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!

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. 
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

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: calidad@llusar.com
3:35PM 1 October 2018
I think that the tongue isn't a exposed part
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.
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: 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.
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.