GFSI requirements for Positive Release and Environmental Monitoring

Hi all,

regarding GFSI reqirements for Positive release. Do any of the GFSI schemes require positive release protocols to be in place.  I don't see in SQF, BRC, FSSC, or IFS that it is required to test finished product for salmonella before it is released. is it defined for frequency and attribute for testing.  Same questions for Environmental Monitoring.  I know the schmes require the program, but frequency and requirements are not defined.  why is that.  is it more of a customer requirement?

Thanks

Hello,

I completely understand where your coming from. These areas are vague but they are vague for a reason. The frequency and protocol are not included because these programs are very dependent on your product and facility layout - overall risk. For instance, our product release does not require any testing before shipping. Our program includes a checklist for proper quantity, weight, quality, labelling packaging and so on.

For environmental monitoring, you will need to do a risk assessment. What is the risk of your product? We have low risk products here so our frequency for environmental swabbing occurs on a quarterly basis. The pathogens you choose to test are also dependent on your product and you can research which are most common for your product. You can justify your choice by showing the auditor your research from accredited sources or stating in the program why you chose these pathogens to test. The results of your EMP will help define your frequency as well. If you start out with a monthly program for example, but your counts are very high, you may want to re-evaluate and increase frequency. 

I hope this helps!

The reason nothing is defined specifically is due to the fact that the type of product, process and size of facility varies greatly from facility to facility.  For example a facility under 30,000 sq. ft. bottling salsa vs. a 200,000 sq. ft. facility packaging flour are going to have two different programs.

It's all based upon the risk of your facility taking into account the product, process, facility size, packaging type, etc.

Try to keep your positive release simple.  A lot of times it can get over complicated and give production and warehousing a headache.  If products do not require micro testing still establish a time before they can ship out of your facility to your customers.  Most of the time you want to do a 24 hour paperwork review but when I worked in beverages we used a 3 day release before products could go out to the customer because we were hot filling products and they would stay hot for at least a day.  Now I am in spices and we have a manufacturing and distrubution center.  I still make sure to complete my review within 24 hours but the product is not going to leave the facility for at least 48 because of shuttling from 1 faciltity to the next.  I don't hold up on the shuttling just the shipping out to the customer.

Hi all,

 

regarding GFSI reqirements for Positive release. Do any of the GFSI schemes require positive release protocols to be in place.  I don't see in SQF, BRC, FSSC, or IFS that it is required to test finished product for salmonella before it is released. is it defined for frequency and attribute for testing.  Same questions for Environmental Monitoring.  I know the schmes require the program, but frequency and requirements are not defined.  why is that.  is it more of a customer requirement?

 

Thanks

PR  is defined and implicitly required in BRC8.

PR is implicitly stated/required in iso22000 for non-conforming products.

PR is implicitly stated/required in ifs for non-conforming products.

As per Post 3, detailed criteria will inevitably be case-by-case

BRCGS V8 expects you to risk-assess products and processes at the NPD stage, with a tie-in with the HACCP plan…

Clause 5.1.1 states:

“The company shall provide clear guidelines on any restrictions to the scope of new product developments to control the introduction of hazards which would be unacceptable to the site or customers (e.g. the introduction of allergens, glass packaging or microbiological risks).”

Clause 5.1.2 states:

“All new products and changes to product formulation, packaging or methods of processing shall be formally approved by the HACCP team leader or authorised HACCP committee member. This shall ensure that hazards have been assessed and suitable controls, identified through the HACCP system, are implemented. This approval shall be granted before products are introduced into the factory environment.”

By the time you get to section 5.6, the standard simply requires that you apply the outcomes from those original risk assessments to your product inspection and testing programme.

Clause 5.6.1.1 states:

“There shall be a scheduled programme of product testing which may include microbiological, chemical, physical and organoleptic testing according to risk. The methods, frequency and specified limits shall be documented.”

Clause 5.6.1.3 states:

“The site shall ensure that a system of validation and ongoing verification of the shelf life is in place. This shall be based on risk and shall include sensory analysis and, as applicable, microbiological testing and relevant chemical factors such as pH and aw. Records and results from shelf-life tests shall verify the shelf-life period indicated on the product.”

So for finished product testing, you need to address food safety hazards such as pathogens as well as spoilage and quality factors. The upshot of all this is that if your HACCP identifies a food safety risk from pathogen viability/proliferation then you’re likely to need to use positive release as a control for every batch. Conversely, if your HACCP determines that there is no risk to consumers from pathogens, scheduled surveillance testing will be sufficient.

The rationale is majorly routed in the outcomes from your HACCP assessment. High risk products such as RTE salad or cooked meat will be subject to food safety risks in the form of pathogens, whereas a product like a plain biscuit is unlikely to need to be subject to positive release. In either case, your NPD process and HACCP assessment will determine testing requirements including microbiological species and testing frequency.