Does primary conversion section 5.9 of BRCGS Version 9 apply to lobsters?

Does primary conversion section 5.9 of BRCGS Version 9 apply to lobsters, if you are only cooking them whole or freezing whole raw lobster? 

Hi NatalieJessome,

:welcome:

Welcome to the IFSQN forums.

An interesting question.

According the BRCGS definition then 5.9 is not applicable for whole lobsters, BRCGS Global Standard Food Safety defines Animal Primary Conversion as follows in the glossary:

Sites that complete the slaughter and/or evisceration of animals (including red meat, poultry and game) or the slaughter and/or gutting of fish. (Applicable sites will therefore fall within BRCGS product categories 1, 2 and 4*.)

*Category 4 includes wet fish, molluscs, crustaceans but only fish are mentioned in the defeinition.

There are some elements of Section 5.9 that are applicable but covered by other sections of the standard for example 5.9.1 risk assessment for potential prohibited substances should be covered in 3.5.1.1:

The company shall undertake a documented risk assessment of each raw material or group of raw materials, including primary packaging, to identify potential risks to product safety, authenticity, legality and quality. This shall take into account the potential for:

……..

• any risks associated with raw materials which are subject to legislative control or customer

requirements.

Similarly, 5.9.4 time and temperature requirements should be covered as in clause 6.1.1 which requires documented process specifications.

My main question would be, are you receiving live lobsters? If so an inspection as per 5.9.2 would seem appropriate but again this could be part of 3.5.2.1 procedures for the acceptance of raw materials and primary packaging on receipt.

In summary if you comply with all other elements of the BRCGS standard then you will more than likely comply with section 5.9 anyway.

If you are receiving live lobsters, I personally would check with your certification body to see if they consider section 5.9 appropriate for your scope of certification.

Kind regards,

Tony