4 replies to this topic

[PSC]

I work for a jerky manufacturer and we have been preparing to become BRC certified. In so doing, we hired a BRC consultant to help with our paperwork and distinguishing certain areas from others based on the BRC risk assessments. Our consultant had told us that our raw and oven rooms are to be considered high-care and that our packaging room is low-risk.

 

Our raw room and oven room are in separate rooms, but they have an open hallway to each other. Our packaging room is a separate room, adjacent to our oven room and has a door creating separation.

 

I had read the BRC decision tree and thought that based on our product being RTE, that our packaging room (which has exposed product) was high-risk, even though our product is shelf stable. Our consultant said I was wrong and that it is low-risk because it is separated from the other rooms and is shelf stable.

 

To further muddle the water, we just had a B1 audit and our auditor told us that our packaging room should be considered high-risk.

 

I feel very confused. I am new to the BRC process, so I feel I have to trust our consultant who before becoming a consultant was a BRC auditor. Can someone help me out?

 

Thank you very much. 

[Charles.C]

Hi PSC,

 

Thanks for yr query and Welcome to the Forum !

 

I assume shelf stable = ambient storage = BRC zone diagram 2

I assume the raw material has not received any specific prior bacterial reduction treatment.

 

It appears the beef jerky manufacturing process is potentially complex with respect to establishing a safe product. For example see the attachments, especially the middle one, in this post -

 

http://www.ifsqn.com...nes/#entry95148

 

This document (2010) looks to be the latest FSA-UK equivalent (contains a lot of the US material et al) -

 Micro. hzards dried meat products, Campden,2010.pdf   713.58KB   44 downloads

 

AFAI can see, there is no high risk option in BRC Zoning Diagram2, only high care or low risk. ???

 

The obvious question is - How did the auditor explain the packaging area to be High Risk ?

 

Beef not my area but i understand a typical process is something like (see attach.referred above) this  - 

 

Step 1 - Strip preparation from whole muscle

Step 2 – Marination

Step 3 – Interventions:  Antimicrobial  to increase the level of pathogen reduction beyond that achieved by heating alone.

Step 4 - Surface preparation

Step 5 – Lethality:  The lethality treatment is defined as the process step or steps used to destroy pathogenic microorganisms on or in a product to make the product safe for human consumption.  The lethality treatment is considered to include the time when the product is placed in the heated oven (including surface preparation and color setting) until the product reaches the desired lethality time-temperature combination (also referred to as “the cooking time”).

In order to achieve adequate lethality, it is important that an establishment’s actual process adheres to the following critical operational parameters: 

•   Product time-temperature combination

•   Relative humidity

Step 6 – Drying: 

Step 7 – Post-drying heat step: 

Step 8 – Handling (including Packaging): 

 

For my example, IMO, the theoretical answer in BRC diag2 (after YN)  seems to primarily depend on raw material / BRC Steps 4,5 (and maybe my example - step 3). 

 

Unclear to me whether BRC step 4 is Y or N with respect to fat level,etc. In view of above comments i suggest to follow the "Precautionary Principle"  so  > Y

 

And, since BRCstep5 is Y in my example flowchart, the result  >> High care.

 

How does yr process compare ?. Significantly different ?.

 

PS - even if the answer to BRCstep4 was NO, it is conceivable that a BRC auditor might still specify High Care. For reason, see the attachment in this post -

http://www.ifsqn.com...nes/#entry91175

 

But in such a case, i would expect the auditor to fully explain his logic. In the situation you describe, I would have directly requested an explanation anyway.

 

PPS - It may be worth noting that in the 1st version of Zoning concept (BRC6) I would have selected Low Risk decisively but BRC might still have applied the caveat  mentioned in the PS. The addition of the "ambient" scenario enables, inter alia, specific handling of certain FS events, eg peanuts, chocolate via a high care approach. As noted in BRC7, it ultimately comes down to a risk assessment of the specific product/process. It is possible this caused the auditor to suggest a "high risk" conclusion for yr process but this then needs to be explained.

 

 

also note this quote from BRC7 -

 

It should be noted that the BRC Standard includes only two clauses relating to specific requirements for ambient high care (clauses 4.3.1 and 4.3.7). Clauses which refer to either high risk or high care (without reference to ambient products) are not applicable to ambient high care.

Edited by Charles.C, 31 October 2015 - 04:22 PM.
expanded

[Simon]

Have you checked the guidelines on defining the production risk zones?

 

Ultimately if you are going to use this Certification Body for your audit then your consultant and auditor need to have a conversation.

 

Regards,

Simon

[PSC]

Thank you both for your input. It definitely seems that our packaging room would be Ambient High-Care and not Low-Risk. 

[JohnWheat]

'The "Precautionary Principle"  so  > Y' that Charles mentions would be the route I would follow too.