| Guidance Note |
|
| BRC Accreditation |
|
HISTORY AND OBJECTIVES OF BRC ACCREDITATION WHO NEEDS TO BE ACCREDITED? WHAT DOES THE BRC STANDARD COVER? WHAT A COMPANY NEEDS TO DO HELP AVAILABLE TO COMPANIES SEEKING BRC ACCREDITATION HISTORY AND OBJECTIVES OF BRC ACCREDITATION The
Objective is very simple: assured
safe food …… which results in minimum incidents of food-related
complaints / incidents and minimum bad press for the food industry
as a whole. The net result benefits the way the food industry is
viewed by the public and, by generating confidence, benefits the
whole of the food industry. The
History of BRC:
Going back to the late 1980s, it was not unusual for food
manufacturers to be audited by each of their customers individually,
annually or more frequently. The net result was that production factories would
receive several audits per month and have to accommodate the nuances
and preferences of each customer. The whole exercise was very
time-consuming and expensive, both for the factory and the
customers. Some larger food manufacturers adopted the ISO9000
system for running their businesses but as this is a general Quality
Management System, not specifically addressing the special concerns
of managing ‘food safety’, it was not generally recognised by
the food trade. Eventually all the major retailers realised the there
wasn’t that much difference in the standards that they were
encouraging their suppliers to achieve, and they, together with some
major manufacturers, agreed on a common standard and accreditation
system that they would all recognise. The standard was based largely
on the ISO System but was very food-specific. It was designed to
replace the frequent audits by each retailer with one single audit
and save everyone a lot of time and expense. The common standard was known as the British Retail
Consortium ‘Technical Standard and Protocol for Companies
Supplying Retailer Branded Food Products’. During the 1990s, the food manufacturing sector in
other developed countries went through roughly the same evolution of
'food safety standards' as the The major players in the international food
manufacturing sector got together with the WHO in 2002 and the
result was the Global Food Safety Initiative. A year later and after
some negotiations between the owners of the various standards in
different countries, it was agreed that a common international food
safety standard would be launched, which would encompass all of the
best points of the various old standards. It was launched as a drive
for improved food safety on a world-wide basis under the banner of
the Global Food Safety Initiative (GFSI). The new 'BRC Global Standard - Food, issue 4',
was published in January 2005 and formally replaced the old
BRC Standard, with effect from 01/07/05. It is one od several food
safety standards all of which are party to the GFSI. WHO NEEDS TO BE BRC ACCREDITED? BRC is not mandatory: no food business has
to be accredited. BRC is basically an industry-recognised system of
best practice on how to operate a food business. It is the phrase ‘industry-recognised’ that
starts to put pressure on food businesses to become accredited. All of the major And as BRC has become increasingly recognised outside
of the retail sector, it is now common for Caterers, Wholesalers,
Food Service providers and even large Hotel chains to insist that
their suppliers are BRC Accredited. So,
the answer to ‘Who Needs To Be BRC Accredited?’ is: Most Food
Manufacturing Businesses in the WHAT DOES THE BRC STANDARD COVER? BRC is a Systematic way of Managing Food Safety. Its starts with a HACCP (Hazard Analysis and Critical
Control Point) system. The principle of HACCP is to have a sound
understanding of the operation of the food business and then look
carefully at all the things that could go wrong (a hazard) which
might adversely affect food safety. These always fall into one of
three simple categories physical,
chemical or microbiological contamination (or
problems that could lead to any one of these). In most food businesses there may be a hundred or
more ‘hazards’. Since it would obviously be impractical
to have formal systems in place to deal with all of them, there
needs to be some kind of rationalisation, to ensure focus on the
most important ones. This initial rationalisation is achieved by
applying what is know as a ‘risk assessment’. A Risk Assessment is a rational means of estimating how important potential hazards may
be. They are normally based on a simple numerical scoring system
covering three key headings: ‘likelihood’, ‘severity of effect
on food safety’ and ‘number of people affected’ (as a result
of eating contaminated food0. The scoring system might be 1=low,
2=medium, 3=high. The principle is easier to understand by taking a
couple of simple examples: Hazard: the metal handle on the cooker door may fall
into the product, becoming a physical contaminant.
Likelihood=1, Severity =1 (the door-handle is a single piece
of stainless steel, too big to be consumed),
Number of People Affected=1(if it does get through to a
finished product, it is ‘1’ item and can only affect ‘1’
pack / person). So the overall risk rating would be 1x1x1=1 Hazard: there is a glass-covered temperature gauge
directly over the mixing vessel: it could break & contaminate
food in the mixer. Likelihood=2, Severity=3 (eating glass is
normally fatal), Number of people affected=3 (if the glass breaks
& falls into the mixer, it will be broken into many small
fragments and distributed throughout the whole batch of product,
which might go into several hundred portions of food).
So the overall risk rating is 2x3x3=18. In the examples above, the ‘oven door-handle’
would not be worth pursuing in terms of HACCP, but the glass
breakage risk would certainly need to be considered! Having used the risk assessment to remove the most
trivial hazards from consideration, the next stage is to look in
more detail at the remaining (significant) hazards. For each
significant hazard, there obviously needs to be some checking to
ensure things are in order. For ‘check’, read ‘Control’: so
every point where you need to do some checking is called a Control
Point. Pre-Requisite systems: In some instances where ‘control’ is required, this will best be
dealt with by general, common sense routines, to be found in most
businesses. For example, the risk of staff contaminating food
because they haven’t washed their hands would be covered by
standard hygiene procedures and some basic staff training. Items
such as this, where robust, well-understood (& documented)
procedures are in place, can also be segregated from the HACCP,
under the heading of ‘Pre-requisite’ systems. Typically, pre-requisite systems would include items
such as cleaning procedures, pest control procedures, staff hygiene
rules, training procedures, purchasing procedures etc. Provided
these procedures are ‘working’ these items can be legitimately
removed from final consideration in the HACCP…… but, measures
such as internal auditing must be in place to verify that the
systems are routinely adhered to! Hazards that might be Critical Control Points: Having ‘filtered’ the initial long list of hazards by taking out
the insignificant ones (using risk assessment) then removing those
covered by pre-requisite systems, a food manufacturer should be left
with just a few really important control points to focus on. Where a given Control Point is the last point in the
process where you could effectively identify and deal with a fault,
it is called a Critical Control Point or CCP. By definition, there will be something to be measured
at each CCP, and the HACCP system requires that a few key points are
defined for each one:- The target value to be achieved. The tolerance either side of the target that is
acceptable / safe. ‘Who’ is responsible for monitoring the CCP and
‘what’ is that person going to do if the measurement is outside
of the tolerance (called a Corrective Action). HACCP studies are not difficult, but are
complicated and need to be written in a very precise way. The study
must be undertaken by a multidisciplinary team of people, the leader
of the team having had formal training in HACCP. The remainder of the Quality Management System is
usually split into three tiers: Policies, Procedures and Records. Policy
A statement of what you intend to do. Procedure:
How you will achieve what you have set out in your policy Record:
Something written down that shows evidence
that a
procedure has been followed. Let us take
‘Purchasing’ as a simple example: Policy:
We will only purchase from proven safe sources of supply
and we will check in-coming goods for conformance. Procedure:
We will use questionnaires and audits to assess suppliers
before buying from them and then annually to ensure
they
are operating good food safety management systems. Record:
Completed questionnaires / audits, an approved supplier
list and records of goods-in checks such as temperatures and
quality assessments. After the initial HACCP section, the remainder of the
BRC Standard is split into five sections as follows:- 2. Q. M. S.
2.1 Quality Management System 2.2 Q Policy 2.3 Q Manual 2.4 Structure and responsibilities 2.5 Management commitment 2.6 Customer focus 2.7 Management review 2.8 Resource management 2.9 Internal audit 2.10 Purchasing 2.10.1 supplier performance and approval 2.11 Documentation requirements 2.11.1 document control and archive 2.11.2 specifications 2.11.3 procedures 2.11.4 records 2.12 Corrective Action 2.13 Traceability 2.14 Crisis / Food Safety Incident Management 2.15 Complaints 3. Factory Standards 3.1 location/ perimeter and grounds 3.2 internal standards floors, walls, ceilings, windows, doors, lights,
ventilation 3.3 services 3.4 equipment 3.5 maintenance 3.6 staff facilities 3.7 contamination physical, chemical, glass 3.8 hygiene and cleaning 3.9 waste and disposal 3.10 pest control 3.11 transport 4. Product Control 4.1. New Product Development
4.1.1 Labelling 4.2 specific handling requirements (GMOs / organics etc) 4.3 metal detection (MD) 4.4 packaging 4.5 product analysis 4.6 stock rotation 4.7 product release 4.8 control of non-conforming product (NCP) 5. Process control 5.1
control of operations
5.2 quantity control & legal
weight / volume compliance 5.3
calibration of equipment 6.
Personnel
6.1training 6.2
personal hygiene 6.3
medical & health 6.4
staff clothing For each of these sections and some of the
sub-sections, there will be Policies, Procedures and Records. Over the following pages, we will look at each
section in greater detail. WHAT A COMPANY NEEDS TO DO QUALITY MANAGEMENT SYSTEM The key words here are ‘management system’. BRC
expects businesses to have a defined system for managing quality and
a Quality Policy statement, containing the commitment to ensure the
supply of safe & legally-compliant foods of appropriate quality
ie conforming to specifications agreed with customers. There must be a ‘Quality Manual’: a book,
folder or computer-based system where all the policies, procedures
and other paperwork is kept. The Quality Manual must cover all of
the six sections / clauses outlined above. The Organisational Structure of the business
must be defined and for key people their Responsibilities and
Authority with respect to assuring the production of safe and
legally-compliant foods have to be set out. The commitment of the management team to
the Quality System needs to be set out as well as their
commitment to satisfying the customers and the methods by which they
will assess customer perception of the business. Management Review: The Management team must state how they will routinely assess the
effectiveness of The Quality Management System. This is normally
done by considering two questions: 1) Is the overall design of the
system a firm foundation for ensuring food safety ie is it
‘valid’ and 2) is the system being implemented / followed on the
factory floor ie is implementation ‘verified’. These questions
are usually considered at scheduled ‘Management Reviews’ which
will consider the findings of ‘internal audits’, ‘customer
complaints & feed-back’, ‘product conformance to
specification’, ‘the status of preventive & corrective
actions’, ‘changes
in legislation or relevant codes of practice for the industry
sector’ and any other recommendations for the improvement of the
QMS. Management Reviews are also normally used as an
opportunity to consider the provision of resources needed for the
Quality Management System to function. The Purchasing & Supplier Management
section requires the business to outline what systems it has in
place to ensure that it is buying safe raw materials from companies
who themselves have appropriate food safety management systems in
place. Businesses frequently achieve this by the use of
questionnaires sent to suppliers, who return them with copies of
their specifications for the items purchased. For certain suppliers
/ raw materials, it may be considered appropriate that the
purchasing company should physically audit the supplier from time to
time. The control of documents is covered in some
detail, primarily to ensure that the business manages the issuing of
new versions of important documents and the withdrawal of old
versions …. particularly important in the context of product
specifications and recipes etc. Non-Conformances, Complaints & learning from
mistakes: All businesses make
mistakes and where these affect food safety they must be
‘managed’ to ensure that they are dealt with effectively.
Procedures need to be in place to control any food safety risk posed
by sub-standard products and also to minimise the chance of the
fault recurring. This section is generally referred to as the
Non-Conformance and Corrective Action section. It is a logical
preamble to the final three parts of Management System, which deal
with Customer Complaints, Product Recall & Withdrawal and
Traceability Systems……. A system to monitor customer feedback &
complaints is required. Analysis for unusual levels of complaints or
‘trends’ can provide a useful indication of a fault in a process
or operating procedure, provided someone is monitoring and
categorising complaints frequently. Staff dealing with complaints need to have some
written guidance as to the type of complaint that may constitute a
major food safety incident, such as a customer reporting becoming
ill as a result of consuming the products, or finding potentially
harmful foreign bodies such as glass in the food. Just in case an ‘incident’ such as this occurs,
the company needs to have a documented plan in place to deal with
the situation. This will cover the use of the (legally required)
traceability system, to determine where the problem may have
originated and to identify other customers to whom affected stock
may have been delivered. Having completed the ‘traceability’ exercise, the
system needs to document how the company will communicate with its
customers and how it will initially ‘recall’ product and then
arrange for that product to be uplifted and safely destroyed
(withdrawal). As with all ‘crisis management systems’ it is
unwise to simply assume that they will work! For that reason, the
Standard requires provision to be made for the routine testing of
the system, with results of the tests suitably recorded. FACTORY ENVIRONMENTAL STANDARDS This section covers most of the common sense items
that we are familiar with from EHO standards and audits, together
with a few extra points, all wrapped up in a more formalised and
systematic way. The location of the premises must be considered ie
ensuring that the building is not sited too near to other activities
that might represent a particular hazard to food. Provision must
also be made regarding the management of the grounds surrounding the
business, mainly to ensure that there are no over-grown or
poorly-drained areas that would make good homes for rodents or other
disease-carrying animals. And finally, the site needs to be
reasonably secure, so as to deter entry by unauthorised people who
may inadvertently or deliberately contaminate food. In terms of the lay-out of the food-handling and
storage areas, there must be a logical product flow (minimising
crossovers that can lead to contamination) and the creation of high
and low risk areas where appropriate. To minimise potential
contamination risks, systems defining how people and food
ingredients move around the premises, and in particular between
‘standard care’ and ‘high care’ areas, need to be put in
place. The fabric and repair of the building and equipment is covered in some detail to ensure that floors, walls, ceilings, windows ventilation systems and the handling of chemicals etc do not themselves pose any risk of food contamination from poor design or poor maintenance. Aspects to be considered under this section are: 1)
Layout
of drainage (from
high risk areas to low
risk areas, to minimise contamination risk), with no discharges over
floors. 2)
Floors
& walls that are resistant to
the process, traffic, cleaning chemicals, and are maintained in good
condition……. floors laid to falls (sloped) where appropriate.
Wall-floor junctions to be ‘coved’ (curved) for ease of
cleaning. 3)
Ceilings and high structures to be designed for ease of
cleaning. 4)
Windows
to be non-opening and with glass protected from
breakage (usually achieved by covering them with plastic film).
Opening windows to be fitted with fly-screens. Internal windows will
ideally be made of unbreakable plastic. 5)
Doors to be close-fitting to minimise the chance of pests
getting in. 6)
Lighting: to be enclosed or protected (plastic sheathed
tubes) so that contamination is minimised in the event of breakage.
And light levels to be sufficient for staff to see what they are
doing (normally 600 Lux for food preparation areas). 7)
Air
Conditioning / Ventilation:
primarily to ensure a safe supply of clean air to working areas and
to ensure no dampness exists which would encourage mould growth. (If
‘extraction’ is installed, give some thought to where the fresh
air will come from: provide pumped incoming air via a suitable
filter, to avoid dusty / insect-laden air from outside being drawn
into the factory). 8)
Services: provision of potable water and clean compressed
air or other gasses (if they come into contact with product or
packaging): planned microbiological testing to verify
microbiological standard of water / gasses. 9)
Equipment: designed & tested to make sure it is suitable
for the process. Documented, planned cleaning & maintenance
programmes in place. 10)
Staff
Facilities: Provision of
appropriate changing areas: separate storage of ‘personal’ &
‘factory clothing’, lockers on legs and with sloped tops for
ease of cleaning. Depending on whether the factory is ‘high
risk’ or ‘standard care’, design & provision of hand
washing facilities within changing rooms and at the entrance to the
production / storage areas.
Staff toilets. Staff canteen & somewhere suitable
(normally refrigerated) where staff can keep food brought in from
home. And
published rules for ‘changing’ and the use of canteen &
toilet facilities with regard to the wearing of factory clothing. 11)
Control
of Physical & Chemical Contamination risks: Locked chemical store and rules to ensure chemicals are not used
during production in a manner where they may contaminate product.
Documented audits of building fabric to ensure that any hazards /
damage / deterioration is dealt with before it can contaminate
products. Glass control procedures: glass & breakables lists and
scheduled audits. Documented procedures to be followed in the event
of glass breakage, to ensure no potentially contaminated product is
supplied to customers. Other documented procedures may be required
for the control of wood and cardboard, depending on the nature of
the product & work-area. 12)
Cleaning: documented schedules are required for the cleaning
of the building fabric, food all equipment and ancillary areas,
services (water storage tanks, air and water filtration systems,
etc). These schedules need to clearly define ‘who’ is
responsible for cleaning, at what ‘frequency’, using what
‘equipment’ and ‘chemicals’ (including dilution / strength
& temperature where appropriate). Verifiable proof that cleaning
chemicals are suitable for food contact application should be kept
on site, together with safety data sheets. Records to show that
cleaning has been carried out in accordance with the schedules and
independent verification that it has been satisfactorily completed.
Microbiological verification of the effectiveness of cleaning
processes will need to be included for high risk areas and may be
required for standard care facilities. 13)
14)
Transport: transportation must be suitable to protect the
product from contamination and the risk of decay. To achieve this,
documented systems must be in place (procedures & records)
covering cleaning, breakdown, maintenance, temperature control &
°C
data monitoring (where appropriate). PRODUCT CONTROL The Product Control section deals with all aspects of
designing and making a safe product. New Product Development: Starts with the
design process, looks at whether appropriate factory trials have
been undertaken to ensure that equipment is capable of producing a
safe product. Analysis of samples must be undertaken in accordance
with documented protocols as a basis for determining product
durability. A HACCP study will need to be undertaken for each new
product or process, or a documented assessment confirming that any
new hazards associated with the new product or process are fully
covered by an existing ‘generic’ HACCP. Labelling must, as a minimum, clearly state what the
product is, an ingredient declaration, required storage conditions,
shelf life declaration and traceability information. In addition to these fundamentals, labelling must
comply with legislation in the country where the product is to be
sold. In Specific Handling Requirements: This section applies where product, ingredients or
packaging could ‘contaminate’ or ‘be at risk of
contamination’ of a nature that would detract from a specific
product attribute. An example of this would be where a factory is
producing a standard product and an ‘organic’ product: organic
ingredients and finished products would need to be handled in
accordance with documented procedures to protect them from
contamination by non-organic items.
Similarly, products which are free of peanuts (a common
allergen) would need to be protected from contamination with peanuts
if these are used as a constituent in another product manufactured
on site. Metal Detection: Metal is one of the most common contaminants of food and can cause
severe injury if consumed. For this reason, all food safety
Standards have quite detailed requirements on what needs to be done
to minimise the risk of metal contaminating finished products. It is worth spending a bit more time discussing this
section as food manufacturers often choose inappropriate
machinery….. a costly mistake! Why should we ‘metal detect’? Food factories are
full of metallic machinery: over time, machinery wears and breaks,
posing the possibility of metallic contaminants in foods. Each
factory must assess whether it needs to use metal detectors, as part
of its HACCP process. Most food production facilities need them, but
they are not mandatory. However, if a site decides that it does not
need to metal detect, it must document its reasons for taking this
decision and be able to show what alternative safeguards are in
place and how those provide adequate
protection from metallic contamination. If metal detectors are to be used, they must fulfil
two basic criteria: 1) to ‘detect’ small pieces of metal and 2)
to ensure that any product contaminated with metal is appropriately
identified (and normally ‘segregated’) to prevent it being
packed. To achieve these twin objectives, metal detectors
have two distinct parts: a detection ‘head’ and a mechanism that
allows contaminated product to be clearly identified and segregated.
Lets consider the ‘detection’ part first of all.
The metal detector must be able to detect all of the
different types of metal that might reasonably be expected to
contaminate the product. For most factories, these will be
‘ferrous’, ‘non-ferrous’ and ‘stainless steel’ (those
being the types of metal used to construct most food machinery). The limit of detection (smallest piece of metal that
the detector can identify) is governed
by, and directly proportional to the metal detector aperture size.
The bigger the aperture, the bigger the ‘smallest’ piece of
metal that the machine can identify. To ensure that optimum detection (smallest metal
piece size) is achieved, it is important that the metal detector
aperture is correctly specified to the product size (normally
product size not more than 10 to 12 centimetres of clearance). If a
small pack is passed through a large-aperture metal detector, the
limit of detection will be inappropriate and the food factory would
be at fault for not correctly specifying the equipment and failing
to adopt ‘industry best practice’.
As a very general guide, the limits of detection for most
retail packs (up to 1kg maximum weight) are normally in the range:
2.0-2.5mm Fe, 2.5-3.0mm Non-Fe and 2.5-4.0mm SS….or better. Having dealt with the ‘limit of detection /
aperture size’ food manufacturers must then decide what
identification / segregation mechanism is to be used. There are two main options available: The first (and
most common) is used for the majority of ‘retail’ / small packs
of foods.. It is a ‘reject mechanism’ ie a mechanical device
within the metal detector which physically removes contaminated
packs from the main stream of ‘good’ product. ‘Reject’
mechanisms are the safest form of ‘identification / segregation’
because they allow the product to be automatically dropped or pushed
into a locked ‘reject bin’. Provided the keys for this bin are
restricted to a Supervisor or other appropriate person, this should
ensure that contaminated product cannot inadvertently be packed. The second type of identification / segregation
mechanism should only be used on packs that are too big or too
delicate to be ‘pushed’ off the line by a reject mechanism eg
5kg packs of flour or delicate, decorated cakes. For packs such as
these, a ‘line stop + alarm’ mechanism is most appropriate. As
you might expect, it does exactly what it says: when a contaminated
pack is identified, the line is automatically stopped and alarms are
activated. The disadvantage of this system is that the product is
not automatically removed from the line to a container where staff
cannot access it. For that reason, clear 'alarms' must be
incorporated to ensure the Supervisor’s attention is drawn to the
incident and key-restart mechanisms are normally required to
complete the ‘safety’ loop. There is a third and final variety of metal detector
that may be used specifically for continuously extruded products,
and where use of the two previous options is not practical. They are
colloquially known as ‘throat’ detectors and similar detection
& isolation options as those cited above must be included…..
however, the mechanisms to achieve those objectives tend to be more
difficult & costly to achieve effectively! Having installed the appropriate equipment,
documented procedures covering the routine testing of metal
detectors and the actions to be taken in the event of a routine test
identifying that the machinery is not functioning (detecting)
correctly. Depending on the design of the equipment and the set-up
of ‘fail-safe’ options specified by the food manufacturer, it
may also be appropriate to include the routine testing of the
‘fail-safe’ and default settings in the documented
‘procedures’. For all of the metal detection procedures,
appropriate records will be required so that operators can record
tests completed, results, quantities of products packed and
investigation of any ‘finds’. Product Packaging: This is a small but fundamentally important section of the Standard.
The objective is simple: to ensure that packaging materials will not
themselves contaminate the food. To achieve this, it is necessary to
ensure that packaging is appropriately specified, that it complies
with legal standards required for items in contact with foods and
that this is written into the specification. If the packaging is of
a nature that it could become a contaminant of food, it should be
‘coloured’ to make it easy to distinguish from the product.
Staples and other items that could contaminate food should be
avoided. As with any other raw material, having established
specifications, appropriate goods-in checks need to be undertaken
and recorded to confirm that each consignment complies with the
specification at the point of receipt. Thereafter it must be stored
and protected to ensure it does not become contaminated. Product Analysis: Most food businesses will need to do some analysis of their raw
materials and finished products: microbiological and perhaps
chemical or nutritional. The Standard simply requires that where
analysis is critical to food
safety, legality or quality, it should be done using appropriate
procedures and facilities, and to an appropriate standard. That
sounds simple enough, but there’s a bit more to it than that. ‘Appropriate’ procedures and standards means
‘done by a lab that is ISO17025 accredited or working to those
principles’….. and in either case it is necessary to have
documentary proof of that. In reality, it is no longer cost
effective for most food manufacturers to run their own labs, so most
will need to send samples to an external lab that has the
appropriate certificates and ‘scope’ to cover the required
tests. If a non-accredited in-house lab is used, the lab
must at least undertake ring-testing, comparative measurements or
challenge-testing on a scheduled basis, to ensure its results are
reliable…. and retain copies of the reuslts of those comparative
tests. Stock Rotation: Very straightforward: ensure that an appropriate date marking or
other suitable system is in place to facilitate using products in
the correct order (normally FIFO). Product Release: Have a system in place that ensures product is only release (for sale
or internally to another production operation where appropriate) by
authorised staff. This sounds complicated but, where a basic QA
System is in place, it is usually sufficient to say that a product
is deemed to be released unless it has failed any one of the
in-house quality checks. Non-Conforming Product: Documented systems
(procedures & accompanying records) need to be established to
ensure that any non-conforming product is safely segregated in a
manner that ensures it cannot inadvertently be sold. This normally
involves having a system of Labelling (QCHold), a segregated and
designated quarantine area, records of what stock has been
quarantined, date, reason, quantity & code, what was the fault,
what has to be done with it and by whom… and by when, and finally
a sign-off to confirm what final action was taken. There are four options for dealing with sub-standard
product: rejection, acceptance by concession, re-working to correct
the fault, and down-grading for a different use (where practical).
Where non-conforming product is ‘trade-marked’, manufacturers
have a duty to ensure the reputation & interests of the
trade-mark owner are not jeopardised: appropriate systems must be in
place to ensure this is achieved. Where a non-conformance renders a
food unsafe to eat, it must be destroyed and documentary
verification of this must be retained. PROCESS CONTROL Food companies must have documentary proof to show
that any ‘processing’ that they undertake and which is
designed to ensure product safety, legality & / or quality, is
initially a) validated and b) undertaken using equipment that can
consistently achieve the desired processing. Thereafter,
an ongoing programme of validation checks should be in place. This is probably easiest to explain if we take a
cooking process as an example: the object of the cooking process may
be to reduce microbiological counts to below ‘x’ and then to
cool the product to <5°C in <90 minutes to ensure that any
surviving spores do not have time to germinate. In this case, the
initial validation would be to challenge test the process by cooking
a sample of food infected with a thermally-resistant bacteria for
the designated time, then cool it in proscribed manner. The sample
would then be sent to a lab to see if the process had reduced the
microbiological count to <’x’, and measurements taken on-site
could be used to prove that the cooling equipment was capable of
reducing its temperature from ‘cooking’ temperature to <5°C
in <90 minutes. Thereafter, routine microbiological testing and
scheduled (normally infrequent) challenge testing would be used to
ensure that this is still the case. Any ‘processing’ defined as ‘critical’
through the HACCP study need to be undertaken in accordance with
clear, documented procedures, and only by people who have been
formally trained to do so. Critical process parameters need to be automatically
recorded, on a system that incorporates an automatic alarm. The final clause in this section (which links back to
HACCP & non-conforming product requirements) requires that,
should any part of the process or equipment be changed, the
effectiveness of the whole process needs to be re-validated. And
should any part of the process not perform correctly, a system needs
to be in place to ensure that non-conforming product is not released
until it is verified as being safe. Quantity Control: The Quantity Control section deals broadly with ensuring that pack
quantities are in line with legal requirements (or specifications
agreed with customers in the case of ‘bulk-packed product). In the
Minimum contents
or
Average contents (‘e’-marked) Lets look briefly at the Average contents system
first, where pack contents is marked ‘e’ :- There
are three basic components of the law. 1)
The
manufacturer / packer must undertake statistically valid sampling of
net pack contents and keep appropriate records. 2)
The
average contents of the batch must not be below the contents
declaration on the pack. 3)
For
any given pack contents, the law dictates what ‘standard
deviation’ is acceptable and these are listed in summary below: 1
standard deviation from the average is termed the ‘Tolerable
Negative Error’ (TNE). Not more than 1 in 40 packs (2.5%) are
allowed to be below declared contents – 1xTNET.
No packs can be below declared contents –2xTNE. Any
packs where the contents are below declared contents – 2xTNE are
defined as being illegal and the manufacturer / packer is liable to
prosecution. The table below gives TNEs for various pack weights: Declared contents (gm or ml)
Tolerable negative error (TNE)
As a % of
Declared Wt
grams 5 to 50
9
------ 50 to 100 ------ 4.5 100 to 200
4.5
------ 200 to 300
------
9 300 to 500
3
------ 500 to 1000
------
15 1000 to 10000
1.5
------
10000 to 15000
------
150
above 15000
1
------ Example: From
the above table, it can be seen that the TNE is 3% of 450g
(ie = 3 /100 x 450) = 13.5g Non
standard packages are therefore those which contain less than
declared weight – 1x TNE = 450 – 13.5g = 436.5g Illegal
packs are those containing less than declared wt–2xTNE
= 450 – 27 = 423g The average weight of the packs must be at least
450g for the production run Not more than 1 in 40 (2.5%) may contain less
than 436.5g No packs may be below 423g The second option (legally) for contents declaration
is the ‘minimum weight system’, which is very simple and
applies by default to any product where the ‘e’ symbol is not used: No pack must contain less
that what is declared on the pack.
(If you need to know more about the Average Contents System, read the 'Code of practical guidance for packers & importers’ (ISBN 0-11-512922-7) available at HMSO: www.tso.co.uk/bookshop/brc
+44 (0)870 243 0129
. Calibration of Monitoring & Measuring Devices is the final part of the ‘Control of Operations’
section of BRC. It is very logical & straightforward:- If you are using equipment to monitor any parameter
that you have defined as being ‘critical’ to product safety,
legality or quality in you HACCP, you need to be sure that it is
accurate! To achieve this you will need to have in place a
procedure to ensure that the equipment is calibrated at an
appropriate frequency and stipulating what action is to be taken if
you find that the equipment is faulty. Where possible, the
calibration needs to be to a recognised national standard. And
between calibrations (normally annual) the company has a duty to
protect the equipment from damage or misuse that might have an
adverse affect on its accuracy. It is normal to have equipment such as weighing
scales and thermometers calibrated by an external organisation
annually, and to retain a certificate as proof that this has been
done. The instrument then needs to be marked with the date it was
calibrated, and the date the next calibration is due. That takes care of ‘annual calibration’…..but
the user has a duty to ensure that the equipment remains accurate in
between those annual external calibration checks too! In the case of
weighing equipment, this is normally achieved by buying some test
weights (also calibrated annually) and using these to conduct
in-house verifications of accuracy at a frequency defined in an
appropriate procedure…..and of course, supported by appropriate
records! For thermometers, ‘calibration baths’ can be purchased
(which of course also need to be calibrated and certificated
annually). These can then be used for in-house verification of
accuracy of thermometers at an appropriate frequency + records etc
etc…………..or you can save some money and use a simple written
procedure based on iced-water and boiling water…..! PERSONNEL This is the final main section of the BRC Standard
and is divided into 4 very logical sub-sections which cover the main
ways that people can adversely affect food safety & hygiene:
Training, Personal Hygiene, Medical Screening and Protective
Clothing. Training: Staff need to be appropriately trained for the job they are required
to do and need to be supervised while they are doing it (linking
back to one of the earlier sections about Company Structure and
Management Responsibilities). Procedures need to be in place for
training and ‘refreshers’ and these need to be supported by
appropriate records, normally signed by trainer & trainee.
Don’t forget that you need to be able to prove (documented) that
the trainer is qualified to give the training as well, and to assess
the effectiveness of the training given! Personal Hygiene: Most of this section is common
sense, but it does need to be documented in an appropriate procedure
and be supported by appropriate training records. In summary, it
covers: Hand cleaning (& assessing the effectiveness of
this process) Rules on smoking, eating & drinking ie not in the
work area and not wearing
factory clothing. Control of personal medicines to ensure they are not
present in working areas. Use of metal detectable plasters for small injuries (including provision to ensure they |