We are the dairy industry with IFS and BRC certification looking to modernize the facilities in some areas. During several audits we were told that the laboratory should be preferably located outside the facility, although we do not perform pathogenic. Because of this we are studying the possibility of transferring the lab outside and bringing the maintenance inside the factory. With this situation we reduce the maintenance traffic patterns drastically from outside to inside, which is very good. Nevertheless the laboratory outside needs to have a whole new working plan. What are your thoughts on that? Thank you.
Is there a specific Local Regulatory Directive involved? In some Locations this automatically controls the issue.
If you are implementing internal microbiological analyses/growth procedures, "pathogens" are inevitably a potential "issue" even if not specifically evaluated.
Some Companies use only external testing solely on Principle/Policy, ie the potential risk to their Brand, albeit Low, is considered significantly greater than any operational benefits.
If in-house implemented, the typical minimum requirement is avoidance of any cross-contamination to Operational/Production Areas with respect to chemicals/materials/personnel etc. This usually involves a segregated installation/access-waste disposal routes.
BRC8 Standard, section 5.6.2 (et al) / BRC Interp.Guide details some typical requirements, eg (intro) -
Pathogen testing (including pathogens tested as part of the environmental testing) shall be subcontracted to an external laboratory or, where conducted internally, the laboratory facility shall be fully segregated from the production and storage areas and have operating procedures to prevent any risk of product
Where routine testing laboratories are present on a manufacturing site, they shall be located, designed and
operated to eliminate potential risks to product safety. Controls shall be documented, implemented and
include consideration of:
• design and operation of drainage and ventilation systems
• access and security of the facility
• movement of laboratory personnel
• protective clothing arrangements
• processes for obtaining product samples
• disposal of laboratory waste.
IMEX the last mentioned item above can be particularly problematic.
JFI, afaik, some Importing Organisations require Suppliers to implement internal laboratories/micro testing.