Production Risk Zones & Hygiene Controls

Aligned with BRCGS Food Safety Issue 9 – Clause 8.5: Risk Zoning

(High Care, High Risk, Ambient High Care)

Requirement Overview

BRCGS Clause 8.5 requires facilities to implement zoning controls that minimize the risk of contamination between different production areas based on the vulnerability of products and processes. These zones include High Care, High Risk, and Ambient High Care.

Clause 8.5.1: “The site shall be zoned to define areas requiring a different level of hygiene control (based on risk) to prevent product contamination.”

Each zone must have appropriate physical separation, personnel flow controls, and hygiene protocols to reduce cross-contamination risks, particularly for ready-to-eat (RTE) or vulnerable 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

  • Define and segregate hygiene zones based on product risk

    Implement hygiene and personnel controls appropriate to each zone

    Prevent cross-contamination between zones

    Document zoning rationale, maps, and hygiene procedures

Step-by-Step Compliance Implementation

1. Conduct a Zoning Risk Assessment

  • Assessment Factors:

    • Type of product (RTE vs. raw)

      Process flow (open vs. closed systems)

      Microbiological risk of contamination

      Environmental controls (airflow, humidity, traffic)

    Evidence to Maintain:

    • Risk zoning assessment report

      Justification for zone classification (High Risk, High Care, etc.)

      Zoning map with clear boundaries

2. Define and Enforce Zoning Boundaries

  • Control Methods Include:

    • Color-coded floor markings and signage

      Physical barriers and airlocks

      Entry/exit procedures and dedicated equipment

    Evidence to Maintain:

    • Facility layout with zoning overlays

      Access control logs and zoning SOPs

      Photo evidence of signage and barriers

3. Implement Hygiene Controls Per Zone

  • High Risk:

    • Strict segregation of raw and RTE areas

      Positive air pressure and HEPA filtration

      Dedicated clothing, footwear, and tools

      High-level handwashing and disinfection protocols

    High Care:

    • Controlled entry with hygiene stations

      Temperature and air control

      Regular environmental swabbing

    Ambient High Care:

    • Segregation from raw material areas

      Controlled personnel and equipment movement

      Focus on dry sanitation and allergen control

    Evidence to Maintain:

    • Hygiene SOPs per zone

      Training logs for hygiene and gowning procedures

      Records of environmental monitoring and compliance checks

4. Control Movement Between Zones

  • Movement Protocols:

    • Controlled personnel and material flow

      Gowning changes and hygiene checkpoints

      Disinfection of tools, trolleys, and containers

    Evidence to Maintain:

    • Visitor and contractor logs with zone access

      Cleaning and disinfection logs for cross-zone equipment

      Staff training acknowledgments on movement protocols

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
No clear zoning boundaries Use updated maps, signage, and barriers
Inconsistent hygiene controls between zones Implement zone-specific SOPs and training
Shared tools or clothing across zones Assign dedicated tools and PPE per zone
Inadequate staff awareness of zoning rules Reinforce through induction and periodic refreshers

Auditor Verification Checklist

During a BRCGS audit, expect to present:

  • Documented zoning risk assessment and classification

    Facility zoning maps with High Risk, High Care, and Ambient High Care identified

    Zone-specific hygiene SOPs and gowning procedures

    Environmental monitoring records for hygiene validation

    Training records showing staff awareness of zoning protocols

Implementation Roadmap

Assess and Define Zones

  • Conduct a zoning risk assessment

    Map production areas and assign zone classifications

Install and Implement Controls

  • Physically separate risk zones

    Apply signage, air pressure controls, and traffic barriers

Train and Monitor

  • Provide zone-specific hygiene training

    Monitor movement and hygiene compliance

Review and Improve

  • Regularly reassess zone classifications

    Update SOPs and monitoring plans as operations evolve

Why This Matters?

  • Prevents cross-contamination in high-risk processing areas

    Demonstrates BRCGS-compliant facility zoning

    Protects product integrity and consumer health

    Enhances audit readiness and regulatory confidence

Support Tools Available

Food Safety Systems provides:

  • Zoning assessment templates and classification guides

    Editable hygiene SOPs for High Risk, High Care, and Ambient High Care

    Facility zoning map examples and signage templates

    Training guides for staff movement and hygiene protocols