1 reply to this topic

[WhySoCereus]

Hi All, 

 

I'm looking for some guidance here. Conducting a risk zoning exercise and formal risk assessment to conform with BRCGS I9. The facility is manufacturing fermented soybean cakes (tempeh).

 

The ownership of the facility is saying that the product is certainly low-risk throughout the production process. I want to agree, but also want to make sure that I'm making the most accurate assessment and covering ourselves in prep for the first BRCGS audit.

 

At this facility, the product is acidified to a pH of 4.5 (CCP) or below prior to innoculation (both to support ideal growing conditions for the mould culture, but also to prevent sporulated pathogens from growing during fermentation. Once fermented, the tempeh is pasteurized (CCP), both to get rid of any pathogens, and to inactivate the culture. After cooling (CCP), it's vacuum packed, sometimes with a marinade (not pasteurized).

 

The facility currently treats the whole process as low risk.The products all have validated cooking instructions (very easy to achieve) and clear wording on the packaging that it is NOT a RTE-food, as well as a general understanding that consumers do not eat this product raw (due to taste/texture). While I agree with all of this, I'm nervous about the auditor seeing that the product does go through a pasteurization step (6.5D Salmonella spp.), and immediately calling it high-risk. The facility does not have the capability to run any of their process as high risk, or even high-care.

 

Any advice?

[Tony-C]

Hi WhySoCereus,

 

Low risk as explained using the information provided below provided this is stored chilled/frozen. Though I would be making it perfectly clear on the label that the product requires cooking and is not to be eaten raw.

 

Guidance is given in the BRCGS Standard Appendix 2 Production risk zones – high risk, high care and ambient high care so make sure you are fully up to speed with that. BRCGS also published a BRC Food Standard 8 Production Zone Decision Tree 1 in Issue 8 which is posted below:

 

 BRC Food Standard 8 Production Zone Decision Tree 1.jpg   165.41KB   0 downloads

 

Step 1 Are the final products stored ambient, chilled or frozen

> chilled or frozen

Step 2 Are products or ingredients within the area open to the environment (i.e. neither packaged nor fully enclosed in tanks or pipes etc.)?

> Yes

Step 3 Does the product support the growth of pathogens or the survival of pathogens, which could subsequently grow during the normal storage or use of the product unless stored chilled or frozen?

> Yes

Step 4 Does the area contain products which. on the basis of cooking instructions and known customer use*, undergo full cooking** prior to consumption?

> Yes

> Low-risk area - for example, raw meat, vegetables (e.g. potatoes), prepared meals containing raw protein, frozen pizza, unbaked frozen pies

 

You might find this topic useful: Assessment for Production Risk Zones based on Clause 4.3.1 of BRC Issue 9

 

There may be others, search the BRCGS - Food Safety Forums

 

Kind regards,

 

Tony

[Scampi]

I cannot believe I need to keep saying this stuff........(sorry but it's a source of frustration)

 

Your #1 goal should be meeting REGUALTORY requirements-----and then adjust (if needed to appease the GFSI audit scheme)

 

https://www.canada.c...-eat-foods.html

 

https://inspection.c...ling-procedures

 

So have a REALLY good understanding of the 2 links provided and then determine next steps

 

While you're product WITHOUT added marinade would be considered low risk, once you've added the marinade (unpasteurized) it is no longer low risk