuit creeps in and maybe a sandwich...

 

From a health & safety POV you should not eat or drink with dirty / oily hands.

[Jeffrey Ort]

This is a common issue and almost always an issue in facilities.
The maintenance area, senior management offices, managers all think that the rules do not apply, even ownership.
Do you state that there is no eating, drinking, gum chewing or spitting (yes) in any area other than a cafeteria?
Do your mechanics/maintenance follow all the GMP's, od they have segregated and sanitized tools?

These are items for thought!

[trubertq]

Blanket ban on eating and drinking anywhere, other than the canteen... makes life easier  for everyone.

[FBQFS01]

we had sort of the same minor at a BRC audit once. The auditor found a piece of fruit in the technical department and stated that the technisians had acces to the factory, thus possible contamination = minor.

We banned all food from the factory including the technical department, since this is a separate room in the factory.

[Madam A. D-tor]

we had sort of the same minor at a BRC audit once. The auditor found a piece of fruit in the technical department and stated that the technisians had acces to the factory, thus possible contamination = minor.

We banned all food from the factory including the technical department, since this is a separate room in the factory.

 

 

Blanket ban on eating and drinking anywhere, other than the canteen... makes life easier  for everyone.

 

 

If there is a communal canteen available personally I would have no eating or drinking in any factory / warehouse work area or joining manager office.

For one it is clear and easier to manage and because it is "fair" it is culturally positive.

 

If engineers can drink tea and coffee no doubt the odd biscuit creeps in and maybe a sandwich...

 

From a health & safety POV you should not eat or drink with dirty / oily hands.

 

As an auditor myself I would indeed raise this as a minor non conformity based on the same issues that are posted by Simon, Trubertq and FBQF S01.

It is so much easier to have simple rules for all of your staff, rather they are in enclosed product areas, maintenance rooms or offices.

Probably there is no exact requirement in the BRC requiring this, but I would write it on the adaption of hygiene standards by all workers (iss 7: 7.2.1)

 

For the non refrigerated milk, I would raise a minor against iss 7: 4.8.10(catering facilities do not contain risk) or 4.8.9 (food brought to site, properly stored).

 

Then, on the other hand, this has no much focus for me and I think a lot of my clients have coffee/tea facilities in their maintenance rooms. Sometimes even offering me the most luxurious coffees from expensive machines placed in the maintenance offices that taste better than the coffee in the canteen.

Hmm! This might be a risk itself, before you know it, production staff is hiding and drinking coffee in the maintenance room.

[djammur]

As long as there are 4 walls and a door, with hand washing facilities you can allow food in the area