Guidance on clause 4.3.6 please

I have a small production unit that makes ready to eat chilled products. We have a physically segregated high care area with its own changing area, pot wash, personnel. We have production flow diagrams to show we've minimised cross overs and we have various controls in place to limit contamination. The only thing we don't have is control of air flow.

It is my considered belief that the size of the operation, type of products and historical micro results means we shouldn't need pressurised air flow system or air filters etc, etc. In my heart I can justify why the safety of the product isn't compromised but I'm not sure if BRC would agree and I'm not sure how to draw up the supporting evidence to my opinion.

Can anyone give me the guidelines/interpretation of this line of the standard -  'Segregation shall take into account the flow of product,nature of materials (including packaging), equipment, personnel, waste, airflow, air quality and utilities provision (including drains)'

What are your thoughts?

I should point out that last year's auditor commented that the +ve air pressure was low and my predecessor took the NC and closed it out with a tick box exercise rather than state that we had no specific control of air quality or pressure in the high care area.

Thanking you in advance

I think the rest of that clause gives you the answer.

Where physical barriers are not in place, the site shall have

undertaken a documented risk assessment of the potential for cross-contamination, and eff ective,

validated processes shall be in place to protect products from contamination.

So I'd risk assess it.  If the air flow is not a major issue (and presumably it isn't if you're not getting micro concerns) then that can be the basis of your risk assessment.  I'd also do some air monitoring to verify it.