6 replies to this topic

[jtang]

What is considered 'enclosed product areas'?

 

1) If left over ingredient is used in production, and it is then folded up, covered, within production area, before it is returned to the warehouse, can the warehouse be considered enclosed product areas?

 

2) What about staging areas? The shrink wrap is removed, potentially taping can be removed, but the ingredients are not yet taken out of packaging.

 

If it is only considered as "enclosed" when product is completely sealed in a case (ie. if product are individually wrapped, and then placed in a case), are we still able to divide the warehouse into areas that is "low risk" vs "enclosed product areas"?

 

 

 

[Tony-C]

Hi Jtang,

 

Yes a warehouse can be considered an enclosed product area:

 

 BRC Global Standard for Food Safety Issue 7 UK Free PDF Unlocked_098.jpg   166.89KB   2 downloads

 

 BRC Global Standard for Food Safety Issue 7 UK Free PDF Unlocked_099.jpg   182.79KB   2 downloads

 

BRC Global Standard for Food Safety Issue 7

4.3.1 There shall be a map of the site which designates areas (zones) where product is at different levels of risk from contamination; that is:
• high-risk areas
• high-care areas
• ambient high-care areas
• low-risk areas
• enclosed product areas
• non-product areas.
See Appendix 2 for guidelines on defining the production risk zones.
This zoning shall be taken into account when determining the prerequisite programmes for the particular areas of the site.

ENCLOSED PRODUCT AREAS
An enclosed product area is defined as an area of the factory where all of the products are fully enclosed and therefore not vulnerable to environmental contamination (e.g. foreign bodies or micro-organisms). This includes areas where:
• the product is fully enclosed within packaging (e.g. raw material and finished product storage and dispatch areas)
• the product is fully enclosed within equipment shielding the product from physical or microbiological contamination from the production equipment during production – this may include enclosure within transfer pipework and fully enclosed equipment, and also where the equipment maintains its own environment to protect the product (e.g. aseptic filling equipment).
Whenever product lines are entered, for example for cleaning, maintenance or sampling, documented processes must be in place to ensure that the potential for contamination is minimised and the line is returned to the correct standard to maintain the enclosed product status.

OPEN PRODUCT AREAS
Wherever ingredients, intermediates or finished products are not protected from the factory environment there is a potential risk of product contamination by foreign bodies, allergenic material or micro-organisms in the environment.

 

Regards,

 

Tony

 

 

 

[Charles.C]

Hi Tony,

 

Thanks for the above.

 

To my mind, the brief definition of "Open Product Areas" is more risk intelligible than the preceding text,

[jtang]

My question is actually not about the warehouse area itself...

We want to be able to call it enclosed product area, but we store opened (but covered up with plastic bag) left over ingredients, returned from production areas.

 

So lets say they opened a bag of sugar, used half, and rolled up the bag, put a plastic sheet over top and return it to warehouse.

 

 

Is this still considered enclosed product??

[Tony-C]

My question is actually not about the warehouse area itself...

We want to be able to call it enclosed product area, but we store opened (but covered up with plastic bag) left over ingredients, returned from production areas.

 

So lets say they opened a bag of sugar, used half, and rolled up the bag, put a plastic sheet over top and return it to warehouse.

 

Is this still considered enclosed product??

 

It would be considered enclosed but the requirements are to be adequately protected. I fail to see how you can safely store sugar that has been 'opened' in a warehouse though.

 

Regards,

 

Tony

[mgourley]

Due diligence in that opened containers are resealed, dated, and inspected? As with any other raw material?

 

Marshall

[Charles.C]

It would be considered enclosed but the requirements are to be adequately protected. I fail to see how you can safely store sugar that has been 'opened' in a warehouse though.

 

Regards,

 

Tony

 

Indeed, and if such a "routine(?)  opening" activity was observed/aware of by an auditor, the latter would agree with you IMO.

 

The "escape" route is presumably the last "Enclosed"  paragraph in post #2 which is ambiguous in scope, probably by intention.