CIP Risk Assessment

Hi all,

We have a BRC audit coming up next week (Food Safety Issue 8 + gluten Free additional voluntary module)

I was reviewing the standard and in clause 4.11.7.1 it said: 

" All CIP equipment shall be designed and constructed to ensure effective operation. This shall include: 

 where rinse solutions are recovered and reused, an assessment of the risk of cross-contamination (e.g. due to the re-introduction of allergen)."

When I checked with sanitation people they said they sometimes re-use chemicals in the CIP system for oven (depending on their personal judgement whether the chemical can be used for another time or is it "too used")

Now our Risk assessment only contain re-validation for the CIP at a frequency based on risk, and following any alteration or addition.

I am not sure, do we need to include the re-usage of chemicals to prevent allergen cross-contamination or this me reading too much into the clause.

Thanks!

Yes, you should demonstrate that re-use of chemicals does not pose a risk in terms of allergen cross-contamination - for example, if you're cleaning after using a product containing gluten, are these same CIP solutions potentially used to clean before producing a gluten-free product?

Obviously if your allergen type(s) handled on site is present in all products then this particular requirement isn't really applicable. Personally I'd still be inclined to document this, just because it's sometimes useful to have a piece of paper to hand to an auditor ;)

I am not sure of the actual situation but based on what you described I think you would want to address not only the allergen cross-contact issue but also the re-use is based on personal judgement.  What criteria are they basing their personal judgement on?  Is there a test they are using to determine how active the chemical still is or is it just someone looking at it and seeing too much of what they consider cloudiness?  Some sanitation chemicals are highly affected by the soils they clean off and are rendered ineffective after one use.

Yes, that's another concern too.. I do not think the person who writes the SOP is aware of the details the sanitation team do. 
 

Thank you !

I am not sure of the actual situation but based on what you described I think you would want to address not only the allergen cross-contact issue but also the re-use is based on personal judgement.  What criteria are they basing their personal judgement on?  Is there a test they are using to determine how active the chemical still is or is it just someone looking at it and seeing too much of what they consider cloudiness?  Some sanitation chemicals are highly affected by the soils they clean off and are rendered ineffective after one use.