9. Inspection and testing
Laboratory controls
In this article we look at the requirements for laboratory controls and how the appropriate facilities must be provided.
Introduction to laboratory controls
When carrying out testing, the appropriate facilities must be provided. This include controls to prevent cross contamination, when performing microbial testing.
The standards
This article on laboratory controls is written to meet the following sections of the standards:
BRCGS Food Safety Issue 9 | 5.6.4 Pathogen testing facilities 5.6.5 Design of laboratory facilities 5.6.6, 9.4.4 Analyses critical to safety and legality 5.6.7 Management of tests not critical to safety or legality 9.4.2 Verification of conformity |
BRCGS Packaging Issue 6 | 5.6.7 Ensuring test result reliability 5.6.8 Test methods 5.6.10 Laboratory accreditation 7.3.2 Verification of conformity 7.3.4 Analyses critical to safety and legality |
BRCGS Agents & Brokers Issue 3 | 4.4.2 Verification of conformance 4.4.4 Status verification for claims |
BRCGS Storage & Distribution Issue 4 | 10.3.6.3 Analyses critical to safety and legality 10.3.6.4 Competency |
FSSC22000 Version 6 | 2.5.1a) Laboratories |
IFS Food Version 8 | 4.8.4 Laboratory facility 5.6.3 Food safety analysis |
SQF Edition 9 | 2.4.4.2, 2.4.4.3 Laboratories |
FSMA Preventive controls for human food (Final 2015) | Laboratory Accreditation for Analyses of Foods (LAAF) Program & Final Rule |
Additional standards | None covered |
The requirements
Procedure
Where tests are completed on site, a risk assessment must be completed to consider where the testing may pose a cross contamination risk to the product. Appropriate controls shall be documented in procedures and implemented to prevent, or reduce to acceptable levels, any risk identified.
The risk assessment must take into consideration:
- The design and operation of drainage and ventilation systems.
- Access and security of the facility.
- The movement of laboratory personnel.
- Protective clothing arrangements.
- The processes for obtaining product samples.
- Disposal of laboratory waste.
Testing must be controlled through laboratory management procedures which must:
- Include test methods based on accepted standards.
- Define the equipment that’s to be used.
- State that the equipment must be fit for purpose and appropriately calibrated.
- Set the standard for staff competency, including ring testing.
- Be verified using internal audits.
- Include customer requirements.
Laboratory test methods
The test methods used must be either:
- Following accredited methods.
- Following recognised, industry methods.
- Or be suitably validated to prove their accuracy and consistency.
Where non-accredited or recognised methods are used, justification must be in place as to why.
Tests which are carried out for product safety or legality, must be either:
- Carried out by an accredited lab.
- Carried out by a lab working to the principles of ISO17025.
Pathogen testing facilities
Pathogen testing must either be:
- Subcontracted to an external laboratory.
- Carried out in-house, in a laboratory that’s segregated product areas and following relevant controls.
Sensory testing facilities
Organoleptic assessment must be completed in a designated area, away from production.
Review
Before implementing new on-site tests, a risk assessment review must take place to ensure that the facilities, resources and competence are available.
Certification
Where testing is carried out by an external laboratory, which is critical to product safety or legality, the laboratory must have a recognised laboratory accreditation, or operate in accordance with the requirements and principles of ISO/IEC 17025.
The laboratory must be accredited for the specific tests they carry out.
Competency
Personnel carrying out testing must be suitably competent, and trained to the relevant procedures. Competency must be verified through paired testing or ring testing.
Verification of supplier results
Where testing of traded product is provided in the form of a certificates of analysis by the supplier, the information must be verified, by carrying out independent product analysis.
The frequency of this assessment must be based on risk, which considers:
- The likelihood of an error occurring.
- The potential consequences if the error occurred.
BRCGS Food Safety Issue 9
The interpretation of 5.6.4 has been expanded to reference legislation where applicable and to state that allergen labs would need similar control.
Clause 5.6.5 has been expanded to include:
- Procedures for laboratory controls.
- Lab hygiene.
- Movement of lab materials.
- Management of monitoring equipment.
- Management of satellite labs in product areas.
The interpretation has also been updated to expand the requirements and level of detail needed for compliance. At-line testing now also must be considered.
The scope of clause 5.6.6 has been expanded to include testing which is carried out for authenticity purposes. This clause also now specifies that labs must have proficiency testing in place.
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