9. Inspection and testing
Managing the testing and inspection system
The testing and inspection system must be managed following the procedure, which must include a risk assessment, testing methods, corrective and preventive action, trending and review.
Introduction
The testing and inspection system provides verification for the materials and product that’s handled by the business. In this article we look at what must be covered by the procedure, the key aspects of risk assessment, how testing methods with acceptable limits must be defined and then, how the results must be recorded, trended and reviewed.
The standards
This article on the testing and inspection system is written to meet the following sections of the standards:
| BRCGS Food Safety Issue 9 | 5.6 SOI Product inspection, on-site product testing and laboratory analysis 3.5.4.6 Acceptance and test procedures 4.11.8.1, 4.11.8.3 Risk-based environmental monitoring programme and its review 4.5.1 Water supply 5.6.1, 5.6.2, Product test schedules and reviewing test results 5.6.3 Shelf-life verification |
| BRCGS Packaging Issue 6 | 7.3 SOI Product inspection and laboratory testing 4.3.2 Microbiological and chemical qualities of water, air and other gases 4.8.5 Risk-based microbiological environmental monitoring 5.6.8 Test methods 7.3.1 Product tests 7.3.5 reviewing test results |
| BRCGS Agents & Brokers Issue 3 | 4.4.1 Product assurance programmes 4.4.5 Reviewing test results |
| BRCGS Storage & Distribution Issue 4 | 14.1 Inspection 9.1.2 Microbial assessment 9.3.1X Water, steam, ice, air compressed air or other gases |
| FSSC22000 Version 6 | 2.5.6d) Allergen verification testing 2.5.7 Environmental monitoring 2.5.9a) ii Quality control – testing |
| IFS Food Version 8 | 5.6 Product testing and environmental monitoring |
| SQF Edition 9 | 2.4.4 Product sampling, inspection and analysis 2.4.8 Environmental monitoring 4.9.9 Water 11.5 Water, ice and air supply |
| FSMA Preventive controls for human food (Final 2015) | There are no specific clauses for product inspection and testing. For laboratories who provide testing; Laboratory Accreditation for Analyses of Foods (LAAF) Program & Final Rule |
| Additional standards | None covered |
The requirements
Procedure
Procedures must cover:
- A risk assessment is required to ensure that product meets the specification (quality and authenticity), conforms with legal requirements, and is safe.
- Sampling methods, including any handling requirements such as temperature.
- Testing methods.
- How reference samples are controlled.
- Disposal of samples (returned to stock, rework or segregation and disposal).
- Recoding of results.
- Corrective action and root cause.
- Reporting protocol.
Risk assessment
The scope of the risk assessment must include:
- Inputs from the material risk assessment.
- All product, including traded product.
- Facility environmental risks.
- Processes which are subcontracted or outsourced.
The risk assessment must take into account hazards such as:
- Micro.
- Chemical.
- Physical.
- Allergens.
- Quality, organoleptic.
- Authenticity, claims.
- Functional integrity
- Nutritional, shelf life.
The risk assessment must include inputs from:
- Significant risks identified through the material risk assessment.
- Customer requirements and accepted industry practices.
- Legal requirements in the country or region.
- Finished product and materials specification criteria.
- Historical data.
- Scientific information.
- The nature of products.
- The flow of products, packaging, equipment, personnel and waste.
- The provision and location of utilities, including air quality.
The output of the risk assessment is to identify and develop a programme of testing, which details:
- The testing that’s required.
- The frequency of testing.
- Sample protocol; identification of sample locations, sample size etc.
- The assessment target, e.g. pathogens, spoilage organisms, weight, colour.
- Test methods (e.g. settle plates, rapid testing and swabs).
- The acceptance limits and rejection criteria.
Water risk assessment
The risk assessment must consider water and specifically potable water.
The frequency of testing must be increased based on risk, and completed at least annually.
The risk assessment must take into account:
- Local legislation requirements.
- Historical incidents with the potability of the water.
- Previous local issues, for example if the region has high levels of nitrate.
- If the water is bore-hole.
- Any specific site concerns, such as how long the water is held in storage or the use of lead pipes.
- Where the water is treated to make it potable.
- The quantity used and therefore the scale of impact if there was an issue.
The microbiological and chemical quality of water shall be analysed to prove that it’s potable.
If mains water is used through a local provider, a chemical analysis from the water company will suffice for the chemical requirements, unless there are other risks identified in the delivery system (e.g. lead pipes). Microbiology testing results from the supplier is not sufficient on its own, as it doesn’t include the contamination risks from the sites distribution facilities.
Where boiler chemicals are used, steam from the boilers should be assessed for the risk of chemical carry over.
Where local legislation specifically allows the use of product contact non-potable water, the water must meet all legislative requirements for that process. The HACCP process must also consider the risks involved, so that the water does not present a risk to the final product.
The potable water must be tested to conform to local legislation, or in the absence of any legislation it must comply with World Health Organization (WHO) standards for drinking water.
Shelf life risk assessment
The site must have that a system of ongoing shelf life verification. The testing must based on risk and include:
- The method of testing e.g. sensory, micro testing, pH and aw.
- Sampling protocols, e.g. frequency of sampling or number from each batch.
- Justification for product selection for testing.
Testing methods
Testing methods must be validated.
Records of the results of testing shall be maintained and must include:
- Quantities of rejected product.
- Code information to enable traceability.
Where legal limits apply, these shall be understood and appropriate action taken promptly to address any exceedance of these limits.
Where applicable, the measurement uncertainty associated with laboratory test results shall be considered.
Corrective action and preventive action
A procedure for corrective and preventive action must be in place, where testing shows the results don’t meet the acceptable limits. This must include:
- Investigation to determine the cause of the failure.
- That samples can be re-tested, only to demonstrate analytical error, not to reverse a previous result.
- Suitable corrective action must be implemented in a timely manner.
- Root cause analysis and subsequent preventive action must be implemented for both significant failures and trends of minor failures.
- The significance of the results must be understood, so the appropriate action can be taken.
- Records of the review of results must be kept, which include the name of the person who carried out the review, the date and any actions.
- Actions must be in compliance with legalisation.
- Affected materials must be quarantined until the results of the investigation are available.
Where test results identify unsafe or illegal product, an incident procedure must be applied. This must include quarantine, investigation, customer notification, and the consideration of product withdrawal or recall.
Trending and review
The company shall review the inspection and testing system at least annually, and whenever there are:
- Changes to the material risk assessment.
- Changes in product, process flow or equipment.
- New developments in scientific information which will impact the risk assessment or testing methods.
- A significant failure which puts the safety or legality of the product at risk.
- External testing (such as local authority or customer) identifies an issue, which wasn’t identified by the internal system.
- An ongoing trend in acceptable results.
- Where horizon scanning identifies new risks.
Testing results must be recorded, trended, and reviewed.
BRCGS Food Safety Issue 9
Clause 5.6.1 has been expanded to state that the process for collecting samples and where necessary, sending them to a lab, must be documented with the method. Examples have been added into the interpretation, to clarify that the schedule must cover all relevant testing on site. Additional requirements have also been added to ensure that sampling procedures are sufficiently detailed.
5.6.2 On-site lab results specifically referenced to ensure that it’s understood that these are included. The measurement of uncertainty must now be understood.
The interpretation has been expanded to now include a requirement for corrective action protocols (procedures). Records must also now include the review and actions taken. When understanding results, you must also understand how the lab applies the measurement of uncertainty.
4.11.8.1 Gives clarification that the term ‘protocol’ means ‘procedure’. It also adds that a procedure is required to manage the environmental programme.
4.11.8.3 – Clarification added that only changes that affect the environmental monitoring programme would trigger a review. Further clarification added to the interpretation that doesn’t change the overall requirements of the clause.
Changes to 4.5.1 is covered in the testing methods article.
Testing and inspection edocs
Pack 9: Testing and inspection
This pack covers the requirements for BRCGS inspection, testing, environmental monitoring, lab controls and calibration of measuring equipment.
The testing and inspection system can be expensive and time consuming, so it’s important to be pragmatic and ensure that the programme really adds value. This pack guides you through the process so that you can just pick out the key attributes for your product, process and service and focus on them, so that you can get the maximum benefit from your testing budget.
Testing and inspection subject area elearning
Mini training
We two mini eLearning courses designed to teach you about understanding lab results and controlling the compliance from testing.
Our elearning is simple and straightforward to use, it includes a lesson guide and can be stopped and started when you have time available to complete it.
Find out more about our eLearning in the testing and inspection subject area
Have your say…