Design & Construction of Food Manufacturing Facilities – Latest Technical Considerations

By guest blogger Jerry Hunter (J Hunter Technical Services Ltd)

While the latest update of the British Retail Consortium’s Global Standards BRCGS doesn’t have any major changes from a construction perspective, there are a number of smaller tweaks, expansions and clarifications with an effect on the construction, equipping and maintenance of food manufacturing facilities, and some items that client and contractors will have to address that are outlined here. Full details can be found in the new BRCGS Standard issue 9 and the Interpretation document, both available from BRCGS.  Below we provide a summary of the key changes that will need to be considered.

HACCP (Hazard Analysis and Critical Control Point)

The emphasis in this section is on involving the HACCP team early on in order to raise concerns. The HACCP flow diagram for the site has to be amended and verified in the event of any changes. The validation and verification should be carried out by a “suitably qualified person”, and this will need to be evidenced for audit purposes. This forms part of a wider theme running throughout issue 9 that changes should be assessed before completion, rather than after, and that technical teams should be involved in specification processes to ensure that all equipment is fit for purpose and compliant.

Food Safety & Quality Management Systems

While there has always been a requirement to carry out internal audits against the BRC standards at least annually (depending on the risk assessment), there is an explicit requirement to conduct a fabrication audit at least on a monthly basis, there is further implication that any material changes require a new audit by the technical department.

Similarly, there has always been a requirement to have a clear approval process for suppliers, however this list has now been expanded to include categories such as product safety consultants and machinery manufacturers.

Site Standards

In line with the above, specifically for construction and fit out, the requirement has been expanded to state “contractors, visitors and drivers shall be made aware of procedures on site”, ensuring that everyone on site is aware of the food safety protocols in different areas. Principal Contractors will need to work closely with the client business in order to ensure that appropriate procedures are implemented and followed by all subcontractors and site visitors with respect to movements between low care and high care areas.

The standard has also been upgraded to clarify that any new fabrication, machinery or equipment should be purchased against a specification that gives consideration to food safety. In practice, this means that technical, engineering and procurement teams will need to work collaboratively to define specifications. The design, construction and specification should be risk-based with regard to the specific type of product that is being manufactured so that appropriate materials are used. For example, high acidity products may need to specify the grade of stainless steel to be used in machinery; or any plastics used in seals or conveyor belts should be compliant with EC1935/2004 and this must be evidenced by the supplier in a documented statement.

Commissioning

A clear, documented, risk-based commissioning procedure should be in place for the installation and setup of new equipment that clearly defines how the equipment will be tested, checked, cleaned and operationalised along with requirements for the HACCP team to test initial samples before commencing full production. This formal procedure should also include information on operator training, how the equipment will be maintained, cleaned and audited. Again, the person responsible for signing off the completion of this process should be authorised, qualified and trained to do so, and this must be evidenced during an audit.

Movement of static equipment

Any major equipment that is not in regular use, such as a line that is used for a seasonal product, should be considered as a new equipment installation when returned to operation and must have its own detailed plan for cleaning, commissioning, testing and so on as outlined above.

Equipment not in daily use

Clear procedures should be in place for disassembling, cleaning, reassembling and disinfecting any equipment that is not in daily use. If an entire production area is shut down for a few days to carry out a new installation, then a full deep cleaning and disinfection process should be carried out.

Mobile equipment used in open product areas

Items such as forklifts and pedestrian trucks are not always included in schedules for cleaning, preventive maintenance and audit, however version 9 confirms that they must be included. There is further emphasis on controls of portable equipment such as pens, phones and calculators in food control areas. The standards specify that these should be provided by the site and that contractors should be reminded not to allow anyone coming on to site to bring their own items in order to reduce any potential for foreign body incidents.

Process Controls

The wearing of jewellery by employees has always been covered by the standard, however the definition of a wristwatch has now been expanded to include similar wearable devices such as Fitbits and Garmins. This should be included in instructions for any contractors or visitors who may enter high risk high care areas.

The personal hygiene standards questionnaire has also been expanded with the self-declaration that an individual is “not the source of an infectious disease”. We presume that this is a follow on from Covid and the increased risk to product safety by having a heavy reduction in manpower.

High Risk and High Care Zones

This section refers to wall plugs in high-risk, high-care areas – sections of whitewall that can be removed to allow for installation or removal of large machinery. A clause has been added on the design of these sections specifying that they must be “tight fitting”, removing the option to mastic the seals and then strip it out as required.

A written procedure should be in place for taking out and re-installing the wall plugs including a process for cleaning, sanitising and reconditioning the area to restore it to high care status including swabbing and testing by the technical team. Once again, BRC clarifies that this must be signed off by a qualified, trained and authorised person.

Clean In Place (CIP)

CIP processes for large equipment that cannot be easily stripped down every day are clearly outlined in BRCGS, however version 9 stipulates that separate systems must be in place for high-risk, high-care areas versus low risk areas to ensure that no cross contamination can occur.

DDK’s internal and contracting teams have decades of experience in food manufacturing construction and are fully conversant with the requirements of BRCGS, so that our clients can rest assured that compliance will be maintained.