Environmental Monitoring – Get Ready for BRC Packaging
In this article I’m going to cover the changes which BRC have published through the new P558 Position Statement – Additional clause on microbiological environmental monitoring (clause 4.8.5).
This new clause will come into effect from 1st August 2019, which coincidentally, is when the new Issue 6 will be published.
The addition of environmental monitoring is inline with the additions to the Food Safety standard for Issue 8.
The new environmental monitoring section will apply to all production areas, so we need to understand what that means. The risk assessment applied, is what will define if monitoring for your product is required, or not.
Environmental monitoring in the food standard is split into three main parts. Now – in this position statement, BRC haven’t included all of these (which is odd) but I would imagine, when Issue 6 comes out they will be included, so let’s go through them anyway. They are:
- A risk assessment which determines the testing required
- Control limits for the results with predefined corrective actions
Let’s go through each one, to establish what needs doing. But before we do, let’s just make sure we understand what we mean by ‘environmental monitoring’.
What is Environmental monitoring?
So, the aim of this section of the standard, is to make sure that the environment (as in the area or facility) that we produce product is, fit for production and doesn’t pose a risk of contamination to the product. To make sure that the standard of the environment is right, we need to check it (monitor it) to make sure it’s OK. Typically, this would only be applicable in areas where the product is open and therefore – a risk of contamination.
In order to decide what environmental monitoring we need to do, the new clause 4.8.5 states that we need to create a risk assessment. The purpose of this risk assessment, is to work out how significant the risk identified are, so that we can use this information, to determine how often the monitoring should be done.
What should you put on your risk assessment?
Well, it all depends on what product you’re making. Think about what your product is susceptible to. Looking at your complaints is a good indicator for this. For packaging made using cardboard, mould complaints may be an issue, as card is known to carry mould spores. For food contact packaging that is used for free-from products, such as gluten free, allergens may be a risk – so this would add this to your risk assessment.
If you produce packaging in a wet environment, you will need to consider. It’s probable that the rest of the micro you may consider would be hygiene indicators, like yeast, mould or TVCs.
But just in case you need it, we’ve created you a really cool pathogen infographic sheet to help with your risk assessment.
We thought you’d like one of these to brighten up your office – it’s a great way to see boring information you can digest more easily!
If you’d like one, just complete the form below and we’ll email it to you. You will then be added to our Environmental Monitoring list so we can update you about our solutions for this area of compliance with BRC Issue 6.
For section 5.6 you also need to do a risk assessment for the product testing that you need to do, this will include risks not just from be food safety, but you need to develop a risk assessment method that includes quality and legal aspects. This means that the severity may start with upset from quality complaints, rather than harm. Once you’ve got your severity definitions sorted, you then need to assess the likelihood of these happening, to then determine the significance of the overall hazard.
Word of warning here, let’s quickly just discuss severity and likelihood, as they are often mixed up. Severity and likelihood are two very different things and should be assessed completely separately to each other. I often see risk assessments where the severity assessment has been done, taking both severity and likelihood into account.
Severity is all about what would happen to the person if they were to eat/receive this product? You do not take into consideration the likelihood of it happening at this stage. This means that the severity assessment should always be consistent when assessing the same hazard. Glass for example should always have the same result. Listeria mono contamination should always have the same result.
The likelihood score is where it should alter. The likelihood of glass contamination will differ depending on the situation you are risk assessing. Louise, one of our consultants explains it this way – which I think is really useful to keep in mind…
- The severity of being hit by a bus – is high.
- But the likelihood of being hit by a bus – is low.
You wouldn’t put the severity of being hit by a bus is low, because it’s not likely to happen. Would you?
Ok, so we’ve now got our severity definitions which should include upset for quality purposes. And we’ve assessed the risks we’ve identified for severity and then likelihood. We now need to use these severity and likelihood results to define how significant the hazard is. The more significant the hazard the more frequent the monitoring should be. It’s a good idea to define what significance would result in what frequency.
Don’t fall into the trap of doing a risk assessment, where the result doesn’t mean anything. The whole point of doing a risk assessment is to determine something, and here it should be frequency.
Control Limits & Corrective Action
Ok, so here – first thing to say is that P558 position statement doesn’t include this section, or the review section which is next. It’s worthwhile including it though, because I really do think it’ll sneak in when Issue 6 is published. We’ve included it in our pack that meets this clause, becuase it just makes sense to do so. There’s no point having a risk assessment that says you have to do checks, if you’ve got no pass or fail limits to compare them to, when you’ve actually got the results.
Right, so let’s explain this bit.
We’ve now got a risk assessment that determines how often the testing should be done. We now need to define how we’re going to do the testing and what limits (results) are acceptable and what limits are unacceptable.
For pathogenic bacteria the limits may be fairly straight forward, in the simplest form – not detected, or detected.
But for other micro-organisms such as the mould we talked about earlier, this isn’t quite so easy to define. You may need to do some work to establish what a ‘clean’ environment looks like, in order to decide what you want to achieve. This may require testing over a period of time, and comparing this to the levels of complaints you get, to work out what is ok and what’s not.
Once you’ve got this, you then need to write down your corrective action procedures. What are you going to do, when the results are out of spec? You need to think about this in advance and write it into a procedure.
The last part of the requirements is to then review the environmental monitoring programme, to make sure it’s working. The BRC have been really clever here and have been really clear about when this should happen. You need to do it annually, as a minimum, but they’ve also said you also need to do it when:
- Something in the environment in the production area changes (such as equipment, structure or layout)
- When new testing methods or test accuracy are launched
- When any product testing fails, but this isn’t reflected in the environmental monitoring results (this includes where a third party tests your product)
- If you are constantly getting ‘in specification’ results
The last two are really clever, because it really reiterates the whole purpose of why we are doing environmental monitoring in the first place. If the product isn’t right and this isn’t shown in the environmental monitoring, then that means the monitoring isn’t working.
Also, getting consistently ‘in spec’ results sounds great, but it’s not so great, if the product results are still not right. It also might mean that we’re not testing in the right places!
Need a solution?
As you would expect from us by now, using our compliance expertise at Techni-K – we’ve created a pack for you to meet these requirements – so you don’t have to spend time developing your own. We’ve also included product inspection in this pack too because this section also requires a risk assessment, so it makes sense to do them both at the same time!
Trending of the results isn’t easy, especially with micro, so we’ve provided a really simple way of doing this too. Those that have purchased the food safety version of this pack have loved it, so we think you will too.
At only £80 plus VAT, we think it’s a bit of a ‘no-brainer!’