BRCGS 4.3.1 - Layout, Product Flow and Segregation

Looking for an help / insight into clause 4.3.1 Layout, product flow and segregation in BRC version 9,  specifically around the Risk Assessment for zoning assignment. 

I have submitted my CA, however NSF keeps rejecting it:(

Greetings Jeff,

Please provide more context. what is the wording of the N/C, what did you do in your CA and what is the response from NSF on rejecting it ?

Regards.

Hi, 

Can you please share your risk assessment? 

;)

Minor -  Site maps showed production areas, employee breakroom and facilities, and the warehouse, however the zones are not designated per the BRCGS definitions (low risk; enclosed products with no High Risk, High Care or Ambient High Care). There was no documented risk assessment for zone assignment.

CA - A risk assessment was conducted on the production risk zones based off the BRCGS definitions. This includes High Risk, High Care, Ambient High Care, Low Risk and Non-Product Areas. See Personnel Movement Map and the Zone Risk Assessment.

Reviewer Comments - submitted evidence does not provide sufficient info on designation of zones as per BRCGS definitions - please provide corrective action on this matter. 14thNov - submitted site map still does not include zones as per BRCGS definitions - low risk, enclosed products, high care or ambient high care, etc where applicable). Please update submitted document with relevant terminology and where within the site those are located

I may be wrong, but I fail to see how the terminology is not included in the R.A. you have provided. Is there a chance the reviewer hasn't understood that the coloring in the first excel tab corresponds to the coloring in the second ??? Maybe add some written clarification for them ? Maybe also rename the second tab like "Personnel Movement & Zones".

It kind of feels silly in my opinion at the moment, but maybe I miss something that another expert in the forum can detect.

The only thing I would argue is that the R.A. can't only take into consideration "Severity" but other elements too, like Possibility of occurence or Likelihood or Possibility of detection through current measures etc (the terminology for this is quite extensive) and the result derives from a set calculation. However, this is another matter for another day.

Hi, 

Please see document attached, I believe there is lack of consideration and I would remove staff zone movement. 

;)

Hi Joell,

Your assessment appears to have been accepted by NSF and so now you need to address the zoning in your map plus the other items listed below from clause 4.3.2 below. Your map appears to designate equipment as areas rather than the whole area. For example, it looks like your low risk open product area is in fact from T1 to BJ1 x T32 to BJ32 on your excel sheet Personnel Movement.

BRCGS Global Standard for Food Safety Issue 9 clause 4.3.2 states:

There shall be a map of the site. At a minimum, this map shall define:

• production risk zones, where product is at different levels of risk from pathogen contamination – for example, high-risk, high-care, ambient high-care, low-risk and enclosed product areas (see clause 4.3.1 and Appendix 2)

• access points for personnel

• access points for raw materials (including packaging), semi-finished products and open products

• routes of movement for personnel

• routes of movement for raw materials (including packaging)

• routes for the removal of waste

• routes for the movement of rework

• location of any staff facilities, including changing rooms, toilets, canteens and smoking areas

• production process flows

• any areas where time segregation is used to complete different activities (for example, time segregation for high-care areas).

BTW I would advise you to change your username from your email address as it is likely to attract spam.

Kind regards,

Tony