6 replies to this topic

[jtang]

Hi,

 

Is there something in BRC I can use to reference...

 

for a tool that is used for decorating of a bakery product that will not go through any further cooking step?

 

The tool needs to be made of food grade material...?

I know for direct food contact packaging we do. What about tools? And what if supplier is not able to provide anything and we have sourced through many suppliers and so far we are not able to find one that can provide the same type of tool?

 

It is made of silicon.

 

 

Thanks!

[Dapulu]

Good afternoon.

 

On BRC you can review section 4.6/Equipment and remember that it sayas all equipment shall be construct of "appropriate materials" (4.6.1). Also, on direct contact with food you need to meet the "applicable legal requirements".

 

If it's something you absolutely need and cannot find any food-grade replacement,  I suggest to start reviewing your country's Good Manufacturing Practices laws or something akin to check if silicon is something that isn't forbidden in food product contact. Then work through your foreign matter programs as to assure that you have an excellent control over your sillicon-based materials used in direct product contact.

 

Remember that the statement of intent is to minimise the risk of product contamination, and by having a good foreign matter program and controls, and by supporting that the tool is allowed by law, I think you can avoid a non-conformance and only get an observation, or at max. get a minor NC.

 

If you could give a bit more detail of the use of the tool and the tool itself, maybe we could help out more.

[jtang]

It's a silicon brush but very small in size, which we've only been able to find online. No way to proof it is food grade or not.

 

I guess we will have to put together a statement of intent, with considerations on the points you mentioned.

 

In terms of control, it is more visual than anything. The colour stands out (blue), and every item is via on production line checks. It is also only used on the very top surface only so would be easily spotted.

 

 

Good afternoon.

 

On BRC you can review section 4.6/Equipment and remember that it sayas all equipment shall be construct of "appropriate materials" (4.6.1). Also, on direct contact with food you need to meet the "applicable legal requirements".

 

If it's something you absolutely need and cannot find any food-grade replacement,  I suggest to start reviewing your country's Good Manufacturing Practices laws or something akin to check if silicon is something that isn't forbidden in food product contact. Then work through your foreign matter programs as to assure that you have an excellent control over your sillicon-based materials used in direct product contact.

 

Remember that the statement of intent is to minimise the risk of product contamination, and by having a good foreign matter program and controls, and by supporting that the tool is allowed by law, I think you can avoid a non-conformance and only get an observation, or at max. get a minor NC.

 

If you could give a bit more detail of the use of the tool and the tool itself, maybe we could help out more.

[Foodworker]

It is not always possible to get definitive evidence that a piece of equipment is suitable for food contact nd complies with whatever legislation that aapplies in different countries. Sometimes it could be the age of the item aand any documentation was lost years before the legislation existed or it could be tht the supplier is unable to provide it.

 

The BRC Standard recognises this and allows you to justify using it following a risk assessment.

 

This is an extract ffrom the Interpretation Guidelines: 

 

 

Where evidence to confirm the suitability of food contact equipment is not available, and the contact material is not a recognised food-safe material (such as stainless steel), a documented risk assessment should be carried out to justify its use and ensure that it is not a food safety risk. The risk assessment must consider factors such as:

•the nature of the food contact surface and its known characteristics

•the length of contact time with the food

•the nature of the food and its potential for contamination (e.g. fatty foods are often at increased risk from migration of contaminants from plastic materials).

[Charles.C]

 

It is not always possible to get definitive evidence that a piece of equipment is suitable for food contact nd complies with whatever legislation that aapplies in different countries. Sometimes it could be the age of the item aand any documentation was lost years before the legislation existed or it could be tht the supplier is unable to provide it.

 

The BRC Standard recognises this and allows you to justify using it following a risk assessment.

 

This is an extract ffrom the Interpretation Guidelines: 

 

 

Where evidence to confirm the suitability of food contact equipment is not available, and the contact material is not a recognised food-safe material (such as stainless steel), a documented risk assessment should be carried out to justify its use and ensure that it is not a food safety risk. The risk assessment must consider factors such as:

•the nature of the food contact surface and its known characteristics

•the length of contact time with the food

•the nature of the food and its potential for contamination (e.g. fatty foods are often at increased risk from migration of contaminants from plastic materials).

 

 

Hi foodworker,

 

I suppose an unblemished history is a given.

 

Must be an occasionally interesting challenge for the auditor. To Believe or not to Believe, that ......

 

I suppose the auditor is always able to fall back on the non-auditable status of the Interpretation Guidelines.

[GMO]

Hi,

 

Is there something in BRC I can use to reference...

 

for a tool that is used for decorating of a bakery product that will not go through any further cooking step?

 

The tool needs to be made of food grade material...?

I know for direct food contact packaging we do. What about tools? And what if supplier is not able to provide anything and we have sourced through many suppliers and so far we are not able to find one that can provide the same type of tool?

 

It is made of silicon.

 

 

Thanks!

 

Having worked in bakery and knowing they are tinkers for using pieces of equipment not always designed for the purpose, this at least sounds sensible.  

 

My views are as follows, the cook step is irrelevant because the risks are chemical not microbiological (mainly) when it comes to food safety although if it deteriorates through use (say, like aluminium) that then can create microbiological problems.

 

You have found this item online.  Have you contacted the supplier?  Might sound stupid but they may even have some evidence it is safe for food use even if that's just the little EU glass and fork symbol on the equipment itself, on the packaging or on their suppliers info.  Here's what I mean: https://en.wikipedia...ntact_materials

 

But yes, anything contacting the food e.g. conveyor belts would need to be food safe.  When I used to work in bakery, we had equipment which was historically in place before the rules came in.  I did a risk assessment on these to cover them off but the majority was stainless steel which made it simple.  I can't see how new equipment can get away without complying but I can't remember the time I failed to get some evidence, unless, as in one factory, they are using a paint sprayer...  I'm totally serious.  

[* Steve]

Hi Jtang,

 

In my opinion any material that regularly comes into contact with food must be of a food safe material. 

 

You can usually get this confirmation from the supplier. (tip: store this in hard copy or keep in a folder on your PC somewhere. This will be asked for at some time..)

 

If yours isn't I am very sure that you can get one that is.