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BRCGS clause 4.15.3 - storage area temperature controls

Started by , Feb 15 2021 09:00 AM
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Hi, in regards to BRCGS clause 4.15.3 and the storage area temperature controls for raw materials, semi-finished materials and final products. Does anyone still record freezer / fridge temperatures manually. Or is it typical to have temperature recording equipment with suitable temperature alarms? If anyone is recording manually, is it done on a 4-hourly basis or at a frequency which allows for intervention before product temperatures exceed defined limits? We don't currently have BRC accreditation but we are working towards obtaining it sometime in the future. We have looked at temperature recording equipment, but with the cost implications, it doesn't look like that is going to happen anytime soon. We would like to continue with a frequency of 8 hours. I think an auditor would have an issue, but would like to know if anyone else has any experience. Thank you

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I've used manual checks in addition to automated alarms (practice already in place, can't hurt to be sure...). Given that you can get calibrated, wifi-enabled data loggers for under £200 these days, I'm struggling to see why you wouldn't do this?

Given that the BRC requirement for 4-hourly is "typically" rather than "shall", you do potentially have a little bit of room to stray from this, but you should expect it to be quite a challenge selling a lower frequency approach to an auditor.

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Hello

 

When you check the interpretation of this clause 4.15.3, it says :

 

''Interpretation Temperature control

Where temperature control is required for the appropriate storage of products, the storage area must be capable of maintaining the required level. Good practice is for doors to close automatically or be alarmed to ensure they cannot be inadvertently le open. Temperature management is usually carried out through the use of automatic temperature-recording systems, which raise an alarm when temperatures fall outside a set range for a defined period (to allow for
the usual defrost cycles). The alarm must be capable of notifying a responsible person outside of normal working hours, either by notification to on-site security, by a home call or by ringing through to a service centre.
Where such automatic systems are not in use, the same level of safeguard to product temperature control needs to be instigated through manual temperature checks. To achieve a similar level of control, manual temperature checks should be carried out on a 4-hourly basis, including during nights and weekends.
The frequency of checks could be reduced where the nature of the product and the insulating capability of the unit are such that the product would remain unaffected by a refrigeration failure of longer than 4 hours (e.g. some frozen products). Ongoing temperature records must demonstrate that product temperature
requirements are being met.
Procedures must specify the frequency of manual checks or the use of automatic continual monitoring systems. All temperature monitoring must allow intervention before product temperatures exceed defined limits for the safety, legality or quality of products.''
 
I don't see the 4-hourly been stretched to 8-hourly happen in an BRC certification. But, as the previously commentary says, why don't go with external thermometer, with don't go with it?
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Thank you for the replies, they back up what i was thinking.

 

We mainly use old containers converted into freezer or fridge units and have around 40 of them, we have looked into an alarmed recording system but because we have lots of units the cost was very high. We do have about half of the freezers on a hourly recording system, although not alarmed, they only give a history of the temperature to the person carrying out the manual check. The system can only handle 20 units (not sure how we would explain to an auditor why only half of the freezers have automatic temp records). 

 

Management know that as soon as we put our current freezer / fridge units (containers converted units) onto an alarm system the alarm will be forever going off. It's not unusual for a freezer unit to trip off and need emptying. My thinking is that if we know that our freezer units don't perform good enough for an alarmed system, then how can they be good enough to extend the four hourly manual checking frequency to 8 hours.

 

The main reason for the 8 hourly checks is so whoever is doing the manual check doesn't need to move stock in the middle of the night.

 

I would not look forward to tying to argue our case to a BRC auditor for 8 hourly manual checks. especially when i don't agree with it myself.

Ah, right, yes, now I understand your predicament - 40 container units is quite significant!

It might be time to line up the relevant senior managers for one of those difficult conversations that occasionally befall people in our line of work? It's not something I envy you for, but the current approach of your managers sounds like it doesn't sit well with some of the senior management committent elements of section 1.1 of the standard...

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What type of industry is yours? 

we make frozen dinners, mainly assembling frozen components together e.g. a fish and chip meal consists of frozen fish portion put together with frozen chips with mushy peas (a fresh ingredient), then frozen  

Hi all,

 

I have another question regarding freezers. What is the best method for validating the temperature distribution in freezers and cold storage in relation to clause 6.1.5 of the BRCGS.

 

'Where variation in processing conditions may occur within equipment critical to the safety or quality of products, the processing characteristics shall be validated and verified at a frequency based on risk and performance of equipment (e.g. heat distribution in retorts, ovens and processing vessels; temperature distribution in freezers and cold stores).'

 

Many thanks, 

the validation for that many freezers would take you a couple of years to do

 

You need to get temperature values from multiple locations in EACH unit, between varying layers of product, repeatedly over time than examine the data--i;m guessing from your previous posts that you won't actually be able to validate them..........

 

Question----are you blast freezing your finished goods or are you adding the mushy peas and then simply moving them into the units?  Packed tight, your exposing the product to a temperature INCREASE as the laws of thermodynamics move both ways

 

 

I validated 1 small blast freezer (8x8) and it took me a month just to get all the data points logged

Hi scampi,

 

Thank you for replying, our meals are quick frozen in a spiral freezer. The finished product are then transferred to an external freezer storage facility. The main use for all our freezers is to store the component ingredients before assembly. 

Gotcha!  That makes more sense

 

You're losing shelf life on your finished goods when the ingredients aren't kept at a relatively flat temperature....particularly the fish---it needs to be super cold.....and stay there

 

Given the history of your units, a 4 hour check is probably insufficient

 

You could do a cost/benefit analysis on the units and product wasted+ shelf life loss to push for a permanent solution

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