BRC 4.11.3 Risk from residue cleaning chemicals

Hi All,

We had our BRC V7 audit last week where we got AA! :spoton:

One of the NCs picked up was - The risk from residue cleaning chemicals on food contact surfaces had not been risk assessed.

I challenged this one as the clause reads as though it only applies to high risk/ high care areas...we are low risk.

After checking, it was found to be a non conformance and he mentioned use of PH strips and finding out the Quat status of our chemicals etc.

Has anybody got any procedures they can share to help with this?

Thank you.

You are on the right track with pH paper- you need to establsi the before pH and after..

i dont have a procedure for this but when you do your validation study for the cleaning - also include the pH or quat test - ie you are validating the cleaning method  that each use, if followed guarantees the removal of the residues

you can then do spot checks here and there

First of all, well done you!

Secondly I can understand why they would ask the question; however, it does sound like another BRC auditor going out of the strict scope of the BRC standard...  You may or may not be aware that the maximum residue limits on quats was reduced in the EU last year and the fear is that many manufacturers may not be compliant in the UK where we don't tend to rinse off quats. 

The first thing to say with quats is there is no food safety risk.  The second thing to say is rinsing them off is not required, it is an option (which at least one major retailer describes as a bad idea).  I would suggest you do a risk assessment.  As part of this it might be worth testing your product in worst case scenario conditions to see if quats are detected (Campden BRI do this testing).  It it's not an issue, I wouldn't change anything.  If it is you might decide to do one of the following:

Rinse (this might cause other issues though)

Discard the first products made from the line

Change to another cleaning product.

pH strips will obviously only work if the pH of your cleaning is different from water?

Hi All,

 

We had our BRC V7 audit last week where we got AA! :spoton:

One of the NCs picked up was - The risk from residue cleaning chemicals on food contact surfaces had not been risk assessed.

I challenged this one as the clause reads as though it only applies to high risk/ high care areas...we are low risk.

After checking, it was found to be a non conformance and he mentioned use of PH strips and finding out the Quat status of our chemicals etc.

Has anybody got any procedures they can share to help with this?

 

Thank you.

Congratulations! We didn't have our BRC 7 yet( one more month left) but the Quat status was brought up on our GFCP audit last November. The auditor for lack of anything substantial to write brought up the quat status. We had a min. ppm level and he wanted both min and max. Fine.CA done. So now we have 200-300ppm level that we measure with a ppm strip after we make the make the solutions.

Thank you for the comments - very helpful :thumbup: 

I will do a risk assessment and look in to testing.

Anika - where do you buy the ppm strips from? Can you send a link of what they look like please.

Thank you for the comments - very helpful :thumbup:

I will do a risk assessment and look in to testing.

Anika - where do you buy the ppm strips from? Can you send a link of what they look like please.

Hi yasmin,

There are many, eg Google >

http://www.amazon.co...r/dp/B0045I6KC0

and i would anticipate yr quat supplier has them. In fact I'm surprised you can run without them.

Thank you for the comments - very helpful :thumbup:

I will do a risk assessment and look in to testing.

Anika - where do you buy the ppm strips from? Can you send a link of what they look like please.

We get ours from Fisher Scientific:https://www.fishersc...its-2/p-4903265

But amazon like Charles suggested would work too of course.

Thank you everyone, I had no idea QAC test kits existed?  The normal method for QAC testing I've seen in the UK is always by titration with drop bottles.  This would give a more accurate result for the chemical strength but these test strips might be useful for us to test residues on machinery!  Every day is a school day!

I have a question. If I am going to include cleaning residue testing in Cleaning and Sanitation Programme SOP, do I test every tools and equipments for example each table, trolley or machine? Or do I randomly place the test strips at particular area?

I would suggest you use a zone plan like enviro monitoring............so direct product contact first, incidental, indirect/accidental contact and then have at it!  You shouldn't have to do nooks and crannies, because your product won't touch those areas

Then break it down 2 areas/week or something (not everyday)

Also, ensure you're doing actual titrations on cleaning solutions...........you can't asses risk, unless you know what's actually being used

My guess is BRC started this because people were not checking dilutions and there was way too much chemical being used

Even if it's dish soap---no one wants to consume that

I have a question. If I am going to include cleaning residue testing in Cleaning and Sanitation Programme SOP, do I test every tools and equipments for example each table, trolley or machine? Or do I randomly place the test strips at particular area?

3-year old thread albeit not uninteresting.

It may relate to what you are doing/using/producing.

Offhand, it looks/looked like nitpicking (eg Post 3).