BRC exam question on cleaning validation

Goodmorning Food safety Professionals,

I got a question in BRC exam and my answer was wrong , just curious what you guys think ?


How might cleaning process be validated?

1). Ask the detergent supplier to provide cleaning instructions.

2). Routinely undertake microbiological swabbing and cleaned surfaces .

3). Undertake at [= a ?] trial of cleaning effectiveness under worst case conditions.

4) Ensure regular checks are carried out on detergent dosing equipment.

Thanks in advance!

Hi Namishka,

Number 2?...

What was your answer?

Kind regards,

Ry

I think # 3 - because, # 1 is prerequisite (you cannot perform cleaning without knowing the dosage of detergent), # 2 - routine control measures, # 4 - again prerequisite (detergent dosing equipment must me checked regularly to ensure it works properly)

What you describe, (IMHO) are verifications, not a validation (which is what they asked for)  but you'd have to double check what BRC considers them to be 

What about titrations?  Checking dosatrons for functionality isn't the same as titrating the solution

I found that test to be hard because of questions like this.   I think I would choose 3.   But I also think the 2 is correct.   

Heck,  i'm not even sure what "a trial of cleaning effectiveness" means.  

Hi Namishka,

Number 2?...

What was your answer?

Kind regards,

Ry

Hi RyH, thanks for your answer
My answer was 2 too which was wrong :(.

The "clue" is maybe to match the options against the Codex (+ BRC)  definition/interpretation of Validation.  > 3. (since "trial","effectiveness")

Although I have little doubt that SQF would happily accept 2 and perhaps FSIS also (= "ongoing" Validation). :smile:

#3....Undertake at [= a ?] trial of cleaning effectiveness under worst case conditions. In order to validate a process you have to show that it works using several data points of data and under real life conditions you'd expect to experience. If your procedure can stand up against the worst case scenario conditions after repeated trials, then you know its effective. 

ATP swabs - verification (daily)
APC swabs - validation (monthly)

ATP swabs - verification (daily)
APC swabs - validation (monthly)

It should be one of suggested answers:)

 think it should be 3 as the answer allows for different methods of cleaning and different ways of judging cleanliness..

Cleaning refers to more than the removal of micro-organisms. Material can remain in equipment as a sterilised, physical contaminant, including allergenic material. The cleaning solution itself can remain behind after ineffective rinsing and be a contaminant in its own right.

Hence the worst case scenario.

Use the parallel of washing hands or using a sanitising gel. The gel will (possibly) kill the bugs, but it won't remove the dirt.

 think it should be 3 as the answer allows for different methods of cleaning and different ways of judging cleanliness..

 

Cleaning refers to more than the removal of micro-organisms. Material can remain in equipment as a sterilised, physical contaminant, including allergenic material. The cleaning solution itself can remain behind after ineffective rinsing and be a contaminant in its own right.

 

Hence the worst case scenario.

 

Use the parallel of washing hands or using a sanitising gel. The gel will (possibly) kill the bugs, but it won't remove the dirt.

Hi Foodworker,

Note the use of the word "might" in the objective. So interpretation is permitted.

I could hypothesise potential contexts in which any of 1-4 could "validate" a specific "cleaning process".

BRC trick question ?

(My guess is that in actuality, further restrictions were given on the exam paper [eg Codex terminologies] which have been omitted in the OP )

Clearly #3 is most close to what's defined as 'validation' i.e. under worst case conditions, and this will do for a Food 8 exam.

A comment for the enthusiasts, who already might have read the BRCGS Food Safety Issue 9 draft -- under 2.12, in the HACCP validation section the draft reads: "For existing HACCP or food safety plans [validation] may be achieved using the established processes detailed in clauses 2.12.2 and 2.12.3 [such as, internal audits; review of records where acceptable limits have been exceeded; review of complaints by enforcement authorities or customers; review of incidents of product withdrawal or recall]".

So BRCGS Food 9 appears to accept historical verification-style data in for HACCP validation. The same does not apply for Cleaning validation however so routine ATP/APC swabs are not considered as full validation.

Clearly #3 is most close to what's defined as 'validation' i.e. under worst case conditions, and this will do for a Food 8 exam.

 

A comment for the enthusiasts, who already might have read the BRCGS Food Safety Issue 9 draft -- under 2.12, in the HACCP validation section the draft reads: "For existing HACCP or food safety plans [validation] may be achieved using the established processes detailed in clauses 2.12.2 and 2.12.3 [such as, internal audits; review of records where acceptable limits have been exceeded; review of complaints by enforcement authorities or customers; review of incidents of product withdrawal or recall]".

So BRCGS Food 9 appears to accept historical verification-style data in for HACCP validation. The same does not apply for Cleaning validation however so routine ATP/APC swabs are not considered as full validation.

Hi sztgyi

Off-Topic

If you are correct, it also appears that BRC do not accept the chronological aspects of Validation as espoused by Codex. Perhaps that's why it is a draft.

Validation: proactive verification of that the process is suitable for later use.

# 1: not a verification

# 2: post-process verification

# 4: in-process verification