8 replies to this topic

[Esther]

Hello everybody

I would like to get an opinion from somebody familiar or with experience on the BRC standard implementation.

This is about a fishery industry which works as a cold store at the same time.

The raw material is frozen and fresh fish in bulk.

The end product ( ready for loading ) can be: the same frozen raw fish after been stored and wrapped and packaged frozen sliced fish.

There is ONLY ONE area for the following operations:
-unloading of raw material in bulk
-loading of raw material in bulk
-loading of the wrapped and packaged product

There are four loading and unloading bays.

The question is, does this plant complain with the "Design and layout " requisite of the BRC standard ?
Is that a mayor non compliance ?

Thank you in advance

Regards
Esther

[Charles.C]

Sorry for not quite understanding - do you mean like that same door/route is used for bringing in both frozen and wet (iced) fish and then also used to allow exit (export?) of all frozen finished product? Or do you mean that like one long room with input doors at one end and output doors at other?
I assume the other processes like repacking, processing /freezing for cut fish are acceptably done in other separate areas?
Regards / Charles.C

[Esther]

Sorry for not quite understanding - do you mean like that same door/route is used for bringing in both frozen and wet (iced) fish and then also used to allow exit (export?) of all frozen finished product? Or do you mean that like one long room with input doors at one end and output doors at other?
I assume the other processes like repacking, processing /freezing for cut fish are acceptably done in other separate areas?
Regards / Charles.C

Hello Charles

It is me who should say sorry.

The unloading and loading area is like a big square room. There are fork lift vehicles working there.In one side there are four unloading/loading bays and in another one ( just by the one before ) there are two unloading/loading bays , one of them only used to the unloading operation ).

Regarding the other two remaining sides, on one of them we got the entrance to the cold store and on the other side just another door to outside.

Please tell me if you need some information. I am really worry about this issue.

Thank you for replying

Regards
Esther

[Charles.C]

Tkks yr info.
Do you mean -
(1) all raw material is frozen?,
(2) all handling is using frozen material only? (ie no thawing operation / processing of thawed material?).
There are a lot of possible variations in processing styles, eg all thawed product, all frozen product, mixtures of the two.
People typically fully segregate an entry ( + handling route) for non-frozen from an entry / exit (+ handling route) for frozen.
People sometimes use the same entry for frozen and for exit of frozen, depends on product / presentation / acceptable sanitation control. The handling route requirement varies, see below.
If yr question relates to segregation of product movement internally, this can be complicated and depends on what is going on.
Hope I've partially understood yr query.
Someone will probably now tell you the opposite.
Rgds / Charles.C

[Esther]

Tkks yr info.
Do you mean -
(1) all raw material is frozen?,
(2) all handling is using frozen material only? (ie no thawing operation / processing of thawed material?).
There are a lot of possible variations in processing styles, eg all thawed product, all frozen product, mixtures of the two.
People typically fully segregate an entry ( + handling route) for non-frozen from an entry / exit (+ handling route) for frozen.
People sometimes use the same entry for frozen and for exit of frozen, depends on product / presentation / acceptable sanitation control. The handling route requirement varies, see below.
If yr question relates to segregation of product movement internally, this can be complicated and depends on what is going on.
Hope I've partially understood yr query.
Someone will probably now tell you the opposite.
Rgds / Charles.C

Hello Charles

Good point !

To sum up, let's say all my product is frozen, raw and unwrapped material ( the entire fish ) and the end and wrapped product ( for example, boxes containing frozen steaks of fish ).

I will tell you that the raw material arrives very dirty ( on the surface ) and it is handled with fork lift vehicles ( which can be used to move pallets of end product ). When handling the raw material the floor become dirty.

On the other hand, because of the way the fish industry works, sometimes the vehicle bringing raw material has to come inside the loading and unloading area ( smokes !!!! )otherwise it will be parked outside while the unloading operation is carried out ( one big door will be open for aprox one hour !!)

So, could you tell me your opinion about which solution you would take:

Solution one:
Because we are talking about and " wrapped and packaged" frozen end product there is no problem I should be worry about.

Solution two:
1- carry out those operations, raw material unloading and end product loading at different times and clean the area between both
2. use of different fork lift vehicles for both operations or clean them before handling end product.

Again, thanks for your answers

Regards
Esther

[Charles.C]

I deduce the SOP's are -
(1) Entry vehicle (totally boxed, whole raw frozen product) >fork lift unload>cold store>later fork lift remove>exit vehicle
(2) Entry vehicle (totally boxed, frozen finished product) >fork lift unload>cold store>later fork lift remove>exit vehicle
Some possible contaminations are -
(a) Box whole product > box finished product
(b) Box whole product > environment > box finished product, etc
© Vehicle > environment > finished product, etc
My comment would be that typically the principle of using same position for in/out of frozen boxed goods is accepted but the practice will depend on yr assessment of the relative risks such as above and how they are handled. Yr comments regarding time segregating different functions and cleaning are all used to varying frequencies depending on the situation (including the interaction (power balance?) between QA concerns and production / export requirements.) You are talking about, I think, only 'low risk' items so there are less 'absolute' statements available compared to "high risk". I guess it comes back to validation / verification criteria as usual.
Regards / Charles.C

[Esther]

I deduce the SOP's are -
(1) Entry vehicle (totally boxed, whole raw frozen product) >fork lift unload>cold store>later fork lift remove>exit vehicle
(2) Entry vehicle (totally boxed, frozen finished product) >fork lift unload>cold store>later fork lift remove>exit vehicle
Some possible contaminations are -
(a) Box whole product > box finished product
(b) Box whole product > environment > box finished product, etc
© Vehicle > environment > finished product, etc
My comment would be that typically the principle of using same position for in/out of frozen boxed goods is accepted but the practice will depend on yr assessment of the relative risks such as above and how they are handled. Yr comments regarding time segregating different functions and cleaning are all used to varying frequencies depending on the situation (including the interaction (power balance?) between QA concerns and production / export requirements.) You are talking about, I think, only 'low risk' items so there are less 'absolute' statements available compared to "high risk". I guess it comes back to validation / verification criteria as usual.
Regards / Charles.C

Hello Charles

Thanks vey much for all your comments.

I think I will have the final answer at the moment the BRC audit is done!

Regards
ESTHER

[Charles Chew]

I will tell you that the raw material arrives very dirty ( on the surface ) and it is handled with fork lift vehicles ( which can be used to move pallets of end product ). When handling the raw material the floor become dirty.

Esther,
a. Time and temperature abuse would cost two major main things to happen - microbial and toxin growth. I think this may not be your main problem but it could as sublimation of ice would have occurred during transit esp. by forklift and unboxed.

b. The raw materials arriving very dirty (cross contaminations), smoky forklifts (dioxin) and dirty floors would all become a problem when inhibited pathogens contained by low temp. are re-activated during thawing at the next food chain.....which means have you prepared your "end-product" for the next responsible party.

I wonder what the BRC auditor would comment on but frankly I would fear the worse.

[Esther]

Esther,
a. Time and temperature abuse would cost two major main things to happen - microbial and toxin growth. I think this may not be your main problem but it could as sublimation of ice would have occurred during transit esp. by forklift and unboxed.

b. The raw materials arriving very dirty (cross contaminations), smoky forklifts (dioxin) and dirty floors would all become a problem when inhibited pathogens contained by low temp. are re-activated during thawing at the next food chain.....which means have you prepared your "end-product" for the next responsible party.

I wonder what the BRC auditor would comment on but frankly I would fear the worse.

Hello Charles

I know, I know. I have the same opinion as you have.

At last I could make the management director understand my worry and now we are starting dealing with that!!!!!!

Thank you again

Regards
Esther