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High Segregation and physical barriers

Section 8.1.3

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Posted 31 October 2019 - 09:21 AM

Where physical barriers are not in place, the site shall have undertaken a documented risk assessment of the protential for cross-contamination, and effective, validation porcesses shall be in place to protect products from contamination.


1. I need help with what this section means

2. What level/type of risk assessment can support the idea of not having a physical barrier?

3. The clause does not talk about a barrier that is completely from ceiling to floor, so is it possible to use movable screens for segregation?


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Posted 31 October 2019 - 09:53 AM

Usually this depends on how liberal your auditor is prepared to be & what standard they are auditing against (ie. GFSI or their own) you have not included this or your product type?...


I worked at a factory that produced chocolate biscuits for Mondolez & their standard had this requirement.


Unfortunately there was no way to fully implement floor to ceiling barriers without huge cost (which eventually would have been passed on to the customer) so, in this case they were prepared to allow a risk assessment (we gathered data on environmental swabbing results & controls on handwashing, GMP audit results, finished product test results etc. and made a case for a waist high movable barrier).


If your auditor is auditing against BRC/SQF/FSSC 22000 they might not be so accommodating (costs would not be passed on to them so no implication for them if they give you a costly major NCF during audit).

Also, if the category is raw meat/cooked meat this would probably not be appropriate as the risk level is much higher?..

Edited by LesleySR, 31 October 2019 - 09:53 AM.

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