Production Risk Zones & Segregation

Aligned with BRCGS Food Safety Issue 9 – Sections 8.1 & 8.2

High Risk • High Care • Ambient High Care

Requirement Overview

BRCGS Food Safety Issue 9 defines production risk zones based on the risk of product contamination. Facilities must identify, segregate, and manage areas designated as High Risk, High Care, and Ambient High Care to prevent cross-contamination, protect product integrity, and comply with food safety standards.

Clause 8.1.1: “The production of products in high-risk, high-care or ambient high-care areas shall be managed to prevent contamination.”

Clause 8.2.1: “Premises and process flows shall be designed, constructed, and maintained to segregate effectively manufacturing zones and minimize the risk of product contamination.”

Proper zone classification and segregation are essential for hygiene control, especially for ready-to-eat (RTE) or high-sensitivity products.

Aligned with BRCGS for Storage & Distribution Issue 4 – Clause 4.3.1 & 4.3.3

Requirement Overview

BRCGS for Storage & Distribution requires that products moved via cross-docking are traceable and controlled at all times, even when they are not held in storage for extended periods.

Clause 4.3.1: “The company shall ensure that traceability is maintained at all stages, including during cross-docking operations.”
Clause 4.3.3: “Procedures shall be in place to ensure that all products handled, including those not stored on-site, remain under control and are not subject to contamination or substitution.”

Cross-docking operations must not compromise product traceability, safety, or integrity. Even with minimal handling and temporary presence, each product must be accurately identified, documented, and protected.

Key Compliance Objectives

  • Identify and validate risk zones based on product and process risk

    Implement physical and procedural segregation measures

    Control movement of personnel, equipment, and air

    Maintain zoning maps, cleaning protocols, and verification records

Step-by-Step Compliance Implementation

1. Identify and Classify Risk Zones

  • Zone Classifications:

    • • High Risk – RTE products with high exposure risk (e.g., cooked meats)

      • High Care – RTE products requiring protection from recontamination (e.g., sandwiches)

      • Ambient High Care – Shelf-stable products requiring strict hygiene (e.g., flow-wrapped snacks)

    Evidence to Maintain:

    • Risk zone assessment documentation

      Product classification and process flow diagrams

      Justification for each area’s risk level

2. Design Effective Physical Segregation

  • Segregation Measures Include:

    • Separate rooms, walls, barriers, or airlocks

      Positive air pressure in High Risk areas

      Controlled drainage flow from clean to dirty zones

    Evidence to Maintain:

    • Facility zoning layouts with marked barriers

      Air pressure monitoring logs

      Maintenance records of doors, filters, and seals

3. Implement Procedural Segregation Controls

  • Key Controls:

    • Staff zoning with uniform color coding

      Dedicated tools, utensils, and PPE per zone

      Entry controls (e.g., handwashing, boot wash, change areas)

    Evidence to Maintain:

    • SOPs for personnel and material movement

      Zone-specific equipment logs

      Uniform and hygiene compliance checks

4. Validate and Monitor Risk Zone Effectiveness

  • Verification Methods:

    • Environmental swabbing (e.g., Listeria, pathogens)

      Internal audits and inspections

      Staff training assessments on zone protocols

    Evidence to Maintain:

    • Microbial test results by zone

      Audit checklists and CAPAs

      Training attendance and evaluations

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
Undefined or inconsistent zoning Conduct a risk assessment and create zoning maps
Cross-use of utensils or PPE across zones Implement color-coded equipment and strict segregation policies
Airflow issues in High Risk areas Install pressure controls and maintain HVAC filters
No validation of hygiene effectiveness Start routine environmental monitoring in each zone

Auditor Verification Checklist

During a BRCGS audit, expect to present:

  • Facility zoning risk assessment and classification rationale

    Segregation layout plans (physical and procedural)

    Environmental test results for High Risk/High Care areas

    Evidence of staff training and zone-specific procedures

    Internal audit results and continuous improvement logs

Implementation Roadmap

Build Your Program

  • Identify risk-based production zones

    Develop zoning diagrams and control procedures

Train and Implement

  • Train staff on zone protocols, flows, and hygiene expectations

    Enforce zoning through uniforms, access controls, and signage

Monitor and Verify

  • Perform routine environmental monitoring

    Conduct zoning audits and risk reassessments

Improve Continuously

  • Update zone controls after layout, process, or product changes

    Respond to audit findings and contamination trends proactively

Why This Matters?

  • Protects RTE and sensitive products from recontamination

    Demonstrates full control of hygiene and facility design

    Meets BRCGS zoning expectations for high-risk processing

    Enhances audit scores and regulatory trust

Support Tools Available

Food Safety Systems provides:

  • Zoning risk assessment templates

    Sample layout maps for risk segregation

    Environmental monitoring protocols

    Training guides for personnel hygiene and area control