Section 4.5 Layout and Product Flow
Can you please help me here; Section 4.5.6 of the BRC standard states that if it is necessary to allow access through production areas, designated walkways shall be provided that ensure there is adequate segregation from materials. My question is, for our associates to access the change rooms and canteen they are currently passing through the Raw material Store area with their street clothes and lunch bags. There is no way we can change that route unless we have to demolish the building to some extent. So how do we design walkways in this case to comply with the standard?
Cay you please help me here; Section 4.5.6 of the BRC standard states that if it is necessary to allow access through production areas, designated walkways shall be provided that ensure there is adequate segregation from materials. My question is, for our associates to access the change rooms and canteen they are currently passing through the Raw material Store area with their street clothes and lunch bags. there is no way we can change that route unless we have to demolish the building to some extent. So how do we design walkways in this case to comply with the standard?
Hi Phillipah,
What you can do is paint walkway lines (as far away from the materials as possible [while maintaining safety]) for pedestrians, and ensure that they walk within that particular path to get to their change rooms and break areas. I've heard that some companies (if possible due to forklift traffic) build rails on either side of the path, to make sure employees remain in that area. As with everything else in BRC, you would need to risk assess the personnel flow through the area.
QAGB
Hi Phillipah,
What you can do is paint walkway lines (as far away from the materials as possible [while maintaining safety]) for pedestrians, and ensure that they walk within that particular path to get to their change rooms and break areas. I've heard that some companies (if possible due to forklift traffic) build rails on either side of the path, to make sure employees remain in that area. As with everything else in BRC, you would need to risk assess the personnel flow through the area.
QAGB
Hi QAGB,
This manouevre seems to defy all the Principles of Food Hygiene to me, ie freely transferring the external environment into the "Production" area.
But i have never worked in Food packaging production.
Hi QAGB,
This manouevre seems to defy all the Principles of Food Hygiene to me, ie freely transferring the external environment into the "Production" area.
But i have never worked in Food packaging production.
Hi Charles,
The reason why I suggest that is because our facility has a weird layout as well. The employee changing areas are separated from production (so employees aren't necessarily in street clothes), but the breakroom is not in that area. You have to walk through two production areas before you get to the breakroom. Each morning, employees walk their lunchboxes through those two areas to get to the breakroom. We have designated pedestrian walkways and employees are not to be found outside of those areas with their lunchboxes (the lunch must be fully enclosed).
Also, when we have visitors or auditors, they come in wearing street clothes. They have to walk through a warehouse and two production areas to get to a conference room. We risk assessed our entire personnel and visitor flow, and found the risk was low in common flow areas. It all really depends on the process and maintaining the integrity of the product. You wouldn't want a common walkway to be put into a clean room or a raw meat production room. However, if the product (food or packaging) is far enough away from the common walkway, is stable enough, and has been risk assessed there usually isn't any problem.
Never had any issues during BRC, our BRC consultants (before we went BRC) were fine with the setup, and our numerous customers and regulatory inspectors have been fine with the setup during audits. As far as freely transferring the external environment into the production area, there are numerous companies out there that are apparently still allowing people to wear their outside clothes rather than uniforms. I find that to definitely defy GMPs, but companies have risk assessed their way out of wearing uniforms.
QAGB
Hi QAGB,
I'm less dogmatic over uniforms because I find over-uniforms a reasonable option to demand/implement for many food situations. But factory hygienic design is something else IMO.
IMEX of a low risk wet food process i think many (all?) of the customers would risk apoplexy at yr second paragraph. Let alone be prepared to do it themselves. In fact it would be legally impossible.
Asssuming you are describing a Food Process rather than Packaging I find that even more (BRC)-remarkable.
(I was half-prepared to expect that BRC Packaging has absorbed certain Packaging "traditions" in respect to a generally, relatively Low Risk Industry (?) [despite the impressively expanded scope of "hazard" in BRC Packaging which is surely pure BRC megalomania]).
I agree that risk assessment can become more like wish-fulfilment. Something else to be laid on BRC ?.
So we can paint walkways and do a risk analysis factoring this as well. they pass through were products is enclosed and not open production zones.
Thank you guys. will try this and when we do Gap Audit see how it goes.
Hi QAGB,
I'm less dogmatic over uniforms because I find over-uniforms a reasonable option to demand/implement for many food situations. But factory hygienic design is something else IMO.
IMEX of a low risk wet food process i think many (all?) of the customers would risk apoplexy at yr second paragraph. Let alone be prepared to do it themselves. In fact it would be legally impossible.
Asssuming you are describing a Food Process rather than Packaging I find that even more (BRC)-remarkable.
(I was half-prepared to expect that BRC Packaging has absorbed certain Packaging "traditions" in respect to a generally, relatively Low Risk Industry (?) [despite the impressively expanded scope of "hazard" in BRC Packaging which is surely pure BRC megalomania]).
I agree that risk assessment can become more like wish-fulfilment. Something else to be laid on BRC ?.
So we can paint walkways and do a risk analysis factoring this as well. they pass through were products is enclosed and not open production zones.
Thank you guys. will try this and when we do Gap Audit see how it goes.
Hi Phillipah,
At this point, you're still working towards certification, and it doesn't hurt to see what your auditor thinks at the Gap Audit. If you have a consultant who can come in and look at your process, they could also help you determine what you need to do. I understand your situation, older buildings like mine (and probably yours) were built in sections and at the time when built, people weren't thinking about process flows and so forth. Perhaps your auditor will be fine with it, and maybe not; but at least you will have time to come up with a different solution after your Gap Audit.
A good portion of my company is wet processing, and our common walkways are closer to the packaging end, where the product is already packed and sealed and being prepared to be put into boxes. I would not be advocating putting a walkway next to a filling operation, or any product that's exposed to the air. That's why I stated it is up to your process and how you setup your walkway. Your product is enclosed near your walkway which should provide justification to your auditor.
As far as legality is concerned, my company falls under two regulatory jurisdictions, and we're BRC Certified. We have customer audits every 2-3 months, and we have plenty of other certifications requiring audits. They all have walked through our facility, we've discussed our flow, and they know where our break room is located. We've never had a problem with the placement of our walkways and it has never been addressed as even a possible concern.
Make sure that you provide justification for your reasoning in the form of a risk analysis, and create a procedure which details your personnel flow.
QAGB
Hi QAGB,
As you say, I guess it all depends on Standard, industry, location, regulatory and export destination.
Hi Phillipah,
What you can do is paint walkway lines (as far away from the materials as possible [while maintaining safety]) for pedestrians, and ensure that they walk within that particular path to get to their change rooms and break areas. I've heard that some companies (if possible due to forklift traffic) build rails on either side of the path, to make sure employees remain in that area. As with everything else in BRC, you would need to risk assess the personnel flow through the area.
QAGB
This is what we have done in our facility. Being as our building was built in 1942, we have little to no choice, unless we want to build an entire new building. We are in the food flavoring industry and this has never been an issue in an audit.
This is what we have done in our facility. Being as our building was built in 1942, we have little to no choice, unless we want to build an entire new building. We are in the food flavoring industry and this has never been an issue in an audit.
Hi nc,
With all due respect, IMO, factory design/layout for food processing cannot be prioritized on age/business opportunity.
It should be prioritized on a food safety-related risk assessment from the consumer's POV. (and similarly Packaging IMO).
However regulatory (and non-regulatory) opinions as to what constitute the minimum requirements (if any?) from a safety POV clearly vary with factors such as in my previous post.
Again, IMO, the bottom line is Safety.
Hi Phillipah,
Designated walkway with painted lines and rails that provide adequate segregation would be accepted by BRC. As it is a raw material store the risk is less than a production area.
Kind regards,
Tony
Hi Tony,
I would have thought the (BRC) decision might have some relevance to the Product and the Process and the Intended Usage and .......... ?
AFAI can see, knowledge of all such items is unknown.
And perhaps any local Regulatory Hygiene Requirements in South Africa ?.
Hi Charles,
The BRC standard is quite clear so for the highest risk packaging:
HIGH HYGIENE CATEGORY
4.5.6 If it is necessary to allow access through production areas, designated walkways shall be provided that ensure there is adequate segregation from materials.
Kind regards,
Tony
Hi Tony,
Each clause of the Standard begins with a statement of intent. This sets out the expected outcome of compliance with the requirements of that section. This forms part of the audit and all sites must comply with the statements of intent in order to gain certification.
Intent
The factory layout, flow of processes and movement of personnel shall be sufficient to prevent the risk of product contamination and to comply with all relevant legislation.
(my underlines)
IMO "Adequate" > compliance /risk-assessed = f ( legality, product, process, etc)
Hi Charles,
If it was a major issue the wording in the standard as you know would say 'based on risk assessment'.
I look forward to you finding some relevant legislation on google regarding walkways through a raw material area :sorcerer:
Kind regards,
Tony
Hi Tony,
I deduce you consider that the decision as to what constitutes "adequacy" is not a major issue. No problem.
Hi Charles,
I have explained in previous posts what I would expect based on what has been implemented in the many BRC approved sites I have seen and worked with, what I have described would be appropriate and adequate.
Kind regards,
Tony
Hi Charles,
The BRC standard is quite clear so for the highest risk packaging:
HIGH HYGIENE CATEGORY
4.5.6 If it is necessary to allow access through production areas, designated walkways shall be provided that ensure there is adequate segregation from materials.
Kind regards,
Tony
Hi Tony,
Our Plant Manager wouldn't accept painting the floor as walkways :).. I know it is needed but I will just wait for the Pre-assessment Audit because I am kind of tired from fighting.
Hi Tony,
Our Plant Manager wouldn't accept painting the floor as walkways :).. I know it is needed but I will just wait for the Pre-assessment Audit because I am kind of tired from fighting.
Hi Lorenab,
They need to be designated not necessarily painted, so a barrier would be quite a good option or alternatively a strong adhesive tape if painting isn't an acceptable option.
Kind regards,
Tony
Hi Lorenab,
They need to be designated not necessarily painted, so a barrier would be quite a good option or alternatively a strong adhesive tape if painting isn't an acceptable option.
Kind regards,
Tony
Thank you Tony!