1 reply to this topic

[FSQA-D84]

Hello Everyone, 

 

I received a non-conformance on a BRC audit pertaining to our CIP System.  The nonconformance was, "There is no documentation to support the validation of the design and operation of the system."  I am not familiar with this process.  Does anyone have information?  Where do I start?

 

We have cleaning validations, but the auditor was referring to validation the flow rate, pressure, time, etc. 

 

Any help is much appreciated. 

 

Thank you!

 

[Tony-C]

Hi Deonna,

 

Welcome to the IFSQN forums

 

If you don’t have the internal expertise then you will need to get the CIP equipment manufacturer or a contractor in to validate the design and operation of the CIP system.

 

BRCGS Global Standard Food Safety Issue 9 requirements are:

4.11.7 Cleaning in place (CIP)

4.11.7.1

All CIP equipment shall be designed and constructed to ensure effective operation. This shall include:

• validation confirming the correct design and operation of the system

• an up-to-date schematic diagram of the layout of the CIP system

……. etc

 

BRCGS Global Standard Food Safety Issue 9 Guidance offer this:

Interpretation - Effective operation, maintenance and validation of CIP systems

Effective CIP starts with the design (e.g. designed by an approved equipment supplier – see section 4.6 for information regarding new equipment) and set-up of the system. The site will therefore need validation to confirm that the design, set-up and proposed operation of the system are suitable for the intended use.

For example:

• knowledge of the layout of the pipework and the position of valves, spray balls and holding tanks is essential to ensure that the system will operate consistently and effectively and that there are no dead spots or areas where cross-contamination between cleaning chemicals and product can occur

• correct design of the CIP system to ensure good coverage of cleaning solutions with suitable drainage to avoid pools of solutions; for example, the prevention of shadows caused by baffles or spray balls that have been incorrectly located

• assurance that the intended cleaning will be effective (e.g. that the food/products intended to be used on the equipment will be effectively removed during cleaning)

• consideration of the risk of potential contaminants (e.g. allergens) from previous products being re-introduced onto the equipment during the collection, recycling or re-use of solutions (e.g. rinse solutions). Where rinse solutions are recovered and re-used, there should be a specific risk assessment to prevent cross-contamination; for example, due to allergens or the existence of different production risk zones in the site. See clause 8.5.4 for the specific requirements for CIP systems operating in multiple production risk zones (e.g. high-risk and high-care areas). Confirmation of the correct design and set-up may be achieved by an inspection report (e.g. from the equipment manufacturer) or by separate documented validation.

A schematic plan or diagram should be provided by the supplier when the system is installed and must be updated whenever a change is made, including to software, equipment and operation of the system.

 

Also I would consider changing your IFSQN username as using your email address could attract spam emails.

 

Kind regards,

 

Tony