Packaging transfer from Low Risk to High Care

Hi
 

I'd appreciate a bit of an advice.

I'm new to a dairy business and just reviewing some of our procedures.

We are BRC accredited ice cream manufacture.

We are and storing raw materials and packaging in low risk environment. Packaging are boxed up and wrapped within the plastic liner. Our movement procedure says that every bag of packaging while being transferred into high care through changing room has to be all sprayed with sanitiser on the outside. I don't quite see what it offers plus it's not very practical at all and for that reason, isn't being done.

Does it really need to be done if the packaging is removed from cardboard container just before entering the H/C? I cannot see any risk of contamination as long packing itself isn't exposed to the low risk environment?

Thanks in advance

Pawel

You're carrying it through your changing room?

If I was an auditor I would want some sort of additional control like the one you specififed. Your changing room is basically considered a bathroom from a risk assessment standpoint. If you then move those materials into your high care environment they are carrying all of that potential contamination in there with them to contaminate your high care environment, even if it doesn't contaminate the product itself.

Further, unless your workers treat the outside plastic liner as if it was a "dirty surface", they're then going to handle the packaging itself after unwrapping and cross contaminate with whatever was on the liner.

If you must carry materials through your changing room, I think your current procedure is a reasonable additional level of control.

Hi
 

I'd appreciate a bit of an advice.

 

I'm new to a dairy business and just reviewing some of our procedures.

 

We are BRC accredited ice cream manufacture.

 

We are and storing raw materials and packaging in low risk environment. Packaging are boxed up and wrapped within the plastic liner. Our movement procedure says that every bag of packaging while being transferred into high care through changing room has to be all sprayed with sanitiser on the outside. I don't quite see what it offers plus it's not very practical at all and for that reason, isn't being done.

 

Does it really need to be done if the packaging is removed from cardboard container just before entering the H/C? I cannot see any risk of contamination as long packing itself isn't exposed to the low risk environment?

 

Thanks in advance

 

Pawel

Hi Pawel,

The BRC's IG document likely gives more info. but yr current procedure may be derived from this comment in a well-known BRC6 document on high risk/care situations -

3.2 Transfer Points (clause 4.3.6)
 The location and operation of all transfer points must not compromise high risk and low risk segregation. For example, where raw materials or staff move into a high risk area, consideration shall be given to whether this introduces a contamination hazard and therefore requires procedures such as:
■   the use of disinfection
■   removal of outer packaging

etc

I'm a little unclear on the process but I'll go through what controls I'd put in place and why.

The purpose is to keep out pathogens, particularly Listeria, heaven knows, people probably didn't think about it much before Bluebell but it is a hazard that it could increase to dangerous levels in your mixes and then survive freezing so you want to keep your production area as clean as possible.

Personally I would put a hatch in the wall specifically for transferring the packaging to avoid water splashes etc in the changing room.

There are a few ways to do this.  Firstly, keep out the cardboard.  So the first control could be to have someone pulling the bag of primary packaging out of the card box while another member of staff holds onto the box on the low risk side.  Not very practical.  Why not just handle the box from low risk?  Well then you have transfer from that low risk person.  You could "tip" the box out into high care but again this could transfer some contamination.  It's all pretty theoretical though as the boxes should be dry.  That said I have found Listeria in card before (long, long story.)

The next step up from this is to have a double layer of protection so within the card box the primary packaging is double bagged, the outer bag is removed at entry to your high care area.  

Lastly as you say you could spray the bag with disinfectant.

Which do I prefer?  Probably double bagging because it's easy to do but the disinfectant will probably work best as even if there is some transfer from the outer, it will be killed.  It really depends on what ingredients / hazards you have on your low risk side as to how much risk there is, that said, Listeria is ubiquitous and it only takes one breach to be an issue.  Whatever you do, validate the process and do verification swabs from time to time (both Listeria and TVC).

Ultimately it's a good question.  If a process isn't happening you need to either change processes so it does happen or enforce it.  

  That said I have found Listeria in card before (long, long story.)

 

We should hear that story. Seriously, maybe we need an environmental monitoring investigations thread where we share some successes and failures there to help others look for similar situations.

Good point but the short version is don't assume that things like card can't be a source even if it's dry.  My top tip though is you can use something like card as a product sample, the lab just need to stomach with the half Fraser broth as they would a product sample.  

Put it this way, we changed our supplier.

I would suggest you put more onus on your packaging supplier to have a secondary liner around the pallet of packaging (if possible). 

Even with this you would have to provide some sort of separation of activities to prevent potential contamination on the outside of the packaging being brought into the high care environment or with the employees in the high care area.  Lots of ways to do this....some expensive, and some less expensive.  Time for management discussion!