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BRC 4.8.5 Environmental Monitoring Programmed - Can it be avoided with a Risk Assessment


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NHer

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Posted 15 March 2021 - 05:34 PM

As per BRC packaging issue 6 clause 4.8.5:

 

"Where appropriate, based on risk, a microbiological environmental monitoring programme shall be in place"

 

Does this mean if we do a Risk Assessment and be able to highlight that the risk is low that we don't need to create a Microbiological Environmental Monitoring Programme? Is this possible to satisfy this clause?



BGAQA

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Posted 15 March 2021 - 10:53 PM

I would suggest that in order to determine the appropriateness as to whether a monitoring program needs to be in place that you would conduct several environmental swab tests. If you get a good outcome from that then you will be on the way to being able to validate your risk assessment.

 

The intended use of the packaging would also play a significant role in the appropriateness of a monitoring progam.



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beautiophile

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Posted 16 March 2021 - 01:39 AM

Two years ago, BRC made the p558 amending to Issue 5 about this concern and clearly said:

 

Most packaging materials are unsuitable for the survival and growth of pathogens and therefore will not require an environmental monitoring programme to be in place.

I don't know why they dropped this line in the interpretation document of Issue 6. However, this thing has been a common knowledge (for decades) of conventional packaging materials, e.g. petroleum-based plastic or glass or metal. A risk-assessment is certainly required for new bio-materials and the Clause must fully apply.

One problem is if the Auditor has such kind of knowledge. Our company got an NC of this because we stated no needs for our ordinary plastic pouches, by an auditor who doesn't even know that PET is a polyester.  :whistle: Lesson learned: don't hire CBs scoring less than 4 stars from BRC.

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NHer

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Posted 16 March 2021 - 09:48 AM

Thanks Beautiophile,  In the document for "issue 6 - guide to key changes" it was stated there that p558 is only effective until 31st Jan 2020 when Issue 6 goes live.

 

My concern now is since that the statements wasn't included in Issue 6 does that mean that even though we are a non food contact packaging manufacturer do we now have to implement an Environmental Monitoring programme even though our risk assessments concludes that we don't need to?

 

Would you be able to let me know where you got the information on your second image?



Charles.C

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Posted 16 March 2021 - 12:45 PM

As per BRC packaging issue 6 clause 4.8.5:

 

"Where appropriate, based on risk, a microbiological environmental monitoring programme shall be in place"

 

Does this mean if we do a Risk Assessment and be able to highlight that the risk is low that we don't need to create a Microbiological Environmental Monitoring Programme? Is this possible to satisfy this clause?

 

Hi NHer,

 

Based on previous BRC threads there seems to have been some auditorial confusion regarding "swabbing necessity" for any of  - 

 

(a) food contact

      (1) pathogens

      (2) non-pathogens

 

(b) non-food contact

      (1) pathogens

      (2) non-pathogens

 

Assuming supported by risk assessment (and position statement), answers for a1, b1 seem to have been generally  "not required". Offhand, based on previous BRC threads (relatively few) the answers for a2, b2 seem to have often been "required" but not 100% of the time.

 

For some examples see this Post and links within (and subsequent sub-links) -

 

https://www.ifsqn.co...mp/#entry160959

 

PS - JFI analogous hassles erupted for SQF Packaging also. Some threads are mixed together.


Edited by Charles.C, 16 March 2021 - 04:31 PM.
edited

Kind Regards,

 

Charles.C


beautiophile

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Posted 17 March 2021 - 12:59 AM

Thanks Beautiophile,  In the document for "issue 6 - guide to key changes" it was stated there that p558 is only effective until 31st Jan 2020 when Issue 6 goes live.

It makes sense since p558 belonged to Issue 5.

 

My concern now is since that the statements wasn't included in Issue 6 does that mean that even though we are a non food contact packaging manufacturer do we now have to implement an Environmental Monitoring programme even though our risk assessments concludes that we don't need to?

If Auditor says so, you have to do despite his ignorance. He's got power and right to issue certificates. You can only complain (as a client) to his CB management or BRC.

 

Would you be able to let me know where you got the information on your second image?

DIPAK K. SARKER: Packaging Technology and Engineering, Pharmaceutical, Medical and Food Applications


Edited by beautiophile, 17 March 2021 - 01:01 AM.


johnmcip

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Posted 17 March 2021 - 06:17 PM

I'm not sure about packaging, but BRCs food safety programs interpretation guideline specifically states that you are not allowed to use risk assessment to avoid this requirement. I would suggest you look in the interpretation guideline for packaging to see if its there. If its NOT there, the other comments in this thread should be helpful.

 

Also to Charles the moderator, sorry for being kinda pissy in that other thread.



beautiophile

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Posted 18 March 2021 - 12:58 AM

I'm not sure about packaging, but BRCs food safety programs interpretation guideline specifically states that you are not allowed to use risk assessment to avoid this requirement. I would suggest you look in the interpretation guideline for packaging to see if its there. If its NOT there, the other comments in this thread should be helpful.

 

Also to Charles the moderator, sorry for being kinda pissy in that other thread.

Hi John,

The thread mentions the production of packaging materials, no food or any edible stuff involved. The context is completely different.



johnmcip

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Posted 18 March 2021 - 02:54 PM

Hi John,

The thread mentions the production of packaging materials, no food or any edible stuff involved. The context is completely different.

 

Yes I understand, but the food safety standard specifically states that you cannot risk assess your way out of EM, and that's the only place where it states that specifically which I find odd. I'm just advising you to check for similar language in the packaging standard.



beautiophile

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Posted 22 March 2021 - 01:35 AM

Yes I understand, but the food safety standard specifically states that you cannot risk assess your way out of EM, and that's the only place where it states that specifically which I find odd. I'm just advising you to check for similar language in the packaging standard.

Thank you. I did. BRC/IoP uses a more generic language so that it can apply more flexibly for other purposes (pharma, cosmetics, kid-toy package), for example: HARA instead of HACCP. However, HACCP can be a format of HARA, still they're not synonyms.

BTW, the packaging is not a part of the food industry. It provides various options of containing, food producers pick what is suitable for them. A problem here is to find the extent of food safety application and that may require a different perspective.






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