Chemical & Physical Product Contamination Controls
Aligned with BRCGS Food Safety Issue 9 – Clause 4.9 (Site Standards)
Requirement Overview
BRCGS Clause 4.9 requires the implementation of controls to prevent contamination of food products by foreign materials, including chemical, metal, glass, hard plastic, and other physical hazards. Effective management of these risks ensures product integrity, consumer safety, and regulatory compliance.
Clause 4.9.1: “Processes shall be in place to manage the risk of chemical and physical contamination of raw materials, intermediate products, and finished products.”
Contamination controls must be tailored to the site’s operations, clearly documented, verified, and reviewed regularly.
Key Compliance Objectives
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✓ Identify potential sources of chemical and physical contamination
✓ Implement site-wide contamination prevention measures
✓ Validate and verify control effectiveness (e.g., detection, removal, segregation)
✓ Maintain detailed records for traceability and audit readiness
Step-by-Step Compliance Implementation
1.Identify Contamination Risks
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Hazards to Assess Include:
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• Cleaning chemicals, lubricants, or pest control substances
• Glass, metal, wood, and hard plastic from equipment or packaging
• Foreign materials from raw materials or poorly maintained infrastructure
Evidence to Maintain:
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• Site-specific risk assessments
• Foreign material hazard analysis within the HACCP plan
• Equipment and area inspections
- • Cleaning chemicals, lubricants, or pest control substances • Glass, metal, wood, and hard plastic from equipment or packaging • Foreign materials from raw materials or poorly maintained infrastructure
- • Site-specific risk assessments • Foreign material hazard analysis within the HACCP plan • Equipment and area inspections
2. Implement Control Measures
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Control Examples:
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• Color-coded cleaning tools and chemical storage segregation
• Preventive maintenance of equipment and utensils
• Physical barriers (e.g., light covers, mesh sieves, filters)
• Foreign body detection systems (e.g., metal detectors, X-ray, magnets)
Evidence to Maintain:
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• Cleaning and chemical usage SOPs
• Equipment maintenance logs
• CCP or PRP validation for foreign material detection systems
- • Color-coded cleaning tools and chemical storage segregation • Preventive maintenance of equipment and utensils • Physical barriers (e.g., light covers, mesh sieves, filters) • Foreign body detection systems (e.g., metal detectors, X-ray, magnets)
- • Cleaning and chemical usage SOPs • Equipment maintenance logs • CCP or PRP validation for foreign material detection systems
3. Manage Chemical Controls
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Specific Measures Include:
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• Approved chemical lists with Safety Data Sheets (SDS)
• Chemical use logs and concentration verification
• Segregated and labeled storage cabinets
• Trained personnel handling food-safe and non-food-safe chemicals
Evidence to Maintain:
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• Chemical inventory and SDS binder
• Chemical dilution verification logs
• Staff training records on safe handling procedures
- • Approved chemical lists with Safety Data Sheets (SDS) • Chemical use logs and concentration verification • Segregated and labeled storage cabinets • Trained personnel handling food-safe and non-food-safe chemicals
- • Chemical inventory and SDS binder • Chemical dilution verification logs • Staff training records on safe handling procedures
4. Monitor and Verify Control Effectiveness
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Verification Actions:
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• Regular audits of high-risk zones
• Monitoring of CCPs (e.g., metal detector test wands)
• Foreign material incident investigations
• Swab tests or product inspections where applicable
Evidence to Maintain:
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• CCP and PRP verification logs
• Non-conformance and corrective action reports
• Internal inspection reports
- • Regular audits of high-risk zones • Monitoring of CCPs (e.g., metal detector test wands) • Foreign material incident investigations • Swab tests or product inspections where applicable
- • CCP and PRP verification logs • Non-conformance and corrective action reports • Internal inspection reports
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| Unlabeled or improperly stored chemicals | Implement chemical storage control procedures and signage |
| Broken or damaged site infrastructure | Add infrastructure maintenance to site inspections |
| Missing foreign body detection checks | Document and verify CCP functionality routinely |
| No foreign material risk assessment | Integrate foreign object analysis into HACCP and site assessments |