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BRC 8.4.1 - Environmental Boot Swabbing

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RHAWLEY

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Posted 01 July 2019 - 01:31 PM

We are in the process of closing out corrective actions for our BRC audit. We had 8.4.1 added with regards to environmental swabbing of our boots after stepping into our foot bath. We produce seafood products RTE and Value added. Does anyone know if a in house Listeria swab would suffice? Should this be sent to an outside lab?



Charles.C

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Posted 01 July 2019 - 02:06 PM

We are in the process of closing out corrective actions for our BRC audit. We had 8.4.1 added with regards to environmental swabbing of our boots after stepping into our foot bath. We produce seafood products RTE and Value added. Does anyone know if a in house Listeria swab would suffice? Should this be sent to an outside lab?

 

This element is presumably linked with BRC's detailed EMP expectations as spelled out in 4.11.8.

 

Unfortunately the exact interpretation/requirements of above  has currently created some confusion here, eg see this recent thread -

 

https://www.ifsqn.co...ssessment-help/

 

Have you already developed a program regarding 4.11.8 ?

 

PS - since you are handling RTE materials, I anticipate you will have implemented a detailed EMPG ?


Kind Regards,

 

Charles.C


Leila Burin

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Posted 03 July 2019 - 01:18 PM

Hello, pls also see that in 4.8.1 the interpretation guideline states that:

.... "By exception, boot-wash facilities may be used instead of changing into captive footwear dedicated to the area. Boot-wash facilities at the entrance to an area will be accepted where this is eectively controlled, managed and validated to prevent the introduction of pathogens. The site must have undertaken a risk assessment to identify the suitability of the boot-wash facilities and established controls to manage the eective sanitation of footwear. The controls must have been validated by microbiological swabbing of footwear, oors and drains in the high-risk area to demonstrate the absence of pathogens (e.g. Listeria

 species)."

 

Pls notice the remark "by exception", this is new in V8, and accepted under a lot of discussion....

 

So: also see the concept of "validation", so, the test method for Listeria monocytogenes (not only Listeria spp), shall be a "minividas like"; and also to have inter comparative tests to support your verification results.

Hope this helps... :)

Leila



Charles.C

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Posted 03 July 2019 - 01:27 PM

Hello, pls also see that in 4.8.1 the interpretation guideline states that:

.... "By exception, boot-wash facilities may be used instead of changing into captive footwear dedicated to the area. Boot-wash facilities at the entrance to an area will be accepted where this is eectively controlled, managed and validated to prevent the introduction of pathogens. The site must have undertaken a risk assessment to identify the suitability of the boot-wash facilities and established controls to manage the eective sanitation of footwear. The controls must have been validated by microbiological swabbing of footwear, oors and drains in the high-risk area to demonstrate the absence of pathogens (e.g. Listeria

 species)."

 

Pls notice the remark "by exception", this is new in V8, and accepted under a lot of discussion....

 

So: also see the concept of "validation", so, the test method for Listeria monocytogenes (not only Listeria spp), shall be a "minividas like"; and also to have inter comparative tests to support your verification results.

Hope this helps... :)

Leila

 

Hi Leila,

 

Can you clarify yr last paragraph ?.

 

Do you mean that you anticipate that testing for Listeria only will be insufficient ?


Kind Regards,

 

Charles.C


Leila Burin

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Posted 03 July 2019 - 01:51 PM

Hello, the mini vidas test is: https://www.biomerie...-lmonocytogenes

 

see also:

https://www.ncbi.nlm...pubmed/10699670

 

there are several in the market... just to mention one...

 

Sorry if I summ my answer too much: What I mean is that is ok to verify with a recognized test such as Mini vidas for Listeria monocytogenes, daily or wekly, depending on the risk assessment frequency of the facility. But having in mind that the standard states "validation", then, this result from the internal lab shall be demostrable to be accurate. And this is achieved with an intercomparative test, a ring test.

 

I hope I clarify myself now....pls tell me if not

best regards

Leila





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