Internal Audit - BRC Issue 9
I recently started doing food safety internal audits for our company and so excited to learn all I can.
In our recent engagement (scope: 4.1-4.3, 4.7, 8.1-8.3) of the BRCGS Issue 9, I asked for the identification of CCPs in our high-care area map (8.1.1). In my understanding of the standard, it is looking for pathogen controls. I was told the requirement/standard is not about CCPs, rather sanitation procedures. When I asked about documented risk assessment of different production areas, I was told only the high-care area needed a RA. When I asked about the Cook Room and Chiller where our cook and chill CCPs are located, I was told that it doesn’t get a designation (low risk, etc) as it is where the CCPs are.
For the life of me, I cannot understand these responses. What am I missing here? Is my understanding of the standards inaccurate?
We are a food processing company for products with HACCP category of Heat Treated, Not Shelf Stable.
Thank you.
I am lost.
8.1.1 is about pathogen reduction / ccp. "the sites pathogen control step must be on the map" is in the guidance.
8.1.2 and 8.1.3 are more about segregation and not sanitation.
which clasue are you refering to for the risk assessment?
Hi gsgl85,
:welcome:
Welcome to the IFSQN forums.
This question is mainly about 4.3 Layout, product flow and segregation, you are required to assess the production risk zones required for the products manufactured, processed or packed at the site, using the definitions in Appendix 2 of the Standard. For a perishable Ready-to- Eat chilled or frozen product you are likely to have a High-Risk/High-Care Zone to prevent post cooking contamination. For your process, I assume that cooking is a CCP, the importance in zoning is to protect your product from contamination after a kill step has been applied, this extract from BRCGS Guidance on clause 8.1.2 explains their expectation in this situation:
High-risk areas are expected to be self-contained and fully segregated. Best practice is that, where there is a cook step in the production of high-risk products, the cooker becomes the transfer point into the high-risk area via a double-door system (i.e. the cooker is loaded in the low-risk area and unloaded directly into the high-risk area).
I have posted other relevant extracts from the BRCGS Standard and Guidance below.
Categorizing production areas helps to ensure that the appropriate food safety controls are in place and to consider whether the movement of personnel and materials between these areas needs to be restricted. For BRCGS, these production risk zones or areas are classified as:
• open product areas, consisting of:
- high risk (chilled and frozen)
- high care (chilled and frozen)
- ambient high care
• low risk
• enclosed product areas (areas where products are fully enclosed within
packaging and production areas where the product is fully enclosed within the equipment
or pipework such as warehouses and storerooms)
• non-product areas (areas where products are not taken at any stage in
their manufacture or storage such as canteens, laundries and offices).
High-risk and high-care zones for chilled or frozen and ready-to-eat products where there is a risk of contamination.
Ambient high care for products where there is a risk of contamination with vegetative micro-organisms originating from raw materials and the products are stored in ambient conditions (rather than chilled or frozen)
Here is a PRODUCTION ZONE DECISION TREE 1 – CHILLED AND FROZEN PRODUCTS which was included in Edition 8 but is not in Edition 9.
PRODUCTION ZONE DECISION TREE 1 – CHILLED AND FROZEN PRODUCTS.png 890.09KB 0 downloads
It is important to note that the high-risk, high-care and ambient high-care production zones usually only apply to part of a factory’s production processes. These zones typically start when products exit a microbiological kill step and include all the processes and steps until the products are enclosed in packaging.
The auditor will expect to see a documented assessment comparing the products manufactured, processed or packed on site with the definitions within Appendix 2 of the Standard.
Note Clause 4.3.2 Requires a map of the site.
At a minimum, this map shall define:
• production risk zones, where product is at different levels of risk from pathogen contamination – for example, high-risk, high-care, ambient high-care, low-risk and enclosed product areas (see clause 4.3.1 and Appendix 2)
• access points for personnel
• access points for raw materials (including packaging), semi-finished products and open
products
Where a site identifies the need for a high-risk, high-care or ambient high-care production zone, the relevant clauses from section 8 will apply to those areas.
8.1 Layout, product flow and segregation in high-risk, high-care and ambient high-care zones
8.1.1 The map of the site (see clause 4.3.2) shall include the location of the pathogen control step(s)
The following clauses that you quoted are not relevant for this discussion:
4.1 External standards and site security
4.2 Food defence
4.7 Maintenance
8.2 Building fabric in high-risk and high-care zones
8.3 Equipment and maintenance in high-risk and high-care zones
Kind regards,
Tony