Is an egg packing room considered an open product area or an enclosed area in a food safety context? - IFSQN (2024)

Hello good afternoon and welcome!

Were you making a statement only or did you have a question?

Hi Brigita,

Welcome to the IFSQN forums.

I understand your comment regarding the egg being protected by the shell, but there is still a possibility for contamination (albeit a reduced one) and the product is not fully enclosed eithin packaging or equipment, so I would say shell egg packing would fall into an open product area - low risk category as per the decriptions from BRCGS below.

Open product areas

Wherever ingredients, intermediates or finished products are not protected from the factory environment, there is a potential risk of product contamination by foreign bodies, allergenic material or micro-organisms in the environment.

Low risk

The significance to human health of microbiological contamination in low-risk areas is reduced because the products either:

• do not support the growth of pathogens (either intrinsically or by design of the product) or the survival of pathogens, which could subsequently grow during the normal storage or use of the product

• are designed to undergo a later kill step that will ensure the product is safe to eat.

Enclosed product areas

An enclosed product area is defined as an area of the factory where all of the products are fully enclosed and therefore not vulnerable to environmental contamination (e.g. foreign bodies or micro-organisms). This includes areas where:

• the product is fully enclosed within packaging (e.g. raw material and finished product storage and dispatch areas)

• the product is fully enclosed within equipment

Kind regards,

Tony

Are the two processes - checking for cracks and storage - done at different times? If they are done at the same time, how far away is the storage from the open product? We have a LARGE area that contains both open and enclosed product and after a certain point, people aren’t required to wear their frocks over their clothes from home (where warehouse comes in to take away pallets of finished goods), but that is about the only differentiation there is between the two areas.

We work on lines at my facility, and the open product gets packaged as it flows down the line, and then gets toted and palletized. The product pallets are then taken from the production area to the warehouse (separated by a wall). Even when the product is fully packaged and traveling down the line and getting toted, we classify this as “open product” since there is a chance that the nearby open product could still get contaminated. Only when it’s on a pallet do we classify it as “enclosed”, because the palletizing area is far enough away from the open product that risk of contamination is negligible…so I would think you would need to do some sort of assessment to determine if there is a risk of contamination to the open product from the storage area. Hope that makes sense!!

Brigita--shell eggs are different than a lot of finished goods

The actual egg is ALWAY protected by the shell (which can be considered primary packaging)

You need a well written risk assessment that lays out that your product cannot be contamination by foreign material (chemicals exempted) without becoming inedible

Hello,
Oh, thank you! This is a good idea to think about it!

Brigita--shell eggs are different than a lot of finished goods

The actual egg is ALWAY protected by the shell (which can be considered primary packaging)

You need a well written risk assessment that lays out that your product cannot be contamination by foreign material (chemicals exempted) without becoming inedible

Hi Scampi,

First of all, the question in the OP is how would the area be classified in terms of BRCGS definitions, although personally I wouldn't get too hung on that providing appropriate controls were in place.

Whilst I understand the thoughts that the shell protects the egg, I would only agree that this is the case for foreign bodies but not so much so for chemicals and there are studies out there that have shown external loading to be important and that micro-organisms migrate into the egg under certain conditions.

Advisory Committee on the Microbiological Safety of Food - Advises the Food Standards Agency

An update on the microbiological risk from shell eggs and their products - Horizontal transmission leading to internal contamination of eggs

2.6 It is possible for micro-organisms to enter intact eggs if cooling takes place in amoist environment such that a negative pressure gradient is created that drawsfluids and suspended micro-organisms into the egg.

Impact of Different Layer Housing Systems on Eggshell Cuticle Quality and Salmonella Adherence in Table Eggs

The bacterial load on the eggshell surface is a key factor in predicting the bacterial penetration and contamination of the egg interior.

Kind regards,

Tony

Hi Brigita

We store, inspect/candle, grade and pack eggs in a single building

We treat eggs as enclosed product due to the shell

but the shell is porous and so 'water' is the biggest risk along with chemicals and that is what we manage.

In the UK it is prohibited to wash eggs

Part of the inspection is to remove very dirty eggs and any with blood stains

We still consider foreign body risks from glass etc that could get into the box, but not the egg

regards