7 replies to this topic

[jtang]

Hello,

How should we decide on the zoning for a packaging area as either high care or low risk?

The packaging area is where metal detector is, but all products are fully enclosed.

 

 

Finished product requires to be stored frozen --> high care

Finished product are ready to eat --> high care

There would be one or two employees going from high care processing area into the packaging area without any uniform change  --> high care

Product has previously been covered, but is being shrink wrapped in packaging area. Would this be considered "ENCLOSED"? --> high care?

 

There is no physical wall as a complete segregation (only half a wall) between processing area and packaging area -> low risk

Warehouse team needs to drive their pallet jack to deliver pallets into this packaging area (contains wooden pallets) --> low risk

There is no handwash station, boot wash or foot foamer outside of this area prior to warehouse pallet jack entering --> low risk

Warehouse team needs to come in and pick up the pallet to move it into the warehouse --> low risk

There is no uniform or coat change when warehouse team enters --> low risk

Finished product are kept frozen and not thawed until prior to consumption --> low risk

 

Appreciate any input!!

 

[Tony-C]

Hi jtang,

 

Be interesting to know your product as it may be high risk but slightly irrelevant as you are not compliant with regards to segregation, facilities required and restriction of movement of personnel.

If you look at BRC Global Standard for Food Safety Clause 4.3.6:
Where high-care areas are part of the manufacturing site there should be physical segregation between these areas and other parts of the site. Segregation shall take into account the low of product, nature of materials (including packaging), equipment, personnel, waste, airflow, air quality and utilities provision (including drains). Where physical barriers are not in place, the site shall have undertaken a documented risk assessment of the potential for cross-contamination, and effective, validated processes shall be in place to protect products from contamination.

BRC Interpretation Guideline High-care areas
This clause is applicable to high-care areas (i.e. areas designed to a high standard, where practices are in place to minimise product contamination by pathogenic micro-organisms).
Vulnerable products and ingredients have, before entry to the high-care area, undergone a process to reduce any contamination by pathogenic bacteria (e.g. a chlorine wash of salad materials), or an early cook step (e.g. the use of pasteurised cream). It is important that the high-care area is effectively protected from contamination from low-risk zones. This is most effectively achieved through full physical segregation by means of walls which separate the high-care area from other factory areas.
Where a separate, fully walled-of area is not available, alternative procedures must be in place to segregate the high-care area. The segregating barrier must be capable of preventing the risk of cross-contamination from:
• unauthorised access and movement between high-care and other areas of the factory except through designated changing areas
• transfer of materials, utensils or equipment except through designated ports with sanitising controls in place
• microbiological contamination which may be present in a low-risk environment
• airborne contaminants (e.g. dust particles or water droplets).

 

Further details in 4.8.5 regarding facilities

 

Regards,

 

Tony

[Charles.C]

Hi jtang,

 

it all come back to risk assessment.

 

eg if the product is exposed to the environment, there must be increased risk. The degree of increase depends on the product/process/process stage/environment.  And similarly the associated risk preventive/protective activities.

 

IMEX the tricky bits, design-wise, tend to be at the interfaces between low/high production areas and the necessary controls implemented in the high risk/care sections.

 

yr comment that frozen product/RTE implies high care is illogical IMO.

[Tony-C]

Hi jtang,

 

it all come back to risk assessment.

 

eg if the product is exposed to the environment, there must be increased risk. The degree of increase depends on the product/process/process stage/environment.  And similarly the associated risk preventive/protective activities.

 

IMEX the tricky bits, design-wise, tend to be at the interfaces between low/high production areas and the necessary controls implemented in the high risk/care sections.

 

yr comment that frozen product/RTE implies high care is illogical IMO.

 

Agree with the tricky bits, not only design but control and discipline of complying with the requirements at those interfaces.

 

High care according to BRC - Products which require handling in a high-care area meet all of the following:
• The finished products require chilling or freezing during storage.
• All microbiologically susceptible components have received a process to reduce the microbiological contamination to acceptable levels (typically 1–2 log reduction of micro-organisms such as Listeria species) before entry to the area.
• The finished products are vulnerable to the growth of pathogens or the survival of pathogens, which could subsequently grow during the normal storage or use of the product (e.g. if a frozen product is defrosted but not immediately consumed).
• The finished products are ready to eat or ready to heat or, on the basis of known consumer use, are likely to be eaten without adequate cooking.

 

Whether the product is frozen or chilled doesn't affect the category. The key elements are if the product is open to the environment, if the product will support the growth/survival of pathogens, if the products will undergo full cooking and if vulnerable products have received a heat treatment:

 

 BRC Global Standard for Food Safety Issue 7 UK Production Zone Decision Tree 1.jpg   154.61KB   60 downloads

 

Regards,

 

Tony

[jtang]

Thank you for the comments.

 

The product is a frozen dessert, can can be thawed and not served right away as it has refrigerated and ambient shelf life.

The product is lidded but not sealed with shrink wrap. This is happening in the packaging area that is in question...

 

I agree we need to do a risk assessment. As having a full wall for segregation is not possible unless it goes through capital expense.... what would be the ideal solution right now?

 

If the packaging area remains as high care, does that mean having full handwash and foot foamer is mandatory prior to warehouse delivering pallets?

 

If we do a risk assessment, I would likely base on the fact that only warehouse personal would be going from low risk (warehouse) into the packaging area (high care). Foot foamers would not be an option as they must bring in wooden pallets, and we do not want the packaging area to become wet.

 

would I be on the right track??

[jtang]

To add,

The product is not fully heat treated during manufacturing. Only certain components has a cooking step.

No further cooking required prior to consumption.

 

The product is not necessarily "Open" to the environment. It has a cover, just not completely vacuum sealed... I wouldn't call it open, but not sealed.

 

Agree with the tricky bits, not only design but control and discipline of complying with the requirements at those interfaces.

 

High care according to BRC - Products which require handling in a high-care area meet all of the following:
• The finished products require chilling or freezing during storage.
• All microbiologically susceptible components have received a process to reduce the microbiological contamination to acceptable levels (typically 1–2 log reduction of micro-organisms such as Listeria species) before entry to the area.
• The finished products are vulnerable to the growth of pathogens or the survival of pathogens, which could subsequently grow during the normal storage or use of the product (e.g. if a frozen product is defrosted but not immediately consumed).
• The finished products are ready to eat or ready to heat or, on the basis of known consumer use, are likely to be eaten without adequate cooking.

 

Whether the product is frozen or chilled doesn't affect the category. The key elements are if the product is open to the environment, if the product will support the growth/survival of pathogens, if the products will undergo full cooking and if vulnerable products have received a heat treatment:

 

BRC Global Standard for Food Safety Issue 7 UK Production Zone Decision Tree 1.jpg

 

Regards,

 

Tony

[Charles.C]

The product is not necessarily "Open" to the environment. It has a cover, just not completely vacuum sealed... I wouldn't call it open, but not sealed.

Hi jtang,

 

if you mean that the unwrapped product is, in the open,  transferred from ??,  placed into a ?? and the ?? is then vacuum sealed, i would call that exposed to the environment.

 

The devil is in the details. Or not.

[Tony-C]

Agree with Charles in that if the product is exposed to the environment where ever it is. I would only normally see this for perishable products with a very short shelf life.

 

With regards to segregation you need to segregate filling and packaging areas but personally I would worry more about the packaging given what you have posted.

 

Regards,

 

Tony