11 replies to this topic

[Monica Nunez Garcia]

Hi everyone! I wonder whether you can help me by sharing your experience from a BRC or other certification perspective. I am being challenged as to why we need to have monitoring frequency of every 4 hours for OPRPs (or CCPs). What is the monitoring frequency your establish for your control measures? What is considered industry best practice or accepted by a certification such as BRC?

Thank you in advance!

 

[Charles.C]

Hi everyone! I wonder whether you can help me by sharing your experience from a BRC or other certification perspective. I am being challenged as to why we need to have monitoring frequency of every 4 hours for OPRPs (or CCPs). What is the monitoring frequency your establish for your control measures? What is considered industry best practice or accepted by a certification such as BRC?

Thank you in advance!

 

Hi Monica,

 

The monitoring frequency often depends on what is being monitored, etc etc..

 

BRC afaik makes no use of "OPRP" which is an ISO invention whereas BRC/haccp is based on Codex.

 

Please inform a little context, eg what is the process step/control measure being monitored ?.

[Monica Nunez Garcia]

Hi Charles,

 

Thanks a lot for your answer. 

We use ISO terminology, and although I know other standards don't use OPRPs, I thought the monitoring frequency still applies.

The specific OPRP I am having issues with is filters - we classified them as OPRPs due to the fact that they have to be checked manually, and so there is no instant response in case of failure. At the moment we have a frequency of 4 hour checks, however this is challenging sometimes due to the physical location of the filters.

 

Kind regards.

[olenazh]

Hi Monica; We're with FSSC22000, which is less stricter and more vague than BRC. Our CCP is pH which monitoring frequency is based not on time but product. We check pH of every product batch - that's per company policy and customer request. We have several OPRPs which are monitored differently depending on their nature (e.g. Cooler temperature's checked twice a day, part count for bottle filler is done at every assembly, etc.) I think, monitoring could be done as often as it's convenient for your company and required by your customers - regardless whoever whatever says.

[Charles.C]

Hi Charles,

 

Thanks a lot for your answer. 

We use ISO terminology, and although I know other standards don't use OPRPs, I thought the monitoring frequency still applies.

The specific OPRP I am having issues with is filters - we classified them as OPRPs due to the fact that they have to be checked manually, and so there is no instant response in case of failure. At the moment we have a frequency of 4 hour checks, however this is challenging sometimes due to the physical location of the filters.

 

Kind regards.

 

Hi Monica,

 

IIRC the BRC Standard specifically refers to Codex HACCP. Maybe yr auditor was unaware of the difference. 

 

(usually either a CCP or a PRP in Codex haccp)

 

The monitoring frequency should be adequate to maintain control of the hazard. Presumably any failure will require rechecking of 4 hours of production. If that is OK for you then yr frequency sounds reasonable. ( I guess checking the filter integrity is not exactly an instantaneous activity).

 

PS - a similar query often gets posted here for "testing" a metal detector.

[pHruit]

I've never had an issue with start and end of batch for filters/sieves as a CCP under BRC. A batch would be anywhere between one and twelve hours of production for us.

The comment in the BRC interpretation guide is: Wherever possible monitoring must be sufficiently frequent to ensure that any necessary remedial action can be taken in adequate time so that there is no risk to the product and that no potentially affected product is released for sale or dispatched to the customer. (My emphasis underlined).

 

Dependent on your line design, you might have an entirely reasonable justification that start/end is the only feasible approach. If I take my final sieve out, liquid pours out all over the floor - it's designed to not be possible to run the line without it in place, as that way it can't be skipped...

 

As long as you're doing the post-production check before releasing the stock out of production then you should easily satisfy the latter part of the IG requirement. For the former bit, you'd just have to document and accept that you might need to scrap the batch if the filter fails, although depending on the specifics you might also have a reasonable argument that you could reprocess the stock.

Edited by pHruit, 28 June 2021 - 01:42 PM.

[Monica Nunez Garcia]

Thank you both for sharing your experience and examples, really appreciate it!

Yes, the question is whether it is ok to have an extended frequency of monitoring checks as long as the product is on hold until the monitoring is completed. How long is too long in terms of frequency? Does the hold justify many hours passing (or days) without checking the OPRP?

[Scampi]

Days is way to long for monitoring frequency for an in process step. That sort of monitoring is for incidental issues, like pest control in the storage areas or water potability.

 

You cannot possible contain multiple days of production in the case of a failure.  Ask yourself HOW MUCH PRODUCT CAN I DESTROY

 

You're approach of "as long as it's on hold" is the reason these programs were created. To get away from doing that, if it's important enough that you've determined it needs monitored AND poses a risk that you cannot control in any other way, then you should be checking at a frequency that makes good sense for the business

 

HOLDS should be use when an issue occurs, not routinely as part of the process

 

If you cannot run any other way, change the program and your inventory system, to a QA hold/release.....................NOTHING EVER ships without your approval

[FSQA MKE]

4 hours is appropriate. However, if you run into issues you must determine an appropriate disposition of any affected product (i.e. discard, re-run, hold, etc.). If you can do this, there isn't a problem. Your organization incurs this risk and has appropriate procedures to deal with affected product.

It might not be feasible to check every 15 mins/ every hour or so if it takes say 10-15 mins to take the equipment apart to check. I know BRC gives some freedom to determine appropriateness for various purposes.

Was this a BRC auditor asking this?

[Monica Nunez Garcia]

Thanks for your answers!

It is not a BRC auditor asking, it is more of an internal challenge...some of the filters are not easy to check, therefore the monitoring frequency is extended to 12 or more hours in some cases, as a temporal concession to our internal standard which is 4 hourly checks at the moment. The challenge is why can't we have more than 4 hours, 12 or longer? My point is that we should aim to have a high frequency of checks, even if this involves improving the technology in order to make it possible. I am very interested in continuing to hear about other food safety professional experiences and points of view, so please keep sharing!

 

Kind regards

[TimG]

Good morning Monica,

BRC being a GFSI recognized standard, I assume they require you to 'say what you do/do what you say' which means there is a problem with:

 ..the monitoring frequency is extended to 12 or more hours in some cases, as a temporal concession to our internal standard which is 4 hourly checks at the moment.

Is your 'internal standard' of a 4 hour inspection written down on any forms or food safety documentation? If so, I could easily see a N/C being handed out by the BRC auditor for failure to follow your own internal written PnP.

[Monica Nunez Garcia]

Thanks for this!

 

The issue I have is more around the questions about the right frequency for the filter monitoring checks...there are proposals to extend the current frequency, however I wonder whether this is correct as the control measure is classified as an OPRP - in place to control a significant hazard.

 

Thanks again everyone for your help!