11 replies to this topic

[Stephen Smith]

Hello everybody, my question relates to compressed air monitoring and how easy people are finding compliance with any HACCP activity that has subsequently identified critical control points for in-direct and direct food compressed air contact applications for example as detailed in the BCAS/BRC guides.  

 

Are you finding that once you have gone through this process there are difficulties identifying laboratories local to you able to provide the necessary services or are you in control of your own destiny and have in-house capability for example ?

 

I ask this as I am Convenor for the ISO working group with the catchy handle ISO TC118/SC4/WG1 Compressed air treatment technology and we deal with the generation/revision of the ISO 8573 air purity classification and measurement standards and since we actively try to include industry feedback during their generation your thoughts and experiences would be of interest to our working group.  

 

Thanks in advance, Stephen Smith

[Charles.C]

Hi Stepen,

 

TBH, based on threads in this forum, the use of CCPs in this ISO topic has generally been superceded by a PRP type analysis.

 

This is mainly a result of expectations such as those typically associated with FS Standards like BRC,SQF,ISO22000.

[neilp]

This is more of a PRP , we have our air quality assessed every 6 months. We put collection stations in the 40 bar air so the subcontractor could fit a sampling vessel and collect air. Tests are made to determine micro activity and any reside such as oil . We also have expensive charcoal type canister filters these are changed every 12 months. This is our PRP as there is no verification or checking that we could perform. Neil

[Stephen Smith]

Hi Stepen,

 

TBH, based on threads in this forum, the use of CCPs in this ISO topic has generally been superceded by a PRP type analysis.

 

This is mainly a result of expectations such as those typically associated with FS Standards like BRC,SQF,ISO22000.

Hi Charles, Thanks for the reply, so if I understand you correctly then the PRP analysis approach eliminates the need for air quality checks, is this because root cause analysis is performed to eliminate the risks associated with compressed air contaminants impacting food quality and safety ?

[Stephen Smith]

This is more of a PRP , we have our air quality assessed every 6 months. We put collection stations in the 40 bar air so the subcontractor could fit a sampling vessel and collect air. Tests are made to determine micro activity and any reside such as oil . We also have expensive charcoal type canister filters these are changed every 12 months. This is our PRP as there is no verification or checking that we could perform. Neil

Hi neilp, thank you for your post, its great to find someone that is actually testing their compressed air.  Do you know if the air is qualified as having been tested to an ISO8573-1 purity class and if so can you be certain that they followed the requirements of the measurement standards to the letter ?

[Charles.C]

Hi Charles, Thanks for the reply, so if I understand you correctly then the PRP analysis approach eliminates the need for air quality checks, is this because root cause analysis is performed to eliminate the risks associated with compressed air contaminants impacting food quality and safety ?

 

Hi Stephen,

 

If by Quality you mean the various items included, for example, in the ISO Air quality standard 8573 then no because all the mentioned FS standards require either validation or verification  (or both) of PRPs  This requires data for related control measures for hazards such as oil, microbiological.

 

Unfortunately food micro hazards due to "air" are not really elaborated in available standards such as BCAS, ISO so the HACCP interpretation tends to become arbitrary, eg any bacteria passing thru a filter may be classified as a "hazard". This "disconnect" has been previously discussed on the forum.

[Stephen Smith]

Hi Stephen,

 

If by Quality you mean the various items included, for example, in the ISO Air quality standard 8573 then no because all the mentioned FS standards require either validation or verification  (or both) of PRPs  This requires data for related control measures for hazards such as oil, microbiological.

 

Unfortunately food micro hazards due to "air" are not really elaborated in available standards such as BCAS, ISO so the HACCP interpretation tends to become arbitrary, eg any bacteria passing thru a filter may be classified as a "hazard". This "disconnect" has been previously discussed on the forum.

Thanks Charles C

 

Yep sorry for that I have a habit of saying Quality when I mean Purity, its a leftover from my earlier days in the ISO arena.  

 

So having looked at where your pointing me it sounds like you are saying the BRC/BCAS guidance are a little off target when they send you to the HACCP approach when risks from compressed air fit better in PRP actions for things like water, oil, particles since they rarely present a significant risk to health (more of an unwanted ingredient I guess).  With regard to micro which does fit more in HACCP (Critical Controls) approach, ISO/BRC/BCAS is not that helpful since we have a Present/Not Present outcome.  

 

Would that be a fair assessment ?

 

If so do you think that there is room/need for a review of these documents ?  For example a re-write of the BCAS guide and/or a purity classification for micro in 8573-1 ?  

 

Also we are looking to work in the near future on 8573-7 which as you are aware is the compressed air standard for sampling for viable micro hazards so I would be keen to hear from users and just as importantly, why people don't use the existing standard(s).

[Charles.C]

Hi Stephen,

 

Fot HACCP it all comes back to Food Safety / Risk Assessment. So the question becomes, qualitatively and quantitatively, which  are the safety-related factors as categorised in ISO 8573. This necesarily also requires a definition of FS hazard. Oil might cetainly fall into this arena, even if it was "food-Grade".

 

I will post the link to previous discussion here if i can find it. Includes references to related ISPE Standards IIRC.

 

From memory, I liked BCAS ver1 until i got to the micro.part.

[Charles.C]

addendum

 

Hi Stephen,

 

These 2 threads should give some idea of the complexity/confusion surrounding food plant (safety) specifications for environmental air/compressed air.
(Not  criticising the ISO Standard(s) which were presumably derived with somewhat different objectives in mind.)

The first thread particularly addresses yr closing paragraph in Post 7.

 

http://www.ifsqn.com...ood-equipement/

 

http://www.ifsqn.com...air-filtration/

 

Note that designation of a control program as a PRP has various possible interpretations from a risk POV. Some authorities regard a low risk hazard situation as a criterion for designating the control measure as a PRP. Others consider that designation of a control measure as a PRP causes the risk to be low. All very subtle.

 

PS - I have not yet seen a copy of the published BCAS 1st revision so unfortunately cannot comment on that (I am aware that the hazard designations have been partially condensed). As you say the 8573 classifications are more "Purity" oriented hence, presumably, the somewhat pioneering motivation for BCAS. A re-orientation of 8573 towards a Safety POV would involve a major re-think i fear.

[Stephen Smith]

Thanks Charles,

 

Boy, is there some confusion in those threads and I basically agree with post 7 from Trace Analytics which accepts that there is no written specification and perhaps we should remind ourselves that the BCAS document is not a specification either, rather a statement of what good looks like.  (FYI the driver for the BCAS document did not come from within the CA industry it was actually at the request of the BRC to assist with their auditing activities.  The revision was necessary since the first edition did not match with the purity classes of the revised 8573-1 and at the same time the complexity was reduced somewhat to only direct and in-direct contact applications.)

 

So going back to my original question, do people have difficulty identifying a lab to perform the necessary test work still stands regardless of the air purity specification deemed necessary by HACCP/PRP etc etc ?

 

On the basis of the forum response however, I guess that either people can find the services they need, do not need to measure the air purity, or have not seen the thread in the first place.  

 

From a UK perspective I have not as yet found a test house claiming to perform air purity tests to ISO 8573-1 and due to the complexities/logistics the labs in the US are willing to support this activity but are limited to what they can provide as you need a laser particle counter for class 1&2 which measure down to 0.1um for example.

 

Thanks again, Stephen

[swanny297]

We just implemented a monitoring program - we are using TRI Air Testing, they supply the test kit and media.  They have been very helpful.  We have a situation where compressed air contacts a food surface contact area.  Although the standard doesn't give specifications it does state that you have to monitor the quality - we set up set points for what we wanted to monitor and sample quarterly.

[Stephen Smith]

We just implemented a monitoring program - we are using TRI Air Testing, they supply the test kit and media.  They have been very helpful.  We have a situation where compressed air contacts a food surface contact area.  Although the standard doesn't give specifications it does state that you have to monitor the quality - we set up set points for what we wanted to monitor and sample quarterly.

Thank you swanny297, I presume that you are using the TRI cylinder kit which is the one they offer for for non breathing air sampling.  Do you have any issues shipping a pressurised gas sample container (I presume in the US) ?  

 

From the various sources I have seen you have to determine for yourself what the acceptable air purity levels are to mitigate risk to food safety and food quality.  Thus the way I see it is you are either taking the approach that the compressed air purification equipment meets the claims of the manufacture/supplier both at the commissioning stage and on an ongoing basis and/or you need to be under an in-house derived minimum purity level or only monitoring for trends.

 

So, on this basis once you have your data you have ticked the 'monitored' box but then you still have to determine if the results represent a risk to food safety and beyond that food quality but what then ?