15 replies to this topic

[The Prof]

Hello all,

 

I would be interested to receive your interpretation concerning the following highlighted text in the BRC Food V8 interpretation document

 

"Time segregation is not an acceptable alternative for high-risk areas, except for the transfer areas noted below. 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 must be given to whether this introduces a contamination hazard; it may therefore require measures that involve: use of disinfection, removal of outer packaging, double-door ovens, controlled air flow, changing the design of entrances and exits......."

 

...and this scenario: If a high risk risk room were to become a low risk room at planned intervals each week, in order to optimise plant capacity, would we not be able to demonstrate conformance to the above BRC Food V8 interpretation note?

 

Naturally, this would be fully risk assessed and controls would be implemented to ensure that the high risk room was set up ready to resume high risk production (to include: environmental monitoring, air filtration, positive air pressure, changing procedures, etc etc).

 

During our recent BRC audit, that did not include high risk, I asked the auditor whether switching from high to low risk to high risk etc would be acceptable in terms of BRC Food V8 when he audits us next time round, and he said it would be OK.  This interpretation was strongly disputed by one of our major customers during a recent audit and they referred me to the above highlighted text.

 

I'd value the views of the IFSQN members.

 

Many thanks

[pHruit]

Not a high risk site, but did read the IG in full when it was first published.
I'd interpreted the "except for the transfer areas noted below" as specifically applying to the single-door cooking system case described at the top of page 167, so the context of the site and equipment is very relevant for the general case exception.

If your intent is genuine dual high-risk / low-risk use of the same physical space at different designated times then that does indeed look to not be possible under the current standard - aside from the IG notes, clause 8.1.2 itself states that "there shall be physical segregation between...", and the IG reiterates this in a few places as well as the comments concerning "the segregating barrier must be capable of...".

Is it possible that the auditor had slightly misunderstood the specifics of your question?
If not already done so then it could be worth asking on Particpate.

 

I suppose there is metaphysical argument that different points in time mean that the same room is physically segregated from itself when considered in the context of a four-dimensional space-time, but (a) it doesn't actually provide the microbiological control for which the clause is actually looking, and (b) good luck trying to sell the concept to an auditor

[Charles.C]

I wouldn't know about the current I.G. but most of the text quoted in OP seems to have originated in the brc6 publication attached below which (additionally) contains -
 

 

Double door ovens, blast chillers or freezers (i.e. those with separate entrance and exit) – Refer to information below on the use of single door ovens/smoke houses
(et seq)

 brc6 F048 - Understanding High care and High risk.pdf   589.79KB   109 downloads

 

 

 

 

[pHruit]

Anyone else think it'd be really rather nice of BRC to keep these supplemental explanatory documents up to date with the standard?
Documents like the one posted by Charles are very useful for some of the more abstruse corners of the Standard (of which BRC certainly has its fair share), and may still be, but too few of them seem to be updated in parallel with the current Issue

Given that high risk / high care has a whole new section of the standard (admittedly created by augmenting and modifying a patchwork of Issue 7 clauses), one would think it would be a relevant time for them to provide an update, or at least publicly confirm that the previous guidance still reflects their expectations...

[The Prof]

Hi all,

 

Many thanks to all those who have replied to my original post.

 

The text quoted in my original post was lifted from the latest Food Version 8 IG.  To recap, my question relates to the concept of "time segregation", its practical application, and whether a high risk room can become a low risk room from time to time to optimise plant capacity, and still fulfil the requirements defined in BRC Food V8.

 

There seems to be mixed opinions on this according to the various sources with whom I have raised this question.

 

Are there further views in IFSQN land?

 

TIA

[Charles.C]

I noticed the BRC8 Standard also has for High Risk (Chilled and Frozen)  foods (Pg 90) -

 

The ideal barrier is a full wall separating the high-risk area from other areas. In assessing the suitability of the segregating barrier, a risk assessment must have been carried out and documented.

 

It is expected that newly built factories will employ full-wall separation where high-risk facilities are required.

 

Time segregation is not an acceptable alternative to physical segregation for high-risk areas.
 

(end of segment)

 

 

Seems the I.G. is misaligned to the Standard unless, perhaps, it only references non-chilled/frozen items(?)..

 

IIRC, in case of ambiguity, the text in Standard should be definitive.

 

Over to BRC (?).

Edited by Charles.C, 07 August 2019 - 12:10 PM.
expanded

[The Prof]

Hi all,

 

I would conclude that a high risk area transitioning to a low risk area from time to time, and reverting to a high risk room, would not conform to BRC Global Food Standard V8 requirements.....

 

If anyone has any further views, please share.

 

Thank you

[pHruit]

I'm guessing it's you that has asked on Participate?
Never clear exactly how frequently BRC themselves bother to check there, but interested to know what they have to say...

[The Prof]

I'm guessing it's you that has asked on Participate?
Never clear exactly how frequently BRC themselves bother to check there, but interested to know what they have to say...

 

Yes, that was me pHruit.  The Participate forum seems very quiet!  Must be the holiday season :-)

[pHruit]

If you think that's quiet then you should pop into the Agents & Brokers section there

[The Prof]

If you think that's quiet then you should pop into the Agents & Brokers section there

 

I bet!

[Charles.C]

Hi Prof,

 

a few more queries, comments -

 

(1) I note that yr particular Product/Process remains anonymous, It may be relevant (eg (4) below). Can you elaborate further ?

 

(2) i am curious as to whether the current IG contains the additional items mentioned in quote Post3, viz -

 

Double door ovens, blast chillers or freezers (i.e. those with separate entrance and exit)

 

(3) the "time segregation" quote in my Post 6 originated in BRC7 using  identical wording to that in BRC8. So not new.

 

(4) With regard to  "conclusion" in Post 7, please also remember the chilled/frozen caveats assumptions in My post 6. For example, as I understand, and perhaps depending on the Product/Usage situation (eg ambient storage), operation of  "baking ovens"  might not necessarily be regarded as a transfer to a high risk area ? (also see the Appendix flowchart).

 

 Slow Participate response may indicate that the BRC8 text quoted in my Post 6 was perhaps intentionally/unintentionally "incomplete".

(Or perhaps resident experts are fully occupied scrutinizing all the EC Food Directives before Oct.31).

[The Prof]

Hi Charles.C,

 

Hi Prof,

 

a few more queries, comments -

 

(1) I note that yr particular Product/Process remains anonymous, It may be relevant (eg (4) below). Can you elaborate further ?  Product is low pH savoury sauce in a small plastic pot with a sealed lid. Product is cooked in low risk, transferred to high risk, hot filled into the pots in high risk and sealed in high risk.  It is then blast cooled in high risk (single door), bagged up and transferred into low risk.

 

(2) i am curious as to whether the current IG contains the additional items mentioned in quote Post3, viz - Yes, the same text is in IG for V8

 

(3) the "time segregation" quote in my Post 6 originated in BRC7 using  identical wording to that in BRC8. So not new. Yes, the same text in IG V8

 

(4) With regard to  "conclusion" in Post 7, please also remember the chilled/frozen caveats assumptions in My post 6. For example, as I understand, and perhaps depending on the Product/Usage situation (eg ambient storage), operation of  "baking ovens"  might not necessarily be regarded as a transfer to a high risk area ? (also see the Appendix flowchart).

Sllow Participate response may indicate that the BRC8 text quoted in my Post 6 was perhaps intentionally/unintentionally "incomplete".

(Or perhaps resident experts are fully occupied scrutinizing all the EC Food Directives before Oct.31).

 

Regards,

 

The Prof

[JohnFiggins]

There is obviously quite a lot of discussion on this topic, but I will try and answer each of the main themes:

 

It is correct that time segregation is not permitted for high risk products - the Standard is clear that physical segregation is required and this should be a full wall. However, this is not a new requirement, the same requirement applied for Issue 7 of the Standard.

Time segregation is permitted for high care areas although it is not the preferred option.

There is a documented exception to this rule which recognises that some traditional processes or older factories may use single door ovens (for example, for smoking fish). In these circumstances a carefully controlled transfer area is permitted.

 

There seems to be a slight confusion regarding the application of high risk and high care areas - as explained in appendix 2 of the Standard these areas are only applicable to chilled and frozen products (and even then only if the products produced meet either of the definitions given in appendix 2. 

 

All of the explanation is included in our guideline 'Understanding High Risk, High Care and Ambient High Care. I note that a previous reply to this discussion attached an old version of this document. I am not sure why the old version was attached rather than the current version, as the document was updated and the Issue 8 update published last year. All up to date guideline documents are available from BRCGS Participate (www.brcgsparticipate.com). All certificated sites have free access to this website and all of the information that is stored on it (there are over 20 guidelines designed to assist sites certificated to the Food Standard, including the Standard and the Interpretation Guideline).

 

John Figgins

Technical Specialist - Food

BRCGS

[Charles.C]

Hi Prof,

 

So, to summarize, as I understand,  the answer to your OP is that your auditor was correct if your Product/Process situation conforms to  -

 

(a) The definitions given in Appendix 2 (which I anticipate that it does ?)

(b) The exception referenced in Post 14 (which I anticipate it does not ?)

 

@John Figgins - Thks for defining the exception.

[The Prof]

Hi John,

 

To summarise, the BRC auditor was wrong and our customer was correct.

 

Hi Prof,

 

So, to summarize, as I understand,  the answer to your OP is that your auditor was correct if your Product/Process situation conforms to  -

 

(a) The definitions given in Appendix 2 (which I anticipate that it does ?) Correct

(b) The exception referenced in Post 14 (which I anticipate it does not ?) Correct

 

@John Figgins - Thks for defining the exception.

 

Many thanks for your help.