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BRC Issue 8: Potential Hazard Identification

FRAUD MALICIOUS CONTAMINATION RADIOLOGICAL CONTAMINATION POTENTIAL HAZARDS

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#1 Swarup Majumdar

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Posted 08 April 2019 - 06:49 AM

Hello everybody.

I had recently faced an initial audit on BRC Global standard, Issue 8. One of the non-confirmity based on clause 2.7.1 is,
Radiological, Fraud, malicious contamination of Products have not been considered as potential hazards.

Can somebody please guide me on this. My product range is FROZEN RAW CRUSTACEANS



#2 Tony-C

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Posted 08 April 2019 - 10:49 AM

Hi Swarup,
 
So they should be included in your list of potential hazards during HACCP implementation: 2.7.1 The HACCP food safety team shall identify and record all the potential hazards that are reasonably expected to occur at each step in relation to product, process and facilities.
 
Guidance - List of potential hazards
It is expected that the list will include specific hazards. The Standard provides examples of those that should
be considered, including:
• specific micro-organisms (e.g. E. coli or Salmonella)
specific chemicals (e.g. veterinary residues, pesticides or radiological contaminants)
• cleaning chemicals
• machinery lubricants
• specific foreign bodies (e.g. glass, metal or plastic)
• specific allergens (e.g. peanuts or egg)
the potential for fraud and/or adulteration
• malicious tampering with the product or processes.

Consideration must be given to all the sources of potential hazards. These could include raw materials, processes and the factory environment. The process flow diagram is a useful tool in considering the potential risks at each stage of production.
There must be a description of each hazard and its sources – one hazard may have several potential sources and occur at more than one point in the process. This is important to ensure that effective controls for each source of hazard are established in the subsequent steps of the process.
 
For radiological contaminants - Consider if they are likely to be contaminated from radiation such as sourcing from Japan (from Fukushima)
For the potential for fraud and/or adulteration - See 3.5.1.1 and 5.4
For malicious tampering with the product or processes - See 4.2
 
Kind regards,
 
Tony


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