Are you compliant with the new Environment Monitoring clause for BRC Version 8?

These requirements have been added to ensure that where sites have production areas containing open products, monitoring and controls are in place for pathogenic and spoilage bacteria that may be present.

The environmental monitoring section now requires sites to employ a risk-based environmental monitoring programme for pathogens (e.g. Listeria, Salmonella) and spoilage microorganisms (e.g. Pseudomonas, yeast, moulds) and for all areas containing open and ready to eat products. This applies to sites dealing with high risk, high care and low risk products such as fruits, nuts, herbs, bread, salads, confectionery, smoked fish and meat.

The clause requires that businesses should set out and document;

1. Sampling protocols used
2. Sampling locations – which should consider the proximity of services to the product
3. Frequency of testing
4. Micro-organisms to be tested for or the relevant indicator organisms
5. Test methods used such as ATP swabbing
6. Results, including failed tests and the corrective actions taken.

Businesses should ensure that their environmental monitoring program verifies that the control measures and site are suitable to manufacture safe food. It is essential that businesses identify any contamination hazards and routes, eliminate them where possible and risk assess them. The results of your environmental program need to be monitored and reviewed at least once a year.

For businesses looking to achieve BRC certification, they should consider the products they are dealing with and the level of risk they provide. This should guide businesses on what level of environmental monitoring they should use for their operation. Rapid response methods such as ATP swabbing can be very useful where more immediate verification is need.

So what should you do next?

As will all monitoring programs the actions taken should be proportionate and appropriate to the risks and hazards involved.

1. Assess the risks associated within your operation and determine what bacteria your products may be exposed to.
2. Asses the likely effect on product safety and quality those bacteria are likely to have on your products
3. Consider the points of your process at which products are at a higher risk of contamination i.e. open product areas, proximity to services.
4. Determine the type of testing needed to detect the identified bacteria. This could be submission of swabs to a lab or rapid response methods such as ATP or pathogen specific test that are now available. You should also consider the time it will take to get a result and any impact this could have on your production.
5. Determine the frequency of testing needed. The frequency of testing required for an area holding ready to eat product is likely to be much higher than that of a low risk product that is going on for further processing.
6. Create a sampling plan with all the testing locations and their frequencies identified to allow you to record your test results.

To find out more about Version 8 of the BRC Food Safety standard, take a look at this blog on the key changes in Version 8 from CFS compliance.