4 replies to this topic

[wendyh]

I hope someone can offer me clarification of high-risk vs. high-care zones as it relates to BRC. I read Appendix 2 and I'm really not seeing the difference between the two. Our facility has a variety of products, cooked soups, RTE salads, oven baked panned products, and RTE precooked chicken. Further, our facility is old, original building erected in 1945, so we basically have built around the processes to the best of our ability. 

 

Thank you,

 

Wendy

[GMO]

In practical terms, the BRCGS standard allows for some leeway on high care and high risk controls.  However, the main difference is high care doesn't have fully cooked components into that area, so that might include salads which are washed in through a process which isn't as effective as cooking.  A high risk area will be fully cooked.  

 

It is possible to have areas which produce foods with fully cooked items and also some which have "high care" type ingredients.  An example of that could be a ready meal with fresh spinach added or a sprig of fresh parsley.  (Damn those marketing people.)

 

The wording in the standard if you look at it is slightly weaker for high care.  This is in recognition I believe that some high care applications cannot have full barriers between low risk and high care.  For example, in sandwich making you can't have a full barrier and effective sanitiser tunnel for bread, even washed in with the wrapper, it would frankly leave it a soggy mess (and the UV ones wouldn't fully work).  So there's an acceptance with high care that the barrier control is slightly weaker.  What you tend to have instead is no raw meat being cooked into the high care area at least not from the same location as the low risk ingredients coming in without full 6 log reductions (e.g. bread, produce washing etc.)

 

So with your mix of products it's worth trying to maximise the barriers as much as you can (as close to high care standards as possible) and then those barriers where you can't, I'd look at the genuine Listeria "pressure" on those barriers.

 

So for example, if you do bring in raw chicken on your site, but you have a separate, segregated area with segregated staff who only work in that raw area and that's all cooked in, great.  Then if perhaps the other end of your factory a completely different team are washing in your salad?  Brilliant.  The problem will come if you have one low risk area where you're washing in salad and processing raw chicken.  That's a disaster waiting to happen.

 

Also 1945?  I'd check your drains.  With a factory that's old and has grown and grown that would be a big worry.  How are your environmental Listeria swabs looking?

[GMO]

Not sure if this helps but here is some key wording from the standard on high risk:

 

Where high-risk areas are part of the manufacturing site, there shall be physical segregation between these areas and other parts of the site. Segregation shall take into account the flow of product, the nature of the materials (including packaging), the equipment, the personnel, the chemicals, the disposal of waste, the flow of air, the air quality and the provision of utilities (including drains). The location of transfer points shall not compromise the segregation between high-risk areas and other areas of the factory. Practices shall be in place to minimise the risk of product contamination (e.g. the disinfection of materials on entry).

 

And high care:

 

Where high-care areas are part of the manufacturing site, there should be physical segregation between these areas and other parts of the site. Segregation shall take into account the flow of product, the nature of materials (including packaging), the equipment, the personnel, the chemicals, the disposal of waste, the flow of air, the air quality and the provision of utilities (including drains). Where physical barriers are not in place, the site shall have undertaken a documented risk assessment of the potential for cross-contamination, and effective, validated processes shall be in place to protect products from contamination, including the procedures for changeover from low-risk to high-care.

 

See how it's a toned down version?  And that latter risk assessment is what I'm talking about. Recognise that the processes to bring in "high care" type ingredients are not as robust as cooking and so you need to understand the risk before the decontaminating process and whether those processes will be effective.  That will depend a lot on what is on your low risk side and your layout.

[wendyh]

Thank you for your response. This is very helpful. 

 

Cheers!

[GMO]

No problem at all.