13 replies to this topic

[AJL]

Hi,
Based on the newest BRC guidance for risk zoning,can I place a frozen dairy desert (enclosed for majority of process) which is defrosted prior to consuming, as low risk?.

[GMO]

Hi, when you say "enclosed for majority of process" is there any part of the process under consideration which is open?  Because "majority" suggests there is?  If so, that product will be consumed without further heat processing and must be kept frozen or chilled prior to consumption.  Therefore, it's a high risk area where the product is open (if every component has had a 70oC / 2 min or equivalent heat process) or it's a high care area if you have for example, fresh fruit added.

 

I can't see justification for otherwise?  Unless the product is fully enclosed for the whole time?

[AJL]

The product is exposed briefly during filling.
In the risk guidance document, it names that some products do not fit the expected risk category.

[GMO]

So if you have a product exposed during filling, you have something which is a dairy dessert, defrosted prior to filling.  On defrost at a consumer home, that dessert could be subject to growth of pathogens, including Listeria monocytogenes which will have survived freezing.

 

Convince me, why should that be low risk?  I can't see it?

[AJL]

Hi GMO,
Valid points, agreed. It is important to ensure that the product is free from listeria at start shelf life.
If it is free from listeria at start shelf life, the defined shelf life (1 day) after defrosting will not give growth of Listeria.

Have you read the document in its entirety. There is a section in the document 'products that do not meet the expected risk category '.

[GMO]

But that's the specific point of a segregated high care or high risk area, to prevent the initial contamination with Listeria monocytogenes.  So what's your rationale for trying to get around that and how is it food safe?  

 

The kind of exceptions to risk zoning I see in the standard copy I have are things like hard cheeses, where there isn't likely growth of pathogens, however, they are susceptible to spoilage.  That's not the case with yourself where you have high potential for contamination, high potential for growth within your work in progress ingredients, environment etc and high potential for consumers to misuse and keep chilled for longer than one day, possibly after temperature abusing it by bringing it out first.  Can you reference which page you're relying on here?

 

I assume you're trying to claim your production process prevents Listeria monocytogenes contamination (how can it consistently if it's not high care or high risk though?  Please don't tell me your control is by testing each batch...)  And I assume you're relying on consumers following the pack instructions.  I have bad news for you there...

 

The whole point of BRCGS etc is about derisking your product to consumer harm.  But sadly all GFSI audits are hamstrung by the standard.  It's not about passing an audit for audit's sake.  What is the safe option for the consumer, not what is the loophole so we can get away without investment if that makes sense? 

 

I'm not trying to harangue you, but I recently heard about a supplier who had switched their zoning and reduced standards by claiming their product was "ready to cook".  It isn't.  It's ready to eat or reheat.  But the reason they did that was to prevent them having to invest.  What they made was a product which could be eaten hot or cold but just changed their packaging to put on it "must be cooked before eating" and actually lowered standards in their plant as a result.

 

They will kill someone eventually unless they actually wake up.  But they will probably pass their BRCGS audit because the auditor isn't looking for risk in the way a risk or independent auditor, unfortunately the scope of GFSI audits is looking for compliance.  If I've misunderstood, I apologise but I urge you not to be that kind of site.  Genuinely think about risk.  Then do the right thing.

[AJL]

Ok page 8- products which do not fit the expected risk zones.

Of course our controls are not testing finished products.
We aren't cowboys - I'm here aren't I? 🙈
I think you might have gotten the wrong end of the stick.

You must be able to appreciate that I understand the risks involved.

Would you just check page 8 when you have time and come with your thoughts. ☺️

[GMO]

Page 8 at least in the English edition includes:
The announced audit programme (with the once every 3 years unannounced)

Blended announced

Unannounced

Additional modules.

 

Nothing on risk zoning, that's at the end of the standard.  Sorry you're going to have to spell this out to me.  What do you want and why do you want it?  

[chrisrushworth]

Appendix 2 - PAGE 141 of standard

Production risk zones section... i assume is the part of the standard your on about?

 

 

However on reading what you have stated... 

I have to agree with GMO, what's your justification for the lower risk?

 

From your explanation your High care as its RTE with no further kill step to mitigate the food safety risk?

 

 

Open product - as you having "filling" - thus your open product not enclosed product

• Potential for spoilage organisms
• Finial product susceptible to growth of pathogens but production process doesn't include a full cook (kill step)

Low care determined as -

1. Do not support growth of pathogens - you have stated DAIRY.. which will grow..
2. Designed to undergo a later "killstep" - you have stated DEFROST and eat 1 day life..

 

Thus your high care/risk determined by the other steps in your process...

Edited by chrisrushworth, 31 March 2025 - 11:28 AM.

[AJL]

Hi GMO, there is a seperate publication called 'understanding risk zones'. That is the document I am referring to. ☺️

Edited by AJL, 31 March 2025 - 04:51 PM.

[GMO]

Hi GMO, there is a seperate publication called 'understanding risk zones'. That is the document I am referring to. ☺️

 

Interesting.

 

I do not have that document, it doesn't look like one which is freely available.  So I'm not honestly prepared to pay.

 

But be warned, whether you are concerned about actual risk to the consumer or about audit risk, one auditor pointed out to me once (when I raised with her she was misinterpreting a clause) "I do not audit against the interpretation guide!"

 

The standard is pretty clear on this.  You're going to have to share what it is in that document which is so earth shattering and removes the consumer risk for your product I'm afraid.  I won't be spending £70 to find out...

[AJL]

No worries GMO ☺️
Thanks for the discussion. I won't share the document as it isn't allowed in the forums, right?
Number one for me is risk to the consumer, anyone who isn't shouldn't be able to pass an audit. That's number 1.
We have a safe process with the controls in place (I can see that as we do a LOT of verification activities).
Yes you are right that sometimes it comes down to investment.
I have previously worked at sites with high care facilities.
The cleaning practices were terrible and despite having segregated zones, I would never have passed them if I audited them. Absolutely terrible.
Despite having no dedicated risk zones, I have 100% confidence in the controls applied, which focus mainly on the food contact equipment but also the general production area.
I would be interested in hearing how some sites are able to use valid risk assessment to show compliance to 80% say of the high care section.
For example I think that the whole idea of seperate changing facilities for a start, make the high risk/low risk very difficult!

[AJL]

Further from the tone, have I touched a nerve? You seem rather frustrated, that wasn't the intention. Am I able to share a short section of the document in the forums here?

Edited by AJL, 31 March 2025 - 07:37 PM.

[GMO]

I suppose the nerve that has been touched is that compliance to 80% of the high care / high risk practices isn't compliance.  It's up to you, it's not my site.  But I'm passionate about food safety.  I've dedicated my life to it.  And the point of high care and high risk is to exclude pathogens like Listeria monocytogenes as much as possible. Even if you've seen it done badly, it doesn't make what you're doing not dangerous.

 

If anything separate changing facilities can be very easy to resolve.  If you share the areas you're not able to comply, it might be possible that we can help?  But to try and twist and turn around to justify it.  Well yes it does touch a nerve.  It sounds a lot like the site I was referring to earlier.  Rather than comply they found an excuse.