Air Handling & Movement

Aligned with BRCGS Food Safety Issue 9 – Section 8: Production Risk Zones

(High Care, High Risk, and Ambient High Care Areas)

Requirement Overview

BRCGS Food Safety Issue 9 defines zoned production areas—High Risk, High Care, and Ambient High Care—as requiring controlled air movement and filtration systems to prevent cross-contamination between zones.

Clause 8.5.1: “Air handling systems shall be designed to prevent airborne contamination (e.g. filtered air, positive air pressure, airflow direction, segregation).”

Proper air control minimizes microbial and particulate transfer, maintains hygienic conditions, and ensures environmental compliance in sensitive processing areas.

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

  • Prevent airborne cross-contamination between zones

    Maintain air quality through filtration and directional airflow

    Verify air pressure differentials in High Risk and High Care areas

    Ensure alignment with risk-based environmental controls

Step-by-Step Compliance Implementation

1. Define Risk Zones and Air Control Requirements

  • Production Risk Zones:

    • • High Risk – Chilled RTE products post-cook

      • High Care – RTE products that bypass a kill step

      • Ambient High Care – RTE products stored ambient, vulnerable to cross-contamination

    Air Handling Must Include:

    • Positive air pressure (especially High Risk/High Care)

      HEPA or equivalent filtration

      Independent air handling units (AHUs) to avoid recirculated contamination

    Evidence to Maintain:

    • Site zoning map with air pressure zones

      HVAC specifications and maintenance logs

      Zoning validation or risk assessment

2. Implement Airflow Controls

  • Required Controls:

    • Airflow direction from clean to less clean areas

      Pressure differential monitoring equipment

      Automatic shut-off or alarms for airflow failure

    Evidence to Maintain:

    • Airflow validation reports

      Pressure differential logs

      Sensor calibration certificates

4. Validate Effectiveness and Prevent Failures

  • Verification Activities:

    • Visual inspections of airflow direction (e.g., smoke pens)

      Periodic microbiological air sampling (especially in High Risk areas)

      Trend analysis on air-related deviations

    Evidence to Maintain:

    • Air sampling reports

      Corrective/preventive action logs

      Validation protocols and outcomes

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
No airflow validation or direction test Conduct smoke tests or differential pressure assessments routinely
Filters not changed as scheduled Implement documented filter maintenance schedule
Shared HVAC across zones Use separate air handling for High Risk/High Care or install filters
Missing pressure monitoring records Log air pressure daily; include in internal checks

Auditor Verification Checklist

During a BRCGS audit, expect to present:

  • HVAC and airflow design diagrams

    Documented air zone pressure differentials

    Maintenance and filter change logs

    Air sampling or airflow validation reports

    Records of any air handling non-conformities and CAPAs

Implementation Roadmap

Build Your Control System

  • Identify all risk zones and assess airflow needs

    Specify and install air handling units with appropriate filters

Operate and Maintain

  • Monitor airflow direction and zone pressure daily

    Replace filters and calibrate systems regularly

Validate and Audit

  • Perform air sampling and airflow direction testing

    Review performance against zoning risk assessment

Improve Continuously

  • Update maintenance and airflow SOPs

    Record and correct deviations proactively

Why This Matters?

  • Controls airborne risks in high-sensitivity production areas

    Ensures product safety, especially for RTE products

    Builds trust during BRCGS audits and regulatory inspections

    Reduces contamination risks and potential recalls

Support Tools Available

Food Safety Systems provides:

  • Air handling SOPs and zoning maps

    Air sampling protocols and log templates

    HVAC maintenance checklists

    Risk-based zoning assessment templates