10 replies to this topic

[boging]

IN NEW REVISION OR NEW ISSUE ON BRC 8, ENVIRONMENTAL MONITORING IS ADDED..AND IT IS RISK-BASED.. I JUST WANT TO ASK HOW TO ASSESS THIS...IN OUR PLANT, WE CONDUCTED AIR SWABBING  IN EVERY MONTH IN ALL AREAS IN THE PRODUCTION..MAY I ASK IF THIS AIR SWABBING IS ALREADY A  ENVIRONMENTAL MONITORING AND IS IT ENOUGH THAT WE MONITOR THE TPC AND YM? OR THERE ARE MORE IMPORTANT TO MONITOR THAN THESE OR AM I DOING THE RIGHT MONITORING..

 

PLEASE I NEED YOUR HELP..

 

THANK YOU

 

BOGING

[Charles.C]

IN NEW REVISION OR NEW ISSUE ON BRC 8, ENVIRONMENTAL MONITORING IS ADDED..AND IT IS RISK-BASED.. I JUST WANT TO ASK HOW TO ASSESS THIS...IN OUR PLANT, WE CONDUCTED AIR SWABBING  IN EVERY MONTH IN ALL AREAS IN THE PRODUCTION..MAY I ASK IF THIS AIR SWABBING IS ALREADY A  ENVIRONMENTAL MONITORING AND IS IT ENOUGH THAT WE MONITOR THE TPC AND YM? OR THERE ARE MORE IMPORTANT TO MONITOR THAN THESE OR AM I DOING THE RIGHT MONITORING..

 

PLEASE I NEED YOUR HELP..

 

THANK YOU

 

BOGING

 

Hi boging -

 

Risk based typically involves zoning.

It may depend on what kind of food / risk level you are processing ?.

An EMPG program involves all potential food contact surfaces + related environmental FS vectors.

 

 

Can try this thread for some ideas -

 

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

[boging]

sir, 

 

our product is a low risk product

 

thank you

[QAGB]

Could you clarify what you mean by air swabbing? There is air plating, and there is environmental swabbing of physical items. Even as a low risk production, you should be doing more than air plates. You should be testing your production equipment (food contact surfaces, indirect contact surfaces of production equipment,  definitely drains and maybe even floors/walls (depending on what you process and your risk assessment). 

[kingstudruler1]

Could you clarify what you mean by air swabbing? There is air plating, and there is environmental swabbing of physical items. Even as a low risk production, you should be doing more than air plates. You should be testing your production equipment (food contact surfaces, indirect contact surfaces of production equipment,  definitely drains and maybe even floors/walls (depending on what you process and your risk assessment). 

agree with QAGB.   air sampling is most likely not enough depending on your product.  there are some free videos from this site.   there are many resources inside and outside of ifsqn.  Are you specifically looking for the risk assessment portion?  

 

https://www.ifsqn.co...monitoring-r148

 

https://www.ifsqn.co...ng-program-r163

 

https://www.ifsqn.co...&attach_id=7377

[boging]

hello,

 

yes sir/ma'am, we do air plating and swabbing in all food contact surfaces. we even do swabbing in non food contact surfaces. i am new in BRC so i dont know much especially when it comes to risk assessment.. and yes i am looking for a template how to do this risk assessment on environmental monitoring programmes. 

 

thank you so much for your help..

 

boging

[kingstudruler1]

hello,

 

yes sir/ma'am, we do air plating and swabbing in all food contact surfaces. we even do swabbing in non food contact surfaces. i am new in BRC so i dont know much especially when it comes to risk assessment.. and yes i am looking for a template how to do this risk assessment on environmental monitoring programmes. 

 

thank you so much for your help..

 

boging

 

OK. From your map and equipment diagram i would create something similar to the attached.  it is completely made up / hypothetical -  but shows that risk and  was used to meet the requirement for brc code 4.11.8.1.   

 

you should also consider and add in high care/risk vs low care/risk / raw vs ready to eat.   these too are considerations that could/should be made on how, where, when, what to test.  

 

I hope this helps. 

 

KSR

Attached Files

•  em plan.xlsx   20.6KB   235 downloads

[Charles.C]

Map ? Equipment diagram ? Where ? I am confused.

 

Actually a zoning arrangement is usually directly regarded as a  "risk-based" presentation, eg templates such as -

 

http://www.ifsqn.com...ls/#entry100060

 

The choice of target organisms should be related to yr Process "X".

 

You may also find the BRC interpretation guidelines of some value.

[kingstudruler1]

Map ? Equipment diagram ? Where ? I am confused.

 

Actually a zoning arrangement is usually directly regarded as a  "risk-based" presentation, eg templates such as -

 

http://www.ifsqn.com...ls/#entry100060

 

The choice of target organisms should be related to yr Process "X".

 

You may also find the BRC interpretation guidelines of some value.

since the poster has a EM program I assumed that they have a map, equipment list, etc.  They were concerned about documenting the risk assessment.   the cheesy template i provided would cover risk based zoning as well as demonstrating assessment /justification of the other requirements of 4.11.8.1.  (assessing organisms as you stated, frequency, when to test, methods, equipment considerations, etc).    

[Charles.C]

since the poster has a EM program I assumed that they have a map, equipment list, etc.  They were concerned about documenting the risk assessment.   the cheesy template i provided would cover risk based zoning as well as demonstrating assessment /justification of the other requirements of 4.11.8.1.  (assessing organisms as you stated, frequency, when to test, methods, equipment considerations, etc).    

 

Hi KSR,

 

Ahh! Thks yr clarification. I thought my PC was maybe losing some OP attachments.

 

Indeed such info., eg regarding Product/process would be useful if initially provided..

 

I suspect the OP has what might be called a basic fcs sampling/testing scheme. Not unusual.

 

EMPG is a new element in BRC8 and, typically, feedback suggests that BRC auditors are unsure what level of data generation is required, eg with respect to micro. pathogens/indicators/others.

 

"Risk assessment", risk-based, etc etc are BRC's bogey-men. No other FS Standard afaik bombards the auditee with so many "risk" requests.

 

From BRC's FAQ -

 

WHAT WOULD YOU EXPECT TO SEE FOR A RISK ASSESSMENT, SINCE THE STANDARD BASES MANY OF ITS REQUIREMENTS ON THIS?

 

We would expect to see some sort of documentation as evidence of the thought process and conclusions made regarding the risks to products.

 

However, the principles and objectives behind a risk assessment are to ensure that the company has considered the issues pertinent to the requirements and can justify the reasons for its policy or procedures (and therefore respond to the challenge by an auditor).

 

In some instances it would be appropriate to have a detailed document (along the principles of a HACCP plan) showing those considerations; examples of this could be the risk rating for suppliers and the subsequent approval process, or an inclusion in the HACCP plan of the risks to product from physical contamination.

 

However, other requirements (such as the policy concerning where beard snoods must be worn) could be evidenced in other ways – these could range from a documented policy and the reasoning behind it, to the understanding by staff of the need for its implementation. This policy would include considerations of best practice within the industry and be open to challenge by an auditor. The need for a documented risk assessment would be particularly pertinent where you have decided not to adopt procedures for a particular requirement (such as not wearing beard snoods in a particular area).

 

 

 

Elsewhere BRC note that  "Risk assessments do not need to be long, complicated documents; they must, however, demonstrate which aspects have been assessed ........"

 

Unfortunately, such optimistic comments are, IMO, occasionally confounded by the textual complexity of Clauses in the BRC Standard, eg in risk assessment for incoming raw materials

 

Indeed I think BRC auditors typically enjoy seeing detailed analytical examples such as your excel example albeit bonus points are not on offer.

 

I generally liked yr example (looks like a Consultant's output ?)  although some of the details are, predictably, (highly) debatable. How closely it applies to the OP's process is unknown.

 

Regardless, appreciate yr efforts.

[Charles.C]

Hi boging,

 

Please do not make duplicate Posts. It causes confusion.