This article is written to meet the following sections of the Standards:
|BRCGS Food Safety Issue 8||SOI 4.9 Chemical and physical product contamination control|
SOI 5.3 Management of allergens
|BRCGS Packaging Issue 6||SOI 4.9 Product contamination control|
P618: Position statement for issue 6 (allergen management control)
|BRCGS Agents & Brokers Issue 3||Not applicable|
|BRCGS Storage & Distribution Issue 4||SOI 7.4 Physical and chemical product contamination risk|
7.4.2 Contamination incidents
SOI 7.7 Management of allergens
|FSSC22000 Version 5.1||ISO 22000:2018 8.2.4 h) PRP – prevention of contamination|
|IFS Food Version 7||4.12.1, 4.12.2 Foreign body controls|
|SQF Edition 9||220.127.116.11 Foreign matter contamination|
The finished consumer product must be protected from contamination, which means that all materials involved in the supply-chain for that product need to be free from contamination.
Contamination can come from the processing environment:
- The processing and storage facility (such as fabrication, pipes, walkways, platforms, ladders).
- The processing and storage environment (such as airborne contamination).
- Equipment and lubrication.
- Tools and utensils.
- Material and finished product packaging.
Although contamination has already been covered in the product safety plan, further risk assessments are still required.
The product safety plan looks at the process steps specifically. It doesn’t look at the overall environment. And it only identifies the type of control needed, it doesn’t go into the detail needed to identify the specifics of how the control must be managed (unless it’s defined as a product safety control point).
Allergen risk assessment
For example, allergens are considered in the product safety plan, but on its own – the hazard analysis doesn’t provide enough detail to be able to prevent allergen cross-contamination.
The product safety plan also doesn’t go into sufficient detail to provide a register of where such contamination risks are located. For example, it wouldn’t identify where all the knives are on site, or how often they should be checked.
So, don’t fall into the trap of thinking that having a statement like ‘contamination is considered in the product safety plan’ in your contamination control procedure – will get you through your audit.
Risk assessment methods
Before you document a risk assessment, you must decide what you’re trying to achieve and how you’re going to achieve it.
This means, you must write down your method for you risk assessment. Doing this may seem like a lot of work, but we promise you’ll find that it’s worth it. Having to write down a method, forces you to work through the detail – which means your assessment will be much more effective and consistent.
All incidents where the product has been contaminated, or is at immediate risk of contamination, must be managed as non-conforming.
The procedure for handling such incidents, must include:
- Communication channels.
- Putting affected materials on hold.
- Investigation, including finding the source of the contamination.
- Corrective action.
- Preventive action using root cause analysis.