Are You Ready for Your BRC Audit?

Review and reassessment CPs and CCPs must be done on a consistent basis by the entire HACCP team, and not just the quality team.

Internal audits and corrective and preventive actions. Audit teams should include cross functional groups and no audit team members should audit their own work. The internal audit teams must have consistent ongoing refresher training since BRC is a living, dynamic program.

All listed non-conformities should be resolved through corrective actions via root cause analysis to truly attain continuous improvement. The need to assess and correct food safety failures is critical. Remember no Band-Aids here. By documenting the non-conformities, establishing clear reasonable timescales for correction, and using root cause analysis to prevent recurrence, you can create bonafide continual improvement in your food safety program.

Besides the internal audits, documented hygiene and equipment inspections are imperative to benchmark sanitation performance via the documented sanitation standard operating procedures (SSOP).

Layout, product flow, and segregation. In most instances for new state-of-the-art facilities, proper product flow and segregation in the facility design are done well. But in many older plants, this fundamental requirement is a major concern that requires significant capital improvements and creativity to achieve proper plant design and prevent cross-contamination due to flawed product flow and poor segregation of the raw to finished side of plant operations.

Any plant manufacturing RTE or RTU products must be diligent in mapping low- and high-risk zones with high-care and high-risk areas being the critical focus. The site maps have to clearly outline doors for forklifts, pallet trucks, and people while mapping typical traffic routes as well. This includes traffic flow of finished product, in-process products, and waste products.

Be sure to properly plan the mapping before the capital expenditures and construction are undertaken to eliminate the root cause of cross-contamination due to poor layout design and segregation. Issue 7’s Appendix 2: Guideline on Defining Production Risk Zones is a “must” read and should be reviewed annually roughly six months prior to BRC certification/recertification.

Training and allergens. For the permanent employee, continual cross-training is mandatory. An employee performing a critical operation must understand the whole production process and appreciate the HACCP plan and PRPs for their current and former or future job functions. The re-training must challenge the employee and re-address in a new perspective key precepts of the plant’s operation, basics of food safety, PRPs, and cGMPs. Plant personnel must understand and be able to explain the “why” as well as the “how to.”

By having food safety cross-training, it enables the plant team member in question to be more valuable to the organization and provide the operation with a degree of flexibility. This includes the sanitation team, a key cog to the performance of a plant’s BRC Standard and HACCP program. An ideal training tool for production personnel and sanitation staff is to have a hands-on class reviewing a SSOP with either a problematic piece of equipment or environmental sanitation niche (i.e. drains).

And lastly, don’t forget that many BRC certification sites generate non-conformities due to allergen mislabeling, allergen raw material storage, and allergen changeovers on production lines. Equipment and environmental sanitation procedures must be continually reviewed to ensure safety when a production line goes from one type of allergen to another or to a non-allergen product.

Giambrone is vice president of technical services for the food safety division at Rochester Midland Corp. Reach him at [email protected].