Food Safety

Welcome to the Food Safety discussion board. Please use this area to raise questions and share your knowledge and best practice guidance on all matters relating to Food and Food Safety.

Discuss

Why not Sign up today or and get into a discussion by posting a comment!

Consumer Retail Package
From: DRestauri@Catelli.com
11:18PM 12 December 2018
Just looking for thoughts on whether the following would be considered a primary packaging material or not.  The retail selling unit includes, two plastic tubs which is holding your product, both tubs contain a piece of lidding film then a lid onto of the lidding film, a sleeve wrapped around both tubs then a plastic strip of banding wrap to hold the two tubs together, would you classify the plastic banding wrap a primary packaging material or no? Your thoughts are much appreciated. Thank you.
From: danny.martin@turners-distribution.com
1:29PM 13 December 2018
Hi,
Personally no i wouldn't. To me the plastic banding is secondary packaging as it does not come directly into contact with product. 
From: DRestauri@Catelli.com
5:08PM 13 December 2018
Thanks for responding, I feel the same. A colleague of mine had been told during an Issue 7 to 8 conversion training session that primary packaging is extended to any part of the packaging that goes home to the Consumer but honestly, that leaves that wide open especially when your purchasing from a place like Costco. I'm interested to hear more feedback from others as well. :)
From: csmith@lerouxgroup.co.za
2:20PM 18 December 2018
Hi Kate. Did BRC gave you the confirmation. During training the primary packaging was the material touch the product was the primary. Su if packed in bulk or 18kh cartons all the material is primary and if the byuer is repacking into a punnet or bag that will also be primary. When a a tracebillity is done the product must be traced to batch nr. 
From: katecummings@eurilait.co.uk
1:15PM 18 December 2018
Hi


I have been informed that everything the consumer takes home is now considered primary packaging.

2.10.1 CCP online and offline measurement
From: cafeoutspan
6:12AM 26 November 2018
Does anyone know the difference between online and offline measurement CCP mentioned in clause 2.10.1? 
From: DRestauri@Catelli.com
12:47AM 28 November 2018
From industry experience, my input on this would be any online measurements would be related to checks being conducted in real time where critical factors are measured during the process(example: internal temperature checks) whereas offline measurements would be any sampling you may conduct after the fact/after the product is package(example:  pH measurements, micro/pathogen testing). In our Establishment we were informed that our finished product program shall also be dictated within our Form 10. Even though it's not part of the monitoring but it is a verification system you have in place.
I hope this helps. :)
From: cafeoutspan
6:49AM 15 December 2018
Thanks for your feedback
Section 9- Traded Goods
From: ainhoa@belazu.com
11:18AM 4 December 2018
I am  being told by my certification body that this section is voluntary and needs to be requested or the auditor won't audit it. that doesn't make any sense to me, if BRC now was 9 sections, and we handle traded goods, surely this is a section we must comply with and therefore will be included in the scope of the audit. Any thoughts?
From: chatluong01@minhha.com.vn
6:17AM 5 December 2018
When the factory sells food products within the scope of the certification assessment, food product is stored in the factory premises but not produced, processed or packed at the factory. This product can be incorporated into the assessment scope by using section 9 (Traded Goods)
From: Jakkrit Vipatikom
3:08AM 5 December 2018
It is still a voluntary additional module and a site may choose to include it in the audit scope. However, it is worth noting that where a site handles traded products but elects to omit this activity from the scope of the audit, this is recorded as an exclusion from scope on the audit report and certificate.
From: DRestauri@Catelli.com
1:25AM 5 December 2018
From what I understood during the auditor conversion course at SAI Global, if you are handling traded goods, you will definitely be audited against it.  It's definitely not an option. 
From: Josie Foster
5:01PM 6 December 2018

This is incorrect. the training material clearly states that section 9; Traded Goods is optional, however if it is relevant on a site, but isn't audited, it becomes and exclusion from scope.
Excluding  only Traded Goods from scope does not have an impact on the use of the BRC GS logo. Please check your slide on day 2, page 8 in your auditor conversion notes.
From: csmith@lerouxgroup.co.za
11:57AM 4 December 2018
As I understand during issue 8 training there must be a document to confirm that you are not high risk. The reason is to show a company went through the clauses
Product Safety Culture Module
From: nicktregear
10:21AM 8 October 2018
Hello
In the interpretation guidelines , in section 1.1.2 it states that the Product Safety Culture Excellence elected module is available to view on BRC Participate. I have looked but I cannot find this. I can buy this in the bookshop, but really just want to assess the contents at present to see if we want to have the additional audit. Will it be added to BRC Participate in the near future?
Thanks

From: Jakkrit Vipatikom
3:15AM 5 December 2018

Auditors are not expected to be auditing “food safety culture” of the site which is to a large extent
subjective, but the evidence of compliance to requirements of the clause
From: John Figgins
3:58PM 31 October 2018
The Culture Excellence Module is currently being updated and the new version will launch shortly.


Please note that clause 1.1.2 of Issue 8 of the Food Standard does not require you to have the module but to have and implement a culture plan.
From: wendy.tillman@giesengroup.co.nz
12:04AM 3 December 2018
Hi, Is the Culture Excellence Module available yet? Thanks!
From: AryztaMalmo2018
1:19PM 14 November 2018
Where do I find the tool/checklist for Food safety culture assessment? questionnarie with 43 points.
From: chatluong01@minhha.com.vn
1:39AM 23 October 2018
Please search and download file F804a: Issue 8 Auditor Checklist and Site Self-Assessment Tool in BRC Participate. I think it is necessary for you.
Input/Thoughts on 3.5.1.2 - Supplier Audit Certifications
From: DRestauri@Catelli.com
1:09AM 28 November 2018
I’m looking for input/thoughts on clause 3.5.1.2. If during
the initial supplier approval process a Supplier has provided you with their
audit certificate which is applicable to the BRC standard or certified to a
GFSI benchmark standard, would it be acceptable during the 1 year renewal of
that Supplier to verify that they have completed their yearly re-certificate
audit via the applicable GFSI scheme online directory or is it mandatory that
you must receive the physical copy of the certificate from the Supplier? Would
Auditors accept the information taken from the Directory or no?
From: chatluong01@minhha.com.vn
3:10AM 1 December 2018

I think it is good when you received from supplier. That is responsibility of supplier. Because any supplier need to show prestige and high quality. And Certification paper is one of some thing their must have.
You can print the certification paper and show when auditor request.
From: ramandeep@naturalbakery.ca
2:30PM 28 November 2018
Hello, From the interpretation guide, it seems that you can accept the certificate from supplier. I have always requested these copies via email and then confirmed their validity on BRC directory. We never had an issue with this.Hope this helps!
From: DRestauri@Catelli.com
11:49PM 28 November 2018
Thank you. That's the process I currently follow but I was wondering if during the renewal phase when your asking the Supplier for their re-certification certificate when it expires, I was wondering if it would be acceptable to just look up their site code on the directory since you have it already and see that they have completed their re-certification or do I need to physically ask them each year for the PDF of their certificate(that's also what I'm doing right now). I understand during the intial approval process when the Supplier/ingredient is new to your facility that you need to get a copy of that certificate but I'm wondering afterwards.
From: ramandeep@naturalbakery.ca
8:49PM 29 November 2018
Hello,
I have a spreadsheet where I am tracking the sites for their audit certificate expiry so either they send me the copy after their re-certification or I request it. In any case, I like to get confirmation from them via email that they were audited and what was their score and again verification of certificate is always a step after that. Please let me know if it clarify the situation for you.

From: DRestauri@Catelli.com
7:25PM 29 November 2018
Thanks Iain. That's also the process I'm following and I understand that requirement. I don't think I'm being clear on my ask or just not being understood I'll just continue following my current process.
From: Iain Wright
7:15PM 29 November 2018
BRC is encouraging use of the directory to confirm that certificates are genuine.  There is a strong suggestion that failure to check the validity of the certificate by using the directory would be viewed as a non conformance. 
The indicator to this is use of the word valid.

>a valid certification to the applicable BRC Global Standard or GFSI-benchmarked standard. The guidance for issue 8 states  "The site must confirm the validity of the certification" and the only way to do this is to use the directory. 
With the new directory (soon?),  there may be opportunities to get status reports on all your BRC certified suppliers .
Primary Packaging
From: charles.bruce@leclercfoods.com
7:10PM 30 October 2018
What is considered primary packaging?  When reviewing the definition online and in the guide there are differences.  I would like to know if Primary Packaging is the packaging that comes in contact with the food?  Or is it the packaging that is the retail unit which would include the retail box?  

thanks 


BRC section starts at 3.5.1.1
From: Iain Wright
7:30PM 29 November 2018
The place we were directed to check was the Glossary.

"The packaging that constitutes the unit of sale to the consumer or customer (e.g. bole, closure
and label of a retail pack or a raw material bulk container)."
So you are correct in saying it's the retail unit- makes a difference!
From: DRestauri@Catelli.com
1:21AM 12 November 2018
I give my thoughts since you haven't had any feedback, primary packaging is considered the retail selling unit. If your placing the retail selling unit inside another corrugated box, that box is not considered primary package. Just be careful because I've been getting challenged alot on the outside of a retail selling unit as well because you need to take into consideration that a Consumer is handling that unit then potentially coming into contact with the product inside that unit so have controls in place for the handling of that retail selling unit after it's been sealed. I hope this helps.
From: charles.bruce@leclercfoods.com
7:10PM 19 November 2018
thanks Donna for your input it is appreciated. 
BRC Directory
From: rachelw@cooperfarms.com
6:17PM 27 November 2018
I am trying to navigate the BRC Directory. Where would I go to access other BRC audits and certifications?
From: DRestauri@Catelli.com
12:20AM 28 November 2018
I usually type in BRC directory in the search engine and it gives me access.   https://brcdirectory.co.uk/
Hope this helps. :)


Envirolmental monitoring
From: nusr_wt@yahoo.com
3:09AM 17 November 2018
Is 4.11.8 applicable for low risk product, dried food ? If yes, how much is enough in comparing to RTE product ? Thank you.
From: sjunaidy@rbi.com
6:01PM 21 November 2018
Yes, Frequency and type of pathogens test depends on risk assessments.
From: nusr_wt@yahoo.com
7:07AM 22 November 2018
Thank you, did you mean 4 zones of risk ?
4.14.2 Pest Management Risk assessment
From: sitskerg@embassyingredients.com
2:14PM 7 November 2018
Does anyone have sample of documented risk assessment? 
From: DRestauri@Catelli.com
2:13AM 20 November 2018
I also have the same place as Paula mentioned but as part of my assessment  and as mentioned in  4.11.4 I do complete trending analysis. My Pest contractor I use gives me access to their monitoring site which generates trends per pest activity monitored and year over year it shows if you need to put other actions in place pending the findings but definitely, if you are using an external contractor for pest control, they should be providing you with this risk assessment on a yearly basis.
From: paula.beaulieu@mccain.ca
12:57PM 19 November 2018
Your pest control supplier should complete this for you annually.
We have a contracted pest control company and they must do a risk assessment annually to make sure we have the most traps and are not vulnerable to other pests.
Clause 4.4.3 Drainage
From: prichard
5:01PM 21 September 2018

The clause states:  Drainage where provided shall be sited, designed and maintained to minimize risk of product contamination and not compromise product safety.  Machinery and piping shall be arranged so that wherever feasible, process waste water goes directly to drain.  Where significant amounts of water are used, or direct piping to drain is not feasible, floors shall have adequate falls to cope with the flow of any water or effluent towards suitable drainage.


Does anybody know what an appropriate drain and trench construction would be for a lobster processing plant?  Are there certain materials that should NOT be used?  What would be the best construction to go with for a new construction?
From: DRestauri@Catelli.com
1:18AM 16 November 2018
The interpretation guide will provide clear details if you haven't already referenced this.  For floor drains, especially if your undergoing new construction, make sure your floors are sloped  downwards towards the drains.  For equipment draining, it becomes a challenge at times but PVC piping does the trick but again, you need to make sure it's directed to a drain. You have to be careful when you have drain hoses which are directing your refrigeration units, from experience I've seen plastic hoses being used for these which are directed into drains.  For the construction material, you can reference this link which will provide you with information on how you can demonstrate or even what you should consider to justify that the materials being used for constructions are safe for use in food manufacturing. http://www.inspection.gc.ca/food/safe-food-production-systems/technical-references/guidance/eng/1412187967735/1412187968391;


From: chatluong01@minhha.com.vn
4:01AM 22 September 2018
I do not see BRC standard shows about there certain materials that should not be used, so you should contact with construction specialist or BRC audit company to have advise. 
I think if it is make safety, it is good idea. You can use the materials you use like you use for your house.
Tongue studs
From: Liverpool1
2:15PM 24 September 2018
Issue 8 - jewellery (7.2.1) - no longer states the tongue as an example of an exposed part of the body (whereas it was in issue 7) - does this mean tongue studs are now permitted?
From: chatluong01@minhha.com.vn
1:58PM 5 October 2018
Yes, i think it is mean tongue studs are now permitted.
From: Matteo Sorrentino
5:26AM 31 October 2018
Luckily! I have always wondered why to forbid the tongue studs and not dental prostheses (dentures), considering that eating on the production lines is forbidden
From: Matteo Sorrentino
5:24AM 31 October 2018

Luckily! I have always wondered why to forbid the tongue studs and not dental prostheses (dentures), considering that eating on the production lines is forbidden :o)

From: Matteo Sorrentino
5:22AM 31 October 2018
Luckily! I have always wondered why to forbid the tongue studs and not dental prostheses (dentures), considering that eating on the production lines is forbidden
From: calidad@llusar.com
3:35PM 1 October 2018
I think that the tongue isn't a exposed part
From: maria.martis@flamingo.net
12:27PM 15 November 2018
Not exposed but with experience they have detached and fallen into open product. Do not take the risk.
Internal audits
From: rocio.garcialatorre@pepsico.com
12:05PM 22 October 2018
Hello! 
Is there any modification of the point 3.4.1. of BRC  v7 in which says that the internal audits must be done at least quarterly??  The point says exactly the following:There shall be a scheduled programme of internal audits throughout the year with a scope which covers the implementation of the HACCP programme, prerequisite programmes and procedures implemented to achieve this Standard. The scope and frequency of the audits shall be established in relation to the risks  associated with the activity and previous audit performance; all activities shall be covered at least  annually. Thanks for your comments. 
From: chatluong01@minhha.com.vn
1:09AM 23 October 2018
I do not think it is must be done at least quarterly. You need to internal audit at least 4 times/ year (4 times, not meaning 4 days). And you can think is at least quarterly is meaning 4 times/ year. You can take internal audit more than 4 time if necessary. In my company, we have taken internal audit 5 times/ year. It is depended on result of the last internal audit and all the point basic, you must be take at least 2 times/ year.
From: DRestauri@Catelli.com
1:02AM 12 November 2018
I just completed the Auditor Conversion course and the way it was explained is that you shall complete the internal audit throughout the year, at least at 4 different times within the year. Example: Section 1 & 2 completed in 1st quarter, Section 3 & 4 completed in 2nd quarter etc, they were finding that alot of Companies were completing the entire internal audit at one time within the year which doesn't give a realistic representation of the effectiveness of your Food Safety Programs. You also have continue to performing your internal audit as per your frequency dictated in your risk assessment. I hope this helps.
3.6.3 Formally Agreed Specification
From: Narongchai Yookittichai
12:55AM 20 September 2018
Issue 7: The company shall seek formal agreement of specifications with relevant parties.

Issue 8: Where the company is manufacturing customer branded products, it shall seek formal agreement of the finished product specifications.

Comment: Slight amendment to clarify that formal agreement should be between the site and the brand owner of the product

Does it mean, from now on, it is no need to seek the formally agreement for raw material specifications?

From: chatluong01@minhha.com.vn
1:29AM 20 September 2018

I do not think so, because if the company shall seek formal agreement of specifications with relevant parties, it is right benefit for your company. And it is prevent fraudulent, fake risk.

From: Jakkrit Vipatikom
5:56PM 22 September 2018
There are only requirement for formal agreement with the
suppliers of services in clause 3.5.3.2 and 9.2.2 Specification under
Requirement for Trade Goods, not suppliers of raw materials or primary
packaging.  


 


Even BRC Food issue 7, there was no requirement for formal
agreement of specification for "" raw material suppliers"".
Requirement has been mis-interpreted by many parties for a long time as this
clause is under statement of intention of “Specifications”


 


Raw materials and packaging were emphasized in clause 3.6.1,
while finished product specification mentioned in only clause 3.6.2.


 


Relevant parties in clause 3.6.3 mean the site and the brand
owner of the product.       You may find
interpretation guideline of BRC GSFS issue 7,  page 42 or BRC GSFS issue 8, page 63 in same
clause regarding formal agreement of specifications  : " Customer-branded, finished product
specifications must be formally agreed with the customer and must, wherever
possible, be signed by both parties. However, where the customer’s signature or
approval is not formally available, proof that specifications have been issued
(such as an email request for formal acknowledgement or specifications on
customer IT specification systems) is required. In this situation the site must
be able to demonstrate it is following a formal process agreed with the
customer.  "


 


.......... I think that is sound reasonable for BRC to
adjust such phrase of requirement slightly for preventing mis-interpretation
this clause as their intention.   


 


Clause 3.6.4 cover clause 3.6.2 and 3.6.3, not 3.6.1. 


 


Clause 3.6.4 is also
reflected in clause 2.14.1, which explains how the HACCP or food safety plan needs
to be reviewed whenever raw materials change.
From: Narongchai Yookittichai
1:45PM 23 September 2018
Great, that is the correct interpretation for 3.6.3 and do hope all auditors read this.
3.5.4.2 - Management of outsourced processing
From: Narongchai Yookittichai
12:39PM 2 September 2018

Refer to Clause 3.5.4.2 applied for outsourced processor.

The approval and monitoring procedure shall be based on risk and include either one or a combination of: 


• a valid certification to the applicable BRC Global Standard or GFSI-benchmarked standard. The scope of the certification shall include the raw materials purchased.

Why the new wording of "the scope of certification shall include the raw material purchased" is added? Is it error added (copied from 3.5.1.2) or intended to enforce the outsourced processor to use the BRC certified raw materials?



From: chatluong01@minhha.com.vn
1:02AM 19 September 2018

The company shall ensure that subcontractors are approved and monitored by successful completion of either:
• certification to the applicable BRC Global Standard for Food Safety or other GFSI-recognised scheme
• a documented site audit with a scope to include product safety, traceability, HACCP review and good manufacturing practices by an experienced and demonstrably competent product safety auditor.
From: John Figgins
2:51PM 10 September 2018
The scope of certification must include the products, processes and/or activities completed by the outsourced company. 
From: John Figgins
2:08PM 10 September 2018
The scope of certification must include the products, processes and/or activities completed by the outsourced company. 
From: JavedFood
10:04PM 3 September 2018

Hi. Yes, I also read this and thought that this was a cut and paste error. I have highlighted this clause  and will ask the Trainer and participants in my forthcoming Issue 7 to 8 conversion for Trainers course.
If it isn't an error than maybe it should read?
"A valid certification to the applicable BRC Global Standards or GFSI- benchmarked Standard.The scope of the certification shall include the product(s) and processes that the site requires and or are certified against".
Senior management review
From: Melissa Álvarez
5:18AM 1 September 2018
A seasonal produce site wants to certify BRC Food, it is needed to have annual senior management review prior its certification?  Thanks!
From: fmogrovejo@bilbosa.com
10:38PM 3 September 2018
Yes, the site should have at least one annual senior management review. Remember clause 1.1 is fundamental and mandatory of compliance. 
Employee Break Rooms
From: prichard
2:13PM 17 August 2018
Can anyone confirm the requirements for break rooms.  I have been to several shellfish processing plants and have been told that there needs to be two separate break rooms and employee entrances to the production plant (one break room for low risk areas and one for high risk areas employees).  I have gone through both Issue 7 and Issue 8 of the standard and do not see the requirement anywhere.
From: John Figgins
11:40AM 28 August 2018
Issue 8 clause 8.4.1 highlights that there should be specifically designated changing facilities for high risk and high care staff, These should be separate to the facilities for low risk staff. The facilities should be located at the entrance to the relevant areas. Therefore, there will be different entrances to the production area.
Protective clothing worn in high risk and high care areas must not be worn in other areas of the factory (details also in clause 8.4.1) and must therefore be removed on exiting the area.
There is no requirement in the Standard for separate break rooms. Practical consideration may also need to be given to toilet facilities as these are often located adjacent to changing rooms (although the Standard doesn't actually prescribe separate toilet facilities). 
BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8 GUIDELINE FOR CATEGORY 5 FRESH PRODUCE
From: COTHN5310
9:20AM 20 August 2018
It was published the guidelines to implement BRC issue 8 in fresh produce, but as the cost of 60 pounds. This publication will be available soon for free download in BRC participate library?
Thanks. 
From: John Figgins
3:57PM 20 August 2018
Yes definitely.
It is quicker for us to attach a new document to the BRC Bookshop as its simply a matter of adding a new pdf. One of the advantages of BRC Participate is that the clauses are mapped ie it is possible to see the clauses of the Standard and the relevant guidelines for the specific clause all in one place. However, this means that it will probably be a couple of weeks, whilst this mapping is completed and the document is then available on BRC Participate.
Fraud in the HACCP Requirement (2.7.1) and Product Authenticity (5.4)
From: Narongchai Yookittichai
8:38AM 4 August 2018
According to the new BRC GSFS Issue 8, 2.7.1 - Fraud shall be included in the Hazard Analysis. What is the difference between fraud in 2.7.1 and fraud in 5.4 Product Authenticity?
From: John Figgins
3:51PM 17 August 2018
The main reason for including fraud in the HACCP section (clause 2.7.1) is to remind everyone that a good HACCP will consider all product safety risks regardless of the source or origin of the risk. (A similar situation exists for malicious contamination which has been added to this cause and is also covered in section 4.2).
Whereas section 5.4 covers all forms of food fraud such as adulteration, dilution, substitution, etc. regardless of whether there is a food safety hazard or not.
Sites should consider the best way of completing these activities - it is not a requirement to complete fraud assessments twice. It is acceptable for all fraud issues to be covered in a vulnerability assessment and then the HACCP to refer to this information.


Similarly, some sites have asked whether food fraud (section 5.4) and food defence (section 4.2) can be completed as one activity or whether 2 separate plans are needed. The Standard allows either option providing that the site can demonstrate that all risks (ie all food fraud and all food defence) have been fully assessed and where necessary action taken to mitigate the identified risks. Personally, I would keep them as two separate activities, as they are both large activities, and treating them separately makes it easier to ensure everything is thoroughly covered, however, the Standard allows either approach. In either approach the auditor will be looking for evidence that all the risks have been considered and appropriate mitigation strategies introduced.
From: Matteo Sorrentino
7:08AM 5 August 2018


I believe
that the clause 5.4 is referred to a fraud analysis on raw material, like a
prerequisite, the statement of intent of clause is “… minimise the risk of
purchasing fraudulent or adulterated food raw materials…”


while in
2.7.1 must be detailed in what process step can be introduced the fraud hazard


 


I also
think that in 2.7 should serve to specify the unintentional fraud ( eg
conventional product instead Organic or POD), (because I do not think there is
anyone naive enough to show how he adulterate food), after all the HACCP manual
are inspected also by official authority, while in 5.4 detail the fraud
analysis of the raw material.



From: Jakkrit Vipatikom
3:28PM 5 August 2018
Milk and infant formula was contaminated with melamine ( Hazard )  in some country. That was some kind of impacts of this fraud. This risk could be concerned during HA in clause No 2.7.1 ,                                  In some case honey in some season of some area is high risk to be fraudulently adulterated with cheap syrups and water, Not food safety hazard, but impact to quality of your products. That s the case in clause 5.4
From: Matteo Sorrentino
7:07AM 5 August 2018


I believe
that the clause 5.4 is referred to a fraud analysis on raw material, like a
prerequisite, the statement of intent of clause is “… minimise the risk of
purchasing fraudulent or adulterated food raw materials…”


while in
2.7.1 must be detailed in what process step can be introduced the fraud hazard


 


I also
think that in 2.7 should serve to specify the unintentional fraud ( eg
conventional product instead Organic or POD), (because I do not think there is
anyone naive enough to show how he adulterate food), after all the HACCP manual
are inspected also by official authority, while in 5.4 detail the fraud
analysis of the raw material.



From: Matteo Sorrentino
7:06AM 5 August 2018


I believe
that the clause 5.4 is referred to a fraud analysis on raw material, like a
prerequisite, the statement of intent of clause is “… minimise the risk of
purchasing fraudulent or adulterated food raw materials…”


while in
2.7.1 must be detailed in what process step can be introduced the fraud hazard


 


I also
think that in 2.7 should serve to specify the unintentional fraud ( eg
conventional product instead Organic or POD), (because I do not think there is
anyone naive enough to show how he adulterate food), after all the HACCP manual
are inspected also by official authority, while in 5.4 detail the fraud
analysis of the raw material.



From: Jakkrit Vipatikom
6:31AM 5 August 2018
Statement of intent in Clause No 2 focus on only food safety as equivalent to Codex HACCP.  As Hazard defined in Glossary is agent of any type with the potential to cause "harm", so only food safety hazards  mentioned in this clause.  Fraudulent materials in clause 5.4 means fraudulent and intentional substitution , for the purpose of financial gain , by increasing apparent value of the product or reducing the cost of its production.   Authenticity of products means ensuring that all products sold or purchased are of the nature, substance and quality expected. This applies not just to product claims, but includes all products and raw materials with the assurance that they meet the specification.  
Glass Test Pieces
From: liz.orr@wgrant.com
7:01AM 30 July 2018
Does anyone know if there is somewhere that I could purchase glass test pieces? This is to test the air rinse process on a glass bottling line to validate that it can effectively remove glass contamination.
From: Matteo Sorrentino
10:07AM 1 August 2018
I suggest to use a cover glass of a microscope slide. Just take the precaution to paint it with a felt tip pen (blue)
From: liz.orr@wgrant.com
10:21AM 1 August 2018
Thank you for your response, we currently use coloured glass which is the same as is used in the process. We filter to make sure that there are no pieces smaller than 0.5mm, but have no other way to define size.
Glass Test Pieces
From: liz.orr@wgrant.com
7:00AM 30 July 2018
Does anyone know if there is somewhere that I could purchase glass test pieces? This is to test the air rinse process on a glass bottling line to validate that it can effectively remove glass contamination.