Important aspects to be kept in mind while preparing Food Safety & Quality Manual: Policy: Organizations policies to be framed Organizations overall and departmental Quality Objectives in measurable terms to be framed Identifying the positions and competencies (education ,relevant experience) needed for performing the work to be documented Recruiting the personnel meeting the requirements as documented above Organization chart and roles & responsibilities to be documented Total layout of the plant in building to be kept including men and material movement Identifying each machine in plant and preparing inputs to the machine and output from the machine to be documented Process flow chart for manufacturing process from raw material inputs to the finished products and its storage and dispatch to be documented Training programs needed to the personnel as per manufacturing processes and processing of training as per these documented requirements to be ensured Handling of customer complaints on the products and its mechanism to be documented Ensure that all the requirements of the respective standard is addressed in the manual. To ensure this it is better to prepare a matrix indicating the requirements on the one side and compliance documents in the manual can be given Normally the following procedures will be documented irrespective of the standard being implemented. • Document control • Control of records • Recruitment of personnel • Training of personnel • Management review meeting • Internal audits • Handling customer complaints • Corrective action • Preventive action • Handling of potentially unsafe product / non conforming product • Verification & validation Raw material and finished product specifications has to framed Procedure for supplier evaluation eFresh Portal made an effort to prepare a Food Safety Manual Structure based on HACCP guidelines, which is generic and the same can be considered as a first step towards preparation of the Food Safety Manual and incorporating the requirements as applicable in individual case. SAMPLE British Retail Consortium Manual BRC Global Standard for Food Safety (issue 5), January 2008 INDEX Section Title Index Control and confidentiality Distribution list Amendment status Company Profile 1 Senior Management improvement 2 The Food safety Plan-HACCP 3 Food Safety and Quality Management System 4 Site Standards 5 Product control 6 Process control 7 Personnel Glossary of terms Commitment and continual MANUAL AUTHORISATION This BRC manual pertaining to Food Safety Enhancement Program has been prepared and established for effective controlling of the food safety hazards. The authority issue and changes to this Manual rests with the Management Representative who is designated as HACCP Coordinator/ of the company. Any change to the contents of this manual is guided and made according to the SOP – Document Control procedure. The minor changes incorporated are highlighted through italics in the document and whereas major changes through a revision note. The MASTER COPY of the manual rests with Management Representative and whenever changes are required in the manual it will be discussed in the Management review meeting and will be updated in the manual accordingly by Management representative (MR) of the company. This CONTROLLED COPY of the manual will be distributed as per the executives identified in the distribution list. Date: Distribution List Copy No. Distributed to Role in HACCP System 1 Management representative HACCP Coordinator/Team Leader 2 Manager QA HACCP team Member Amendment List S. No. Document / Topic Title Page No. Revision No. and Date Revision Description/ Reason Note: Amendment Record pertaining to BRC manual shall be maintained as per the above format by HACCP Food safety Team Leader and verified by HACCP Food Safety Team from time to time and details regarding amendments shall be intimated during MRM to the Top Management. INTRODUCTION: Of the company…………………………………… INFORMATION ON THE OPERATOR: Sl no Particulars Details 1. Name and Address of the Company & Manufacturing facility 2. Year of Establishment 3. PFA Reg. No. 4. Factory Reg. No. 5. No. of Shifts 6. Exemptions granted in relation to Food Safety 7. Details of the market 8. Statutory and Requirements Regulatory SCOPE OF APPLICATION: The British Retail Consortium Global Standard for Food Safety Systems described in this manual is applicable to the M/s.XYZ, Hyderabad for “The Procurement of raw materials, Storage, Processing, Packing, Storage and Dispatch of finished product”. The scope also covers other functions of the organization like maintenance, engineering and housekeeping, training etc. All the manufacturing processes such as Receipt of Raw Material and Packaging Materials, Storage, Processing, Packaging and Dispatch are carried out in the same location & form a part of the scope of the British Retail Consortium Global Standard for Food Safety Systems system. Receiving: Management will ensure procurement of appropriate raw material from reputed primary production / reputed suppliers and transported to the factory premises with adequate care. Storage: Organization ensures to store raw materials systematically with traceability and in appropriate conditions. Processing: By following Good Manufacturing Practices (GMP) / Good Hygiene Practices (GHP) in the production area, all operations are focused to ensure food safety. This includes cleaning sanitation, personnel hygiene, waste management and pest control etc. Packing: Organization packs the finished product in food grade packaging material by trained staff in hygienic condition. Dispatch: Dispatch of the finished product in clean and hygienic condition at ambient temperature. All the steps like procurement of raw material, storage & manufacturing processes such as cleaning, packing, storage and dispatch are carried out in the same location and forms a part of the scope of HACCP system. The HACCP system elements such as Product Information, Process Information, Hazards, Risk and Control Measures, Critical Control Points, Standards and Critical parameters, Monitoring of Critical Process limits, Corrective actions, Verification and Documentation are carried out for all product groups. Section 1: Senior Management Commitment and Continual Improvement The Top Management is fully committed to the implementation of the requirements of the Global Standard for Food Safety by making provision for adequate resources including effective communication, systems review and actions taken to effect continual improvement. Opportunities for improvement are identified, implemented and fully documented 1.1 The senior management is providing the required resource both human and financial for the identified process as per quality management system and the food safety plan. 1.2 Systems are established for clear communication and reporting to General Manager by Food safety Team Leader who monitors the compliance with the Global Standard for Food Safety and reports the effective compliance regularly. 1.3 Food safety and quality objectives have been established at each functional level and are documented, monitored and maintained. The food safety and quality objectives are periodically reviewed. Refer: Food Safety and Quality Objectives 1.4 Issues related to safety and legality of the products are identified and addressed through review meetings. Actions related to these identified safety and legal issues are recorded in Management Review Meeting minutes. 1.5 General Manager of the company is responsible for conducting such reviews. Refer: Management review meeting minutes 1.6 The review is conducted at an interval of 6 months to ensure critical evaluation of the food safety plan and the HACCP system’s suitability, adequacy and effectiveness. 1.7 The review process includes the evaluation of • Internal, second party and third party audits • Previous management review documents, action plans, and time frames • Customer performance indicators, complaints and feed back • Incidents, corrective actions, out-of-specification results and non conforming materials • Process performance and deviation from defined parameters • Reviews of the HACCP based system • Developments in scientific information associated with the product in scope • Resource requirements 1.8 Records of management reviews are comprehensively documented and retained. 1.9 The decisions and actions agreed within the review process are effectively communicated to appropriate staff, and actions implemented within agreed time scales. The records are updated to show when actions have been completed (Refer record of Management Review meeting minutes). 1.10 The current issue of the Global Standard for Food Safety is available with HACCP Team leader. 1.11 The certification to the Global Standard for Food Safety is maintained by the company by effective timescale planning to ensure that certification does not expire. 1.12 The General Manager of the company ensures to attend the opening and closing meetings of the audit for Global Standard for Food Safety certification. 1.13 The company’s Director and or General Manager ensure that non-conformities identified at the previous audit against the Standard are effectively acted upon. Section 2: The Food Safety Plan-HACCP The company’s food safety plan is on the basis of HACCP system which is systematic, comprehensive covering all products and processes. In the preparation a thorough analysis of activities has been done. The plan is fully implemented and maintained. The plan is made based on the Codex Alimentarius HACCP principles. Wherever applicable reference to legal requirements, codes practice or guidelines are provided. 2.1 The HACCP Food Safety Team—Codex Alimentarius Step 1 2.1.1 The HACCP plan is developed and managed by a multi-disciplinary food safety team that includes Quality Assurance, Production, Maintenance, Stores, Commercial and other relevant functions such as Personal and Purchase. The team members have specific knowledge of HACCP and relevant knowledge of product, process and associated hazards. 2.1.2 The Quality Assurance Manager is nominated as the HACCP team leader who has sufficient experience and competence in understanding the principles of HACCP and its applications. 2.1.3 The HACCP Food Safety Team has adequate HACCP training. The company has sought external expertise for training and documentation of Food Safety system. The day to day management and control of activities are fully controlled by HACCP team leader and team. 2.1.4 As a part of senior management Executive Director and or General Manager is fully committed for implementing and reviewing the Food Safety System by HACCP team. 2.2 Describe the Product –Codex Alimentarius Step 2 2.2.1 The HACCP Food safety team has defined the product and its related processes. 2.2.2 The information to conduct hazard analysis is collected by the following sources: • • • • • • The latest scientific literature Historical and known hazards associated with the product Relevant codes of practice Recognized guidelines Food safety legislation of the product in destination countries Customer requirements The information thus collected is maintained, documented and updated. The details of references and information are available with HACCP Food Safety Team. 2.2.3 The Product Characteristics developed gives detailed description of the product including relevant information on food safety. The product information contains • • • • • • • • • • • Composition of raw materials, ingredients, recipe Origin of ingredients Physical properties ( their impact on food safety) Chemical properties( their impact on food safety) Treatment and processing methods Packaging system Storage and distribution conditions Target safe self under prescribed storage and usage conditions Instructions for use Potential misuse Traceability 2.3 Identify Intended Use—Codex Alimentarius Step 3 2.3.1 The Intended Use of the product is described by considering • Target group of Consumer • Suitability of the product for vulnerable groups of the population e.g. infants, elderly, allergy sufferers. 2.4 Construct a Process Flow Diagram – Codex Alimentarius Step 4 2.4.1 The flow diagram is prepared to cover the process of the product. It covers all aspects of the food process operation within the HACCP scope –raw material selecton through processing, storage and distribution. The below mentioned aspects are considered for construction of the flow diagram: • • • • • • • • • • Plant and equipment layout Raw materials including utilities and other contact materials Utilities and other contact materials – water, packaging Sequence and interaction of all process steps Out sourced processes and subcontracted work Process parameters Potential for process delay Rework, reuse and recycling Low/high risk and clean/dirt area segregation Finished products, intermediate/semi-processed products, by-products and waste 2.5 Verify Flow Diagram – Codex Alimentarius Step 5 2.5.1 The HACCP food safety team verifies the accuracy of the flow diagram on site. The daily and seasonal variations are considered and evaluated. The verification records are maintained. 2.6 List All Potential Hazards Associated with Each Process Step, Conduct a Hazard Analysis and Consider any Measures to Control Identified Hazards – Codex Alimentarius Step 6, Principle 1 2.6.1 The scope of the HACCP Paln is confirmed by the HACCP Food safety team. The team list all the potential hazards that are reasonably expected to occur at each step in relation to product, process and facilities which may not be controlled by existing Pre requisites. The list also includes hazards • that are present in the raw materials, • those introduced during the process or surviving the process steps • allergen risk; and • preceding and following steps in the process chain 2.6.2 The HACCP food safety team conducts hazard analysis by identifying the hazards which need to be prevented, eliminated or reduced to acceptable levels. This HACCP study is based on the risk assessment. In conducting hazard analysis, the following factors have been considered. • Likely occurance of hazard • Severity of the effects on the consumer safety • Vulnerability of those exposed • Survival and multiplication of microorganisms of concern • Presence or production of toxins, chemicals or foreign bodies • Contamination of raw materials, intermediate/semiprocessed product or finished product • Potential for adulteration/delibrate contamination Risk Assessment: Hazard Analysis (Risk) • • FS Team Members shall identify, analyze and evaluate all potential hazards (biological/microbiological, chemical/ physical) that can have adverse effect on the safety of the food product. - The likely occurrence of hazards and severity of their adverse health effects - The qualitative and/or quantitative evaluation of the presence of hazards, - Survival or multiplication of microorganisms of concern, - Production or persistence in foods of toxins, chemicals or physical agents, and - Conditions leading to the above. The hazard analysis process is for identifying hazards, determining the risks and control/ reduction of the risk is the risk management. RISK MANAGEMENT PROCESS Hazard Identification Resp: FS Team Members - shall list all hazards and define its characteristics (Refer Hazard Analysis worksheets) Hazard Analysis (Risk Assessment) Resp: FS Team Members - shall estimate the magnitude of the risk Risk Control / Reduction Resp: FS Team Members - programme - control measures(Refer Hazard Analysis worksheets • Hazard analysis serves to identify the potential sources and specific points of contaminants by analysis of each step in the food manufacturing process. Hazard analysis shall be applied at all points from incoming material inspection to consumer. • Hazard Analysis has been conducted by the Food Safety Team based on the Flow Diagrams. Methodology followed for arriving a hazard is as follows: - Number all steps in the flow Diagrams - Verify each step of flow Diagrams for possible physical/chemical and Biological/Microbiological hazards - Assess the likelihood of the hazard - Asses the consequence / severity of the incident. - Based on the above, level or risks have been evaluated. All the risks are included with the help of group discussions by Food Safety Team and other associates from relevant areas. - The likely occurrence of the identified hazard, evaluated quantitatively, in terms of Very High, High, Medium or Low and likelihood of occurrence, as follows: LIKELIHOOD/ PROBABILITY CONSEQUENCES/ SEVERITY RISK / LEVEL Improbable (eg. 5- 10 years) 1 Rarely Unlikely (eg. yearly) 2 Minor (eg. Light injuries etc.) 1 5-6/Low Occational (eg. Monthly/4-6 Monthly) 3 Likely (eg. Weekly/Monthly) 4 Medium (eg. Injuries, stomach pain, uneasiness ) 2 Major(eg. Illness, Hospitalization) 3 Critical (eg. Death, Permanent disability) 4 7-9/ Medium Frequently (eg. Daily/ Weekly) 5 1-4/very Low DETERMINATION OF RISK AND SEVERITY OF HAZARDS 1. Probability of occurrence Very High > automatically happen High > Likely to happen Medium > could happen Low > Not likely to happen 2. Severity of each hazard Critical > Will frequently result in unsafe product Major > Will likely result in unsafe product Medium > May result in unsafe product Minor > Will not result in unsafe product 10-12/ High 15-20/Very High Determination of significance SEVERITY MINOR MEDIUM MAJOR CRITICAL PROBABILITY LOW XXXXX XXXXX ///////////////////////////// ///////////////////////////// MEDIUM XXXXX XXXXX ///////////////////////////// ///////////////////////////// HIGH XXXXX ///////////////////////////// ///////////////////////////// ///////////////////////////// VERY HIGH ///////////// ///////////////////////////// ///////////////////////////// ///////////////////////////// SIGNIFICANCE: XXXXX NO: //////////////// YES: Risk / Hazard Assessment • The severity of the hazard’s adverse health effects, evaluated quantitatively, in terms of critical, major or minor impact severity, as follows: • The risk rating, in quantitative terms (arrived at by multiplying the probability of occurrence with the severity of impact), and the classification of the identified hazard into significant or non-significant category based on the risk-rating factor. A risk rating of 10 or above indicates that the control measure is required to control the identified hazard. SEVERITY PROBABILITY LOW (unlikely) 2 MEDIUM (occasionally) 3 HIGH (Likely) 4 VERY HIGH (Frequently) 5 MINOR 1 MEDIUM 2 MAJOR 3 CRITICAL 4 5 9 10 12 7 10 12 15 9 12 15 17 12 15 17 20 • An explanation / justification for the risk rating arrived at, together with the general control measures in place for that risk. • A risk level of below 10 is generally considered as permissible and the routine OPRP’s and PRP’s are sufficient to control the hazard. It is the process of evaluating the magnitude of a risk and deciding whether or not it is acceptable. Risk is the combination of the likelihood (probability) and the consequences (severity) of a specified hazardous event occurring. To evaluate the risk, likelihood and consequences should be estimated. The organization has adopted the following model for risk analysis for identification of significant hazards to ensure food safety. 2.6.3 The HACCP food safety team identify the control measures--One are more control measures with synergitc effect necessary to prevent, eliminate or reduce the hazard to acceptable levels. Justification for acceptable levels in the finished product for each hazard is determined and documented. 2.7 Determine the Critical Control Points(CCP) – Codex Alimentarius Step 7, Principle 2 . EXAMPLE OF DECISION TREE TO IDENTIFY CCPS 2.7.1 2.8 Whether the particular step / process (Risk rating above 6) is a CCP is ascertained with the help of Decision Tree vide CCP determination and Justification. The CCP are determined by the above decision prevent, eliminates and / or reduces the hazard to acceptable levels for production of safe product. If a hazard is identified at a step where control does not exist, the product or process is modified at that step, at an earlier or later step, to provide a control measure. Establish Critical Limits for each Critical Control Point (CCP)– Codex Alimentarius Step 8, Principle 3 Refer: HACCP PLAN: [example of CCP] CCP Number: CCP Step Description: Significant Hazard: CCP Controller: Limits Critical Limits: Product temperature Not more than 12.5° C Action Limits: Product temperature 12.3° C Target Value: Product temperature 12.0° C 1 Step no. 1 Receiving raw material Bacterial pathogens Hazard Type: Raw material Temperature Control Measures Control Monitoring and Records What: Incoming material temperature check How: Calibrated hand held thermometer When: Every lot Where: Receiving section Who: Stores Supervisor Record Name: Incoming material inspection report Corrective Actions and Records 1. On Product: Check if product temperature is within acceptable limit of < 12.5°C and if yes then no problem. If no, then reject product. Who: Stores Supervisor Record Name: Incoming material inspection report Recorded By: Receiving Incharge B C P Manual monitoring of chilled raw material temperature of every lot. Verification and Records What: Product temperature records; Thermometer calibration records; cross check product temperature when lot is received. How: Periodic cross check of product temperature and Calibration certificate & frequency of calibration of thermometer. When: Record review every week Where: Receiving section Who: Production Head Record Name: as above. 2.8.1 For each CCP, the appropriate critical limits are defined in order to identify clearly if the process is in or out of control and if the identified acceptable level of the food safety hazard in the finished product is likely to be exceeded. Critical limits are measurable wherever possible (e.g. time, temperature, pH) and the rationale for their establishment is clearly documented. The HACCP food safety team has taken into account relevant legislation or codes of practice when establishing critical limits. 2.8.2 Criticls limits based on subjective data such as visual inspection are supported by clear guidance or examples. 2.8.3 The HACCP food safety team has validaed all the established CCPs and provides the documented evidence to show the control measures selected are capable of consisently controlling the hazard to the level specified by the critical limit. 2.9 Establish a Monitoring System for each Critical Control Point – Codex Alimentarius Step 9, Principle 4 Refer: HACCP Plan The HACCP food safety team has established a monitoring system for each CCP to ensure compliance with critical limits. 2.9.1 Each defined CCP is kept under control. The monitoring system is able to detect loss of control of CCPs and wherever possible information is provided in time for corrective action to be taken. The below mentioned monitoring system, as applicable, to keep CCPs under control is used: • online measurement (if applicable) • offline measurement (if applicable) • continuous measurement, if required. 2.9.2 where discontinuous measurement is used, the system ensures that the sample taken is representative of the batch of product,if applicable 2.9.3 Records associated with monitoring CCPs are signed by the person responsible for the monitoring and verified, as appropriate, by an authorised person.Appropriate records are maintained including details date and result of measurements carried out. 2.10 Establish a Corrective Action Plan – Codex Alimentarius Step 10, Principle 5 Refer: HACCP Plan 2.10.1 The HACCP food safety team has specified and documented the corrective action to be taken when monitored results indicate a failure to meet a control limit, or when monitored results indicate a trend towards loss of control. This also includes the action to be taken by nominated personnel-HACCP Food safety Team Leader with regard to any products that have been manufactured during the period when the process was out of control. 2.10.2 Documented procedures are established and maintained for the appropriate handling of potentially unsafe products to ensure that they are not released until confirmed as suitable for release. 2.11 Establish Verification Procedures – Codex Alimentarius Step 11, Principle 6 2.11.1 Verification Procedure is established to confirm that the HACCP plan is effective. The verification activities includes: • internal audits • review of records where acceptable limits have been exceeded • review of complaints by enforcement authorities or customers • review of incidents of product withdrawal or recall. 2.11.2 Verification results are be recorded and communicated to the HACCP food safety team 2.12 HACCP Documentation and Record Keeping – Codex Alimentarius Step 12, Principle 7 2.12.1 The records and documents are maintained to implement the system and to demonstrate its effective functioning. • Reference Documents • Cleaning and Sanitation Documents. • Pest Control related Documents. • Validation and Verification Document. • Preventive Maintenance Program. 2.13 • Personnel Hygiene & training • Records related MRM, Internal Auditing etc • Records as per the HACCP plan Review the HACCP Plan 2.13.1 The HACCP food safety team ensures that procedures exist to review the HACCP plan prior to any changes which may affect product safety. Review of HACCP Plan is carried out when there is a , • change in raw materials or supplier of raw materials • change in ingredients/recipe • change in processing conditions or equipment • change in packaging, storage or distribution conditions • change in staff or management responsibilities • change in consumer use • developments in scientific information associated with ingredients, process or product. Appropriate changes resulting from the review are incorporated into the HACCP plan, fully documented and validated. 2.13.2 Irrespective of any of the above changes, the HACCP plan is reviewed annually once and records are maintained. Section 3. Food Safety and Quality Management System 3.1 Food Safety and Quality Policy Refer: Food Safety and Quality Policy FOOD SAFETY POLICY Policy statement: The Food Safety Team in M/S.XYS Company is committed to serving food to its guests prepared under hygienic and safe conditions. Our Food Safety Practices shall: • • • • • • • Ensure that only Trained and Skilled staff are inducted into the kitchen Reflect Food Safety Standards in relation to safety practices, premises and equipment standards Reinforce consistent food safety practices in the service Aim at providing Safe and Hygienic food Reduce the risk of potential food-borne illnesses Comply with legislative requirements while maintaining a flexible approach to meet the best practices Reflects continual improvement in the Food Safety Standards. This commitment to Food Safety Policy will be demonstrated by the management conforming to Food Safety Management System based on BRC requirements and the following objectives as mentioned in the table on the next page. FOOD SAFETY AND QUALITY OBJECTIVES AT FUNCTIONAL LEVELS FOR THE PERIOD OF 2011-2012 S.NO FUNCTION OBJECTIVE RESPONSIBILITY LEVEL (Functional Heads) 1 HR To give employees, a minimum Manager QC of one training program in a month in handling, processing, and serving of the safe food. 2 Purchase / Stores Nonconforming input materials not more than 5% per supplier of the total consignment per month Manager Stores 3 Production / Manufacturing To bring down the wastage of the Executive Chef food to 5 % of the total production. 4 Quality Assurance Customer complaints: Not more than 5% per month Manager Production The company’s Food safety and Quality Policy is developed, documented and established by Director duly authorized -signed and dated. The policy is reviewed for suitablity and adequecy once in a year during Management Review Meeting. 3.1.1 The policy states the company’s intention to meet the obligation to product safety, quality, legal requirements and its responsibility to customers. It states commitment for review and continual improvement. The importance of meeting statutory, legal and customer requirements are communicated to all levels of staff by the Management through display boards and training programs. The policy requirements are understood and accordingly implemented by all concerned staff and key personnel. 3.2 Food Safety and Quality Manual BRC Manual is the Food Safety and Quality Manual which describes the requirements of the Global Standard for Food Safety. These requirements are implemented, reviewed once in six months and revised if necessary. 3.2.1 This manual contain or make references to the Standard working procedures SOPs, work sheets, working methods and practices, which are used to meet the requirements of the Standard. 3.2.2 This manual and related document is readily available to the key staff. The copy holders are given in Distribution List of the manual. 3.3 Organisational Structure, Responsibilities and Management Authority Refer: Refer Organization Chart from HACCP manual The company has an organizational structure, which ensures that the job function, responsibility and reporting relationship of all personnel, whose work affect the product safety, agility and quality are clearly defined and documented. 3.3.1 The organization structure demonstrates the structure of the company. 3.3.2 The levels of responsibility and accountability are clearly defined for key staff in product quality, safety and legality. 3.3.3 Whenever specified staff is on leave either replacement is given by the person having equal subject knowledge on the specific work 3.3.4 The description of general duties / work instructions are made available at the place of work and communicated to all the staff involved with the activities related to product safety, legality and safety. 3.3.5 A suitable system has been developed to collect all information related to legislative requirement of the product, Quality and Food safety issues, scientific and technical developments, industrial code of practice applicable to the country of origin / sale. Organization Chart Managing Director Production Manager Electrician Plant Operators Maintenance in charge Microbiologist Supervisor Supervisor Manager Procurement Manager QA Supervisor Hygiene Supervisor Highlighted is the HACCP team Stores in charge HR Manager Ripening shed in charge 3.4 Contract Review and Customer Focus Customers requirements and expectations with regards to product safety and quality are identified based on direct interactions and feedbacks. The procedure clearly defines the method, roles and responsibilities of the process and personnel. 3.4.1 The Marketing Department is responsible for communications with customers and has an effective system for communication via e-mails, telephone and software for order processing. 3.4.2 Customer requirements relating to the development, specification, manufacture and distribution of product are defined through specification and approvals of the contracts prior to the release of orders. It is ensured that these requirements are fulfilled. If specification are not formally agreed upon, the order clearly mentions the approval for acceptance of the product as per companys specification by the customer. 3.4.3 Depending on the contract/agreement period, the customers’ needs and requirements are reviewed. Any changes to the existing agreements or contract are agreed by the marketing department upon approval of Director and communicated to the Production, Quality Assurance and other appropriate departments. 3.4.4 Customer satisfaction index is established to monitor the customer satisfaction levels and communicated to appropriate staff. 3.5 Internal Audit The company audits those systems and procedures which cover the requirements of the Global Standard for Food Safety to ensure that they are in place, appropriate and complied with. 3.5.1 Audits are scheduled based on the risk assessment with minimum of 6 months intervals. Their scope and frequency is established or modified based on the risk associated with the activity. 3.5.2 The internal audits are carried out buy the audit team who are trained and competent. It is ensured that they do not audit their own area of work or have direct influence on the operation over the section, which is audited. 3.5.3 Records of internal audits are maintained to ensure that the conformity / non-conformity are clearly identified and verified. 3.5.4 The results of internal audit are brought to the attention of the personnel responsible for that activity. The corrective actions and time scales for implementation are finalized and agreed. 3.5.5 The completions of the corrective actions are verified by the HACCP Food Safety Team Leader or Director or General Manager upon the agreed date. 3.5.6 The records of all scheduled internal audits and associated action and audit reports are maintained to demonstrate compliance and to ensure non-conformities can be identified and verified. 3.6 Purchasing – Supplier Approval and Performance Monitoring All purchasing processes that are critical to product quality, safety and legality are controlled to ensure that products and services procured confirms to defined requirements. 3.6.1 Purchase describes the procedures adopted for supplier approval and continual assessment program. These continual assessments are done based on risk assessment. 3.6.2 The procedures also cover the criteria for assessment and standards for approval. The assessment may cover one of the following forms of monitoring performance. • In house verification. • Verifying certificate of analysis. • Through suppliers inspection reports. The supplier’s assessments include evaluation of HACCP systems, product safety information, traceability and legislative requirement. 3.6.3 The procedure also describes how exceptions are handled. E.g. use of products and services when audit or monitoring is not undertaken. 3.6.4 Based on the new supplier performance during the trial period, further decision on ongoing supplier performance monitoring is decided. 3.7 General Documentation Requirements Documentation Control Through Control of Documents procedures the company ensures that all documents, records and data critical to food safety management, legality and quality are in place and effectively controlled. 3.7.1.1 All documents in use are properly authorized and correct version is ensured. 3.7.1.2 Documents are legible and unambiguous and sufficiently detailed to facilitate correct application by appropriate personnel and accessible at all times. 3.7.1.3 Reason for changes and changed details critical to product quality, safety & legality and procedures recorded. 3.7.1.4 The procedures address controls available in identification and removal of obsolete documents and replacement with updated version. 3.7.2 Specifications Company’s specifications have been developed and cover 1) Raw material including Packing material 2) Finished products 3) Intermediate semi-processed products; and Any other product or service that could affect integrity of the finished product. 3.7.2.1 It is ensured that the company’s specifications are adequate, accurate and match with relevant safety and legislative requirements. 3.7.2.2 It is ensured that the manufacturing instructions comply with recipes as detailed in agreed customer specifications and implemented. 3.7.2.3 Customer specification if any are formally agreed and authorized by relevant parties. If the specifications are not formally agreed then suitable steps are initiated to get approvals. 3.7.2.4 The specifications are reviewed once a year or whenever changes are carried out to ensure adequacy and correct status. 3.7.2.5 Specifications and/or their contents are accessible to relevant staff. 3.7.3 Record Completion and Maintenance Records are maintained to demonstrate the effective control of product safety, legality and quality. 3.7.3.1 While preparation of records genuinely and legibility is ensured, approved by authorized person retained in good condition for defined time period. 3.7.3.2 Alterations in the record are authorized by appropriate persons and justification for alteration is also recorded by the authorized person. 3.7.3.3 The procedure for control of records explains collection reviewed maintenance storage and retrieval of all records related to product safety, legality and quality. 3.7.3.4 The retention time for documentation and record is based on the shelf life of the product and to consider the extended shelf life at customer end (e.g.) freezing. 3.7.3.5 Any legal and customer specific requirements relevant to record retention is taken into account. 3.8 Corrective and Preventive Action Corrective action procedures have been established to investigate the cause of the non conformity against standards, specifications and procedures that are critical to product safety, legality and quality. 3.8.1 The corrective actions are accurately documented in corrective action reports clearly indicating person assigned and accountable. 3.8.2 Corrective actions are implemented to prevent further occurrence of non-conformity. 3.8.3 Corrective action plans related to safety, legality and quality of products are agreed by personnel who are responsible and accountable for the areas of control. These personnel also verify and report to satisfactory completion of the corrective action planned. 3.8.4 The completion of corrective actions are monitored and recorded to ensure their effectiveness and completion within an appropriate timescale. 3.9 Traceability Suitable traceability system has been developed. This system has the ability to trace and follow all raw materials including primary packing material from source through all stages of processing and distribution of finished product to the customer. 3.9.1 Identification of raw materials including primary and any other relevant packaging and processing aids, intermediate/semi-processed products, part-used materials, finished products and materials pending investigation, are adequate to ensure traceability. 3.9.2 The system is tested once a year to ensure traceability can be determined from raw material to finished product and vice versa. It includes quantity check/ mass balance. Traceability records are maintained. 3.9.3 If there is a requirement to ensure identity preservation within supply chain, e.g. Use of logo then appropriate control and testing procedures are established. Relevant test records are available at HACCP Food safety Team Leader. 3.9.4 When rework or reprocess is carried out, then traceability is maintained. In addition, the company demonstrates that this does not affect the safety or legal status of the finished product, e.g. ingredient declaration, allergy information or identity preservation. 3.10 Complaint Handling Suitable system for management of product related to complaint is established. 3.10.1 All complaints are recorded, investigated and the results of the investigation recorded. 3.10.2 Immediate corrective actions are initiated for customer complaints depending on the seriousness and frequency of the problem. Suitable replies are given to the customer based on the root cause analysis. 3.10.3 As a part of data analysis, the complaint data is analyzed to initiate preventive actions and part of on going improvements related product safety, legality and quality. 3.11 Management of Incidents, Product Withdrawal and Product Recall Plans and procedures have been developed to effectively manage incidents, product withdrawals and product recalls. 3.11.1 The company has procedures designed to manage effectively incidents and potential emergency situations that impact food safety, legality or quality and have effective product withdrawal and product recall procedures in place. This includes consideration and contingency planning for business continuity and product withdrawal or recall in the event of the following: • disruption to key services such as water, energy, transport, staff availability and communications • events such as fire, flood or natural disaster • malicious contamination or sabotage. 3.11.2 Emergency preparedness procedure provides the guidance to relevant staff regarding type of event that would constitute an incident or emergency situation that impacts food safety, legality or quality. Such incidents reported are recorded. 3.11.3 Emergency preparedness procedure includes the follwing details: • identification of key personnel constituting the incident management team with clearly identified responsibilities • an up-to-date list of key contacts, e.g. incident management team, emergency services, suppliers, customers, certification body, regulatory authority • a communication plan including the provision of information to customers, consumers and regulatory authorities in a timely manner • details of external agencies providing advice and support as necessary, e.g. expert laboratories, regulatory authority and legal expertise • product withdrawal and/or recall procedures • corrective action and business recovery. 3.11.4 The procedure for incident reporting, product withdrawal and product recall are made in such a way that they can operate for any product at any time. While developing these procedures, the possible product stock, logistics involved, the recovery, storage and disposal of the recalled product is also considered. These procedures are reviewed once in a year and if necessary revised / updated. In line with the corrective and preventive action procedures, the incidents, recall, product returns and withdrawals are analyzed and corrective and preventive actions are initiated 3.11.5 Mock drills are conducted once a year to test the effectiveness of product recall / withdrawal procedures. The results of the mock drill is retained and reviewed for necessary improvements. 3.11.6 The Executive Director ensures that results of this test is used to implement improvements as necessary. 3.11.7 In the event of a product recall, the certification body and appropriate authority is informed in a timely manner. Section 4: Site Standards 4.1 EXTERNAL STANDARDS The factory site is located, constructed, designed and maintained so as to prevent contamination and enable the product on of safe and legal products. 4.1.1 Consideration is given to local activities and environment, which can have adverse impact on the product, and control measures are taken to prevent product contamination, if applicable. Whenever such measures are taken, then these are reviewed to ensure they continue to be effective e.g. dust or odor control. 4.1.2 The external areas are maintained in good order. An unwanted growth like weeds and shrubs are periodically checked and removed. The condition of the site is included in the internal audit process. 4.1.3 Suitable drainage systems have been constructed and maintained. All the drainage systems lead to the Effluent Treatment Plant. 4.1.4 External traffic routes, under site control are paved and maintained in good repair to avoid contamination of the product. 4.1.5 The building fabric are maintained to minimise potential for product contamination, e.g. pipe work are appropriately sealed to prevent pest entry, ingress of water and other contaminants. 4.2 Security Measures are in place to maintain site security and ensure only authorized staffs have access to production and storage areas. 4.2.1 Access to the site by employees, contractors and visitors is controlled and a visitor reporting system is in place. Prior to the entry into the production or storage primeses, vistors has to fill the required details in the Visitor’s Declaration Form 4.2.2 Staff are trained in site security procedures and encouraged to challenge unidentified or unknown visitors. The visitors are provided with the apron and visitor’s pass which is later handed over to the Security at the main entrance. 4.2.3 Measures are in place to maintain site security and to ensure only authorised staff have access to production and storage areas via designated access points. Areas are assessed according to risk; sensitive or restricted areas are defined, clearly marked, monitored and controlled. 4.2.4 Based on risk assessment, procedures are in place to ensure the secure storage of all materials including ingredients, packaging, chemicals and equipment. 4.2.5 Procedures are in place to ensure that finished product is held under secure storage and transportation conditions, e.g. tamper evident packing, contractual handling agreements. 4.2.6 Site is registered with and approved by Mr.XYZ.The Registration Number is ………………… 4.3 Internal Site Standards 4.3.1 Layout, Product Flow and Segregation Premises and plants are designed, constructed and maintained and procedures put in place to control the risk of product contamination and to comply with all relevant legislation. 4.3.1.1 The process flow from intake to dispatch is arranged in such a way that the risk of product contamination is minimized. The process flow is well documented in the Process Flow Diagram referred in this manual. 4.3.1.2 Segregation of products (If required) takes into account the flow of product, nature of materials, equipment, personnel, waste, airflow, air quality and utilities provision. 4.3.1.3 Facilities for cleaning and washing of housekeeping equipments and containers and general purpose cleaning are adequately segregated from all production areas. 4.3.1.4 Premises allow sufficient working space and storage capacity to enable all operations to be carried out properly under safe hygienic conditions. 4.3.1.5 Cleaning and inspection of areas and equipment are aided by the avoidance of obstructions and where appropriate the provision of adequate space. 4.3.1.6 Temporary structures constructed during building work or refurbishment, etc., are designed and located to avoid pest harbourage and potential contamination of products. 4.3.1.7 To avoid the risk of growth of pathogenic microorganisms, finished products are segregated from raw material and other processing areas. These high risk areas are designed and maintained under high standard of hygiene. Hygiene controls related to personnel, ingredient, equipment, packaging and environment are in place to prevent contamination of product by microorganisms. Packing area in the main building, Raw material ware house, Packaging material ware house and finished goods ware house are well segregated. 4.3.1.8 The processing methods are developed to reduce the potential physical, chemical or microbiological contaminations and risks. Physical contaminations are controlled by manual check at the time of receiving. Chemical and microbiological contaminations are controlled by procuring raw materials from the approved suppliers RO treatment to process water Proper machinery (like closed pipelines, no leakages etc) Fabrication-Raw Material Handling, Preparation, Processing, Packing and Storage Areas The fabrication of the site, buildings and facilities are suitable for the intended purpose. 4.3.2.1 Walls 4.3.2.1.1 The Walls are designed, constructed, finished and maintained to prevent the accumulation of dirt, reduce condensation and mould growth, and facilitate cleaning. 4.3.2.2 Floors 4.3.2.2.1 Floors shall be designed to meet the demands of the process, and withstand cleaning materials and methods. They shall be impervious and maintained in good repair. 4.3.2.2.2 The Drainages are designed and maintained suitably to minimize risk of product contamination / product safety. Drains from laboratories are kept in such a way that they do not present a risk to the products. 4.3.2.2.3 The Floors are built with sufficient slope to cope up with the flow of any water towards drainage where applicable. 4.3.2.3 Ceilings/Overheads 4.3.2.3.1 Ceilings and overheads are designed, constructed, finished and maintained to prevent the accumulation of dirt, minimise condensation and mould growth, and facilitate cleaning. 4.3.2.3.2 Where suspended ceilings are used, adequate access to the void is provided to facilitate cleaning, maintenance of utilities and inspection for pest activity. 4.3.2.4 Windows 4.3.2.4.1 Where windows are designed to be opened for ventilation purposes, they are provided with mesh to prevent entry of pests. 4.3.2.4.2 Glass windows are paneled and prevented from breakage by providing hooks and made shatter proof by poly-lining 4.3.2.5 Doors 4.3.2.5.1 Doors in the raw material stores, processing, packing and product storage areas are either kept closed or provided with curtains to prevent pest entry. 4.3.2.5.2 Doors are in good condition and easy to clean, where required. 4.3.2.6 Lighting 4.3.2.6.1 Adequate lighting is provided for all work areas. 4.3.2.6.2 All bulbs and tube lights, including those on pest-o-flash units, in the high care zone, are protected by shatterproof plastic covers 4.3.2.7 Air Conditioning/Ventilation 4.3.2.7.1 Adequate ventilation and extraction is provided in product storage and processing environments to prevent condensation or excessive dust. 4.3.2.7.2 Wherever filtered air is required, the blowers, exhaust fans and the filters used for this purpose are adequately maintained. 4.3.2.7.3 The entire material movement is either by manual, fork lifts, and trolleys. 4.4 Utilities All utilities to and within the production and storage areas are designed, constructed, maintained and monitored to control the risk of product contamination. 4.4.1 All water used as processing aid in the production unit or for equipment or plant cleaning is potable and pose no risk of contamination. Water used for toilet and washing is also from the bore wells and the storage tanks are protected and cleaned periodically to minimize any risk of contamination. 4.4.2 The quality of water, air and compressed air that comes into contact with food or packaging is regularly monitored to avoid risk to product safety or quality. 4.5 Equipment Equipment are suitably designed for the intended purpose and used so as to minimize the risk of contamination of product. 4.5.1 All equipments shall be properly specified before purchase and tested and commissioned prior to use. 4.5.2 The layout and positioning of equipment is made in such a way that there is adequate access in and around them for ease of cleaning and servicing. 4.5.3 Certificates of conformity or other evidence are available for equipment in direct contact with food to confirm its suitability for use, e.g. conveyor belts. 4.6 Maintenance A system of planned maintenance is in place covering all items of equipment and plant, which are critical to product safety, legality and quality. 4.6.1 Equipment, including fixtures and fittings, are maintained in such condition as to minimise the risk of product contamination. 4.6.2 Whenever new equipment is commissioned, based on the risk assessment, suitable preventive maintenance instructions are developed and implemented. 4.6.3 During maintenance and cleaning operations, sufficient controls are maintained to avoid product contamination and to ensure the safety or legality of product is not affected. 4.6.4 In addition to any planned maintenance programme, where there is a risk of product contamination by foreign bodies arising from equipment failure, the equipment are inspected at predetermined intervals, inspection results documented and appropriate action taken. 4.6.5 Where temporary repairs are carried out, , packing, binding wires, etc., they are controlled to ensure the safety or legality of product is not affected. As soon as possible, they are made permanent. 4.6.6 Contractors involved in maintenance or repair activities are under the supervision of a nominated person. 4.6.7 Maintenance work is followed by hygiene clearence procedure-House Keeping activity, recording that the product contamination hazards have been removed from the machinery and equipment. On completion of maintenance work, care is taken to clean and make free from contamination hazards. 4.6.8 Materials used for equipments and plant maintenance such as lubricating oil and paints, that may pose a risk by direct or indirect contact with raw materials, intermediate and finished products, is ensured that they are suitable for intended use. 4.6.9 Engineering workshops are controlled to prevent risk of contamination to the product. 4.7 Staff Facilities Staff facilities provided is sufficient to accommodate the required number of personnel, and are designed and operated to minimise the risk of product contamination. Such facilities is maintained in good and clean condition. 4.7.1 The changing facilities for staff, visitors and contractors are located in such a way that after changing the personnel has direct entry into the production, packing or storage areas without recourse to any external area. 4.7.2 The workers who work in raw material handling, processing, preparation, packing and storage area are provided with sufficient size storage shelves to accommodate all personal items. 4.7.3 The workers are provided with storage shelves so that outdoor clothing and other personal items are stored separately from work wear. 4.7.4 Suitable and sufficient hand washing facilities are provided at the entry points of the production areas. The facilities include, • sufficient quantity of water at an appropriate temperature • liquid soap • single use towels or suitably designed and located air driers • appropriate instructions for use . Where high-risk products are handled, the following additional requirements are provided: • water taps with hand-free operation • hand disinfection 4.7.5 Toilets are adequately segregated from production, packing and storage areas and do not open directly into these areas. The facilities include, • sufficient quantity of water at an appropriate temperature • liquid soap • single use towels or suitably designed and located air driers • appropriate instructions for use. 4.7.6 Smoking is not permitted inside the factory premises. 4.7.7 No food consumption is permitted in the processing and packing areas. Suitable provision is made for the storage of food brought onto the premises by staff in clean and hygienic state. 4.7.8 If catering facilities are provided, it shall be suitably controlled to prevent contamination of product. 4.7.9 Tea and refreshment is served in the designated area and waste generated is appropriately disposed. 4.7.10 Facilities provided for visitors and contractors are as per company’s hygiene norms. 4.7.11 Where an operation involving high-risk products (refer to glossary) exists, personnel enter via a specially designated changing facility, and follow specified procedures for applying visually distinctive clean overalls, headwear and footwear. 4.8 Chemical and Physical Product Contamination Control. Raw Material Handling, Preparation, Processing, Packing and Storage Areas Appropriate facilities and procedures are in place to control the risk of physical or chemical contamination of product. 4.8.1 The company has identified the potential risks from chemical, physical or taint contamination based on risk assessment. The risks are controlled and managed by appropriate control measures. The areas associated with such risks are • Storage • Production operation or processes or machinery • any maintenance or building work carried out • hygiene and cleaning operations Such Potential contamination from building material and overhead structures are controlled through regular documented audits and corrective action is taken to minimize risk of product contamination. 4.8.2 4.8.2.1 Chemical Control Chemical control procedure details the use , storage and handling of non-food chemicals. The controls includes are 4.8.3 • Approved purchase • Availability of material safety data sheets and specifications • If required, confirmed suitability for food use • Avoidance of strong scented products • Identification of chemicals at all times • Segregated and secure storage with restricted access to authorized personnel • Use of trained personnel only Metal Control 4.8.3.1 The documented metal policy provides the control of the use of sharp metal implements including knives, cutting blades on equipment, needles and wires including suitable controls both into and out of the factory, and safe disposal. 4.8.3.2 Snap-off blade knives are not to be used. 4.8.3.3 Non-production blades, equipment and tools are not to be left in a position that allows them to contaminate the product. 4.8.3.4 Where staples or other items are used which are likely to cause contamination in packaging, appropriate precautions are taken to minimise the risk of product contamination. 4.8.4 Glass, Brittle and Hard Plastic, Ceramics and Similar Materials 4.8.4.1 All glass and brittle material in raw material storage, processing, packing and product storage areas are listed in a register indicating its locations and checked for damage at specified intervals determined by risk analysis. 4.8.4.2 Documented procedures for handling glass, brittle or hard plastic, ceramic or other similar materials is in place and implemented to ensure that necessary precautions are taken. Procedure includes: 4.8.4.3 4.8.5 4.8.5.1 4.8.6 • list of items detailing location, number, type and condition • recorded checks of condition of items carried out at a specified frequency based on risk assessment • details on cleaning or replacing items to minimise potential for product contamination. Documented procedure details the action to be taken in case of breakage of glass, brittle or hard plastic, which includes glass packaging and similar material based on risk assessment. The action paln includes the following: • quarantining the products and production area that were potentially affected • cleaning the production area • inspecting the production area and authorising to continue production • changing of workwear and inspection of footwear • specifying those staff authorised to carry out the above points • recording the breakage incident. Wood In areas where a risk assessment has identified the potentials for product contamination from wood, the use of wood is excluded. Where the use of wood cannot be avoided, and the risk is managed, the condition of wood shall be regularly checked to ensure it is in good condition and clean. Other 4.8.6.1 Filters, sieves and magnets used for foreign body control are regularly inspected and properly maintained. Such activities are recorded and investigated. 4.8.6.2 Based on risk assessment, procedures are implemented to minimise foreign body contamination of packaging during filling operations, e.g. covered conveyors, container inversion and foreign body removal through rinsing or air jets. 4.9 Housekeeping and Hygiene Housekeeping and cleaning systems are in place which ensure appropriate standards of hygiene are maintained at all times and that risk of contamination in minimized. 4.9.1 Documented cleaning schedules have been developed and followed for building, services, plant and all equipment. Cleaning procedures include the following: • responsibility for cleaning • item/area to be cleaned • frequency of cleaning • method of cleaning • cleaning materials to be used • cleaning records and • responsibility for verification. 4.9.2 Cleaning-in-place (CIP) facilities are monitored and maintained to ensure effective operation. Consideration is given to frequency, cycle time, temperature, chemical concentration and spray ball location and coverage. CIP have adequate separation from active product lines. 4.9.3 Cleaning and housekeeping is carried out by trained personnel in accordance with documented procedures and records are maintained. 4.9.4 Cleaning chemicals and equipments are chosen based on • fit for purpose • suitably identified for intended use, e.g. colour coded or labelled • stored in a hygienic manner to prevent contamination 4.9.5 The effectiveness of the cleaning and sanitation procedures is verified and recorded. Corrective actions are documented. 4.9.6 Cleaning and disinfection procedures are revalidated following building or maintenance work, new product introduction or changes to equipment. 4.10 Waste/Waste Disposal There are adequate systems for the collection, collection disposal of waste material. 4.10.1 Systems are in place to avoid the accumulation of waste in production areas and prevent the use of unfit materials. 4.10.2 Presently there are no legislative requirement for waste / scrap disposal. 4.10.3 The waste / scrap are disposed through approved contractors. 4.10.4 External waste collection bins and containers are clearly marked and controlled to avoid mix up and to minimize risk. The containers/ bins are • clearly identified • designed for ease of use and effective cleaning • well maintained to allow cleaning and where required, disinfection • emptied at appropriate frequencies • covered or doors kept closed as appropriate 4.10.5 If substandard trademarked materials are transferred to a third party for destruction or disposal, it is ensured that third party is a specialist in secure product or waste disposal and provide records of material destruction or disposal. 4.11 Pest Control 4.11.1 The company is responsible for minimizing the risk of pest infestation on the site. 4.11.2 The company has a contract with a competent pest control organization for regular inspection and treatment of premises to deter and eradicate infestation. The service contract clearly defines and reflects the activities of the site. 4.11.3 Pest Control procedures and inspection documentation are maintained. This includes: • an up-to-date, signed and authorised site plan identifying numbered pest control device locations • identification of the baits and/or monitoring devices on site • clearly defined responsibilities for site management and the contractor • details of pest control products used and instructions for their effective use. Detailed records of the pest control inspections, necessary action under taken are maintained. 4.11.4 Bait stations are placed at outer wall of the plant. They are robust, of tamper resistant construction, secured in place and appropriately located to prevent contamination risk to product. 4.11.5 The pest-o-flash/pheromone are correctly positioned and operations throughout manufacturing operations and periodically checked and cleaned. 4.11.6 In the event of infestation, immediate action are taken to eliminate the hazard. Action are taken to identify, evaluate and authorise the release of any product potentially affected. 4.11.7 Detailed records of pest control inspections, recommendations and actions taken are maintained. The company ensures all of the relevant recommendations made by their contractor are carried out and monitored. The completion of corrective action are demonstrated by documented evidence. 4.11.8 Results of pest control inspections are assessed and analysed for trends regularly, in the event of an infestation and annually.This includes a catch analysis from trapping devices to identify problem areas. Any such problems are suitably rectified. 4.12 Storage and Transport All facilities used for the storage and transportation of product, movement around the site, and dispatch of finished product are suitable for the purpose, maintained in good repair and in a hygienic condition. 4.12.1 Procedures to maintain product safety and quality during storage, loading and transportation are developed on the basis of risk assessment and implemented accordingly. These may include as appropriate the following list: • controlling temperature • cleaning storage areas and vehicles • segregating to avoid cross contamination or taint uptake • storing materials off the floor and away from walls as appropriate • ensuring that vehicles such as bulk tankers are of hygienic design and designated for food use; putting in place procedures to prevent cross contamination from previous loads • vehicle pre-loading and unloading inspection • vehicle loading or unloading in covered bays • maintaining product security and preventing damage. 4.12.2 Where temperature control is required, the storage area or transport facility are capable of maintaining product temperature within specification, under minimum and maximum load and under worst case ambient temperature. 4.12.3 Where temperature control is required, documented procedures are in place to ensure product temperature requirements are met. This shall include temperature data-logging devices which can be interrogated to confirm time/temperature conditions or a system to verify and record at predetermined frequencies the correct operation of refrigeration equipment. 4.12.4 Where storage outside is necessary, items are protected from contamination and deterioration. 4.12.5 Receipt documents and/or product identification facilitate correct stock rotation of goods in storage and ensures materials are used in the correct order and within the prescribed shelf life. 4.12.6 If the company employs third-party contractors, all the requirements specified in this section are clearly defined in the contract or the company shall be certificated to the Global Standard for Storage and Distribution. 4.12.7 Traceability is ensured during storage and transportation. There are clear record of dispatch and receipt of goods and materials to demonstrate that sufficient checks have been completed during the transfer of goods. The returned goods from market is stored at an identifed area. The returened material along with packing material inspected and disposed as appropriate. 4.12.8 Documented maintenance and hygiene procedures are maintained for all vehicles and equipment used for loading/unloading. The records of the measures taken are maintained. 4.12.9 Procedures are in place in the case of vehicle breakdown. All incidents of vehicle or equipment breakdown are recorded and corrective action documented. Section 5: Product Control 5.1 Product Design/Development Product design and development procedures are in place to ensure manufacturing processes are capable of producing a safe and legal product. 5.1.1 During Product design and development process, HACCP plan is developed to identify potential hazards and the control measures. 5.1.2 Factory trials are carried out and thorough testing to validate that product formulation and manufacturing processes are capable of producing a safe and legal product against the proposed shelf life. 5.1.3 Shelf-life trials are undertaken using documented protocols reflecting conditions during storage and handling throughout shelf life. Test Results are recorded and retained which confirm compliance with relevant microbiological, chemical and organoleptic criteria. 5.1.4 During new products introduction, the company ensures control of handling requirements for specific materials. 5.1.5 Purchase Procedures ensures that product packaging conforms to relevant food safety legislation and specification and is suitable for its intended use. 5.1.6 The Executive Director / General Manager ensures that a system is in place to confirm that labelling of the product or other forms of customer information meets legislation for the designated country of use and in accordance with the appropriate product specification. 5.1.7 Where a product is designed to enable a claim to be made to satisfy a consumer group, e.g. a nutritional claim of reduced sugar, the company ensures that the product formulation and production process is fully validated to meet the stated claim. 5.1.8 The product design/development process is documented and effectively communi cated throughout the organisation, to ensure that changes in formulation are adequately assessed for safety and legality. 5.2 Handling Requirements for Specific Materials – Materials Containing Allergens and Identity-preserved Materials Where raw materials and finished products require special procedures for handling specific materials (e.g. material containing allergens or the requirement for identity-preserved status such as Genetically Modified Organisms, assured organic status or special designated origin) these are in place to ensure that product safety, legality and quality are maintained. 5.2.1 Material Containing Allergens 5.2.1.1 The company has carry out risk assessment of raw materials to establish the presence and likelihood of contamination by allergens including approval of raw material specifications. The company has systems to specify the integrity of the raw material and compliance with specification throughout the purchasing and supply chain. 5.2.1.2 The company shall identify and list allergen-containing materials handled on site. This shall include raw materials, intermediate and finished products. Presently, no genetically modified raw materials containing raw materials are used. If legal requirements warrant additional controls, like declaration, then it will be established. 5.2.1.3 Risk assessment are carried out to identify routes of contamination and establish documented policies and procedures for handling raw materials, intermediate and finished products to ensure cross contamination is avoided. This includes: • physical or time segregation while allergen containing materials are being stored, processed or packed • use of identified, dedicated equipment for processing or cleaning • all food brought onto site including that by staff. 5.2.1.4 Where rework is used, or reworking operations carried out, procedures are implemented to minimise cross contamination from allergen-containing materials and ensure the safety, legality and quality of the finished product. 5.2.1.5 Where a claim is made regarding the suitability of a food for allergy or food sensitivity sufferers, the company ensures that the production process is fully validated to meet the stated claim. 5.2.1.6 Based on risk assessment, documented equipment or area cleaning procedures are undertaken to remove or reduce to acceptable levels any potential cross contamination in compliance with finished product specifications. 5.2.1.7 All relevant personnel, including temporary staff and contractors, are appropriately trained in allergen handling procedures prior to commencing work and are adequately supervised throughout the working period. 5.2.1.8 Any non-conformities relating to allergen control are included in the management review process and may include, as appropriate, internal or external incidents and customer complaints such as labelling or cross-packing errors. The review process also considers updates or changes in allergen legislation or scientific information. 5.2.2 Identity-preserved Materials 5.2.2.1 Where identity preserved claim is made and products brought onto site require segregation, the company carry out a risk assessment of raw materials to specify the integrity of the raw material and compliance with specification throughout the purchasing and supply chain. 5.2.2.2 Risk assessment are carried out to identify routes of contamination and establish documented policies and procedures for handling raw materials, intermediate and finished products to ensure cross contamination is avoided and that controls are in place to maintain identity preserved status. 5.3 Foreign Body Detection The company shall have appropriate foreign body detection equipment in place and ensure its effective operation. 5.3.1 Foreign body detection equipment shall be in place unless it can be justified as not necessary. This justification shall be documented. Detection equipment shall be situated to maximise foreign body detection within the finished product. 5.3.2 The sensitivity of detection shall be specified and best practice applied with regard to the nature of the food, the location of the detector and any other factors influencing the sensitivity of the detector. 5.3.3 The metal detector shall incorporate the following based on best practice: an alarm on a belt stop system an automatic rejection device which shall either divert contaminated product out of the product flow or to a secure unit accessible only to authorised personnel in-line detectors which identify the location of the contaminant and effectively segregate the affected product. There shall be documented procedures specifying corrective and investigative action to be taken in the event of the detection of metal or a foreign body. 5.3.4 The company shall establish and implement procedures for the operation, routine monitoring, testing and calibration of the metal or other foreign body detectors. This shall include: frequency and sensitivity of checks authorisation of trained personnel to carry out specified tasks documentation of checks 5.3.5 The company shall establish and implement corrective action and reporting procedures in the event of the monitoring and testing procedure identifying any failure of the metal or foreign body detector. Action shall include a combination of isolation, quarantining and re-inspection of all product produced since the last acceptance test of the metal or other foreign body detector. 5.4 Product Packaging Product packaging is appropriate for the intended use and stored under conditions to minimise contamination and deterioration. 5.4.1 Certificates of conformity are available for product packaging to confirm its suitability for use. 5.4.2 To avoid cross contamination, Packaging is stored away from raw materials and finished product. 5.4.3 Any part-used packaging materials suitable for are effectively protected before being returned to an appropriate storage area. Defective packing materials are returned to main packing store for returning to the supplier / scrapping. 5.4.4 Product contact liners (or raw material/work-in progress contact liners) if used, are appropriately coloured and of sufficient gauge to prevent accidental contamination where appropriate. 5.4.5 Presently packaging materials do not pose a product safety risk. If required, special handling procedures are in place to prevent product contamination. 5.5 Product Inspection and Laboratory Testing The company carries out own product inspection and analyses which are critical to confirm product safety, legality and quality, using appropriate procedures, facilities and standards which prevent risk to product safety. 5.5.1 Product Inspection 5.5.1.1 Based on risk assessment, testing and inspection schedules are established to ensure specified product requirements are met. Inspection and testing methods and frequency are documented. 5.5.1.2 Test and inspection results are recorded and reviewed regularly to identify trends. Appropriate actions are implemented promptly to address any unsatisfactory results or where trends indicate unsatisfactory results. 5.5.1.3 Where validation of finished product quality attributes is required, organoleptic tests are carried out regularly in accordance with specifications and recorded. 5.5.1.4 The company ensures that a system of ongoing shelf life assessment is in place. This based on risk and includes microbiological and sensory analysis as well as relevant chemical factors such as pH and aw. Records and results from shelf life tests validate the minimum shelf life period indicated on the product. 5.5.2 Laboratory Testing 5.5.2.1 When such activity is carried out in house, the laboratory facility shall be located remote from the manufacturing site. 5.5.2.2 Routine testing laboratories are present on a manufacturing site. The laboratory is located, designed and operated to eliminate potential risks to product safety. Controls are documented, implemented and include consideration of the following • design and operation of drainage and ventilation systems • access and security of the facility • movement of laboratory personnel • protective clothing arrangements • processes for obtaining product samples • disposal of laboratory waste. 5.5.2.3 Where tests, which are critical to product safety or legality, are carried out at the out side laboratory, or subcontractors, then their control and recognition in accordance with the requirements and principles of ISO 17025 are acertained. 5.5.2.4 The reliability of the lab results are cross checked at least once a year by testing in other laboratories. This includes: • documented testing procedures 5.6 • ensuring staff are suitably qualified and/or trained and competent to carry out the analysis required • use of a system to verify the accuracy of test results, e.g. ring or proficiency testing • use of appropriately calibrated and maintained equipment. Control of Non conforming Product The company ensures all out-of-specification product is clearly identified, labelled and quarantined. 5.6.1 Procedures for the control of non-conforming material, indicates the controls adopted, including rejection, acceptance by concession, or regrading for an alternative use. The details are communicated to all concerned and authorized personnel to ensure that they are aware of the requirements. 5.6.2 Corrective actions are implemented to avoid recurrence of non-conformance and adequate records are kept on the action taken. 5.6.3 All non-conforming material are clearly identified and quarantined as appropriate, and handled or disposed of according to the nature of the problem and/or the specific requirements of the customer. 5.7 Product Release The company ensures that finished product is not released unless all agreed procedures have been followed. 5.7.1 A procedure are in place, based on risk assessment, to ensure that only products conforming to specification are dispatched and released by authorised staff. Section 6: Process Control The company demonstrate effective control of all operations undertaken. 6.1 Control of Operations The company follows validation procedures to verify that the processes and equipment employed are capable of producing consistently safe and legal product with the desired quality characteristics, in full compliance with the HACCP food safety plan 6.1.1 All Critical Control Points and specified limits identified through HACCP are transferred into day-to-day production controls and are fully validated. 6.1.2 Process monitoring such as temperature, time, pressure and chemical properties are established and adequately controlled to ensure that product is produced within the required process specification. 6.1.3 Process monitoring are carried out by trained staff and documented. 6.1.4 In circumstances where process parameters are controlled by in-line monitoring devices, it is ensured these are linked to a suitable failure alert system that is routinely tested. 6.1.5 In the case of equipment failure or deviation of the process from specification, procedures are in place to establish the safety status of the product, prior to release. 6.1.6 Corrective action are taken in the event of deviation of process from specification and recorded. 6.1.7 Procedures are in place to ensure that products are packed into the correct packaging and correctly labelled with due consideration given to product changeover. 6.1.8 In the event of changes to product formulation, processing methods, equipment or packaging, monitoring of the specified process are re-established based on HACCP. 6.2 Quantity – Weight, Volume and Number Control The company operates a quantity control system which conforms to legal requirements and additional industry sector codes or specified customer requirement in the country where the product is sold. 6.2.1 The frequency and methodology of quantity checking meet the requirements of appropriate legislation governing quantity verification. 6.2.2 Where the quantity of the product is not governed by legislative requirements (e.g. bulk quantity), the product must conform to customer requirements. 6.3 Calibration and Control of Measuring and Monitoring Devices Measuring equipment used to monitor CCPs and product safety and legality are identified. The identified measuring equipment are calibrated to a recognised national or international standard. Where a traceable calibration is not possible, the company will demonstrate the basis by which standardisation is carried out. 6.3.1 6.3.2 6.3.3 6.3.4 The company has identified measuring equipment used to monitor CCPs and product safety and legality.This shall include: • a documented list of equipment • equipment identified and marked in accordance with requirements (e.g. numbered, calibration due date). All identified measuring devices are checked and where necessary adjusted: • at a predetermined frequency, based on risk assessment • by trained staff • to a defined method traceable to a recognised national or international standard where possible. The prescribed measuring and monitoring devices are: • prevented from adjustment by unauthorised staff • protected from damage, deterioration or misuse. Procedures are in place to record actions taken when the prescribed measuring and monitoring devices are found not to be operating within specified limits. Section 7: Personnel 7.1 Training – Raw Material Handling, Preparation, Processing, Packing and Storage Areas The company ensures that personnel performing work that affects product safety, legality and quality are demonstrably competent to carry out their activity, through training, work experience or qualification. 7.1.1 All relevant personnel, including temporary staff and contractors, are appropriately trained prior to commencing work and adequately supervised throughout the working period. 7.1.2 Where personnel are engaged in activities relating to Critical Control Points, relevant training and documented monitoring procedures are in place. 7.1.3 The company has documented programmes covering the training needs of relevant personnel. These include: 7.1.4 7.1.5 • identifying the necessary competencies for specific roles • providing training or other action to ensure staff have the necessary competencies • reviewing and auditing the implementation and effectiveness of training and competency of the trainer • consideration of the delivery of training in the appropriate language of trainees. Records of all training are available. This includes: • name of trainee and confirmation of attendance • date and duration of training • title or course contents as appropriate • training provider. The company are routinely reviewed for the competencies of staff and provide relevant training as appropriate. This may be in the form of training, refresher training, coaching, mentoring or on-the-job experience. 7.2 Access and Movement of Personnel The company ensures that access and movement of personnel, visitors and contractors shall not compromise product safety. 7.2.1 Plant layout defines access points for personnel, travel routes and staff facilities. 7.2.2 If required, to allow access through production areas, designated walkways will be provided that ensure there is adequate segregation from materials. 7.2.3 All facilities are designed and positioned, where possible, so that movement of personnel is by simple, logical routes. 7.2.4 Contractors and visitors, including drivers, are made aware of all procedures for access to premises and the requirements of the areas they are visiting, with special reference to hazards and potential product contamination. 7.3 Personal Hygiene – Raw Materials Handling, Preparation, Processing, Packing and Storage Areas The company’s personal hygiene standards are documented and adopted by all personnel, including contractors and visitors to the production facility. These standards are formulated with due regard to risk of product contamination. 7.3.1 The requirements for personal hygiene are documented and communicated to all personnel. Compliance with the requirements are checked regularly. 7.3.2 Based on risk assessment, the company has documented its jewellery policy. 7.3.3 Watches are not worn. Jewellery are not worn, with the exception of a plain wedding ring, a wedding wristband and sleeper earrings (continuous loop). Rings and studs in exposed parts of the body, such as noses, tongues and eyebrows, are not to be worn. 7.3.4 Hand cleaning is performed at a frequency that is appropriate, based on risk assessment. 7.3.5 Fingernails are kept short, clean and unvarnished. False fingernailsare not permitted. Where visitors cannot comply, suitable control procedures are in place, e.g. non-handling of product, use of gloves. 7.3.6 Excessive perfume or aftershave not worn. 7.3.7 Smoking (where permitted under law), eating and drinking is permitted in designated areas segregated from food-handling and storage areas. 7.3.8 All cuts and grazes on exposed skin are covered by an appropriately coloured plaster different from the product colour and containing a metal detectable strip where metal detection/X-ray equipment is in use. At present, metal detectable strips are not used but in addition to the regular plaster, a finger stall is worn. 7.3.9 At present, metal detectable strips are not used. 7.3.10 Procedures are in place to control the use of personal medicines to minimise the risk of contamination. 7.4 Medical Screening The company ensures that medical screening procedures are in place for all employees, contractors or visitors who will be working in or visiting areas where product safety could be compromised. 7.4.1 The company have a procedure for the notification by employees, including temporary employees, of any relevant infections, disease or condition with which they may have been in contact or be suffering from. 7.4.2 Where there may be risk to product safety, visitors and contractors are required to complete a health questionnaire prior to entering the raw material, preparation, processing, packing and storage areas. Where appropriate, these persons shall undergo medical screening before permission is granted. 7.4.3 There shall be written and communicated procedures for employees, including temporary employees, contractors and visitors, on action to be taken in the case of infectious disease from which they may be suffering or have been in contact. Particular consideration should be given where product safety may be compromised. Expert medical advice shall be sought where required. 7.5 Protective Clothing – Employees or Visitors to Production Areas Suitable company issued protective clothing are provided to employees, contractors or visitors working in or entering production areas. 7.5.1 Based on risk assessment, the company has documented and communicated to all employees, contractors or visitors the rules regarding the wearing and changing of protective clothing in specified work areas, e.g. high-risk and low-risk areas. This includes policies for wearing of protective clothing away from the production environment, e.g. removal before entering toilets, use of canteen and smoking areas. 7.5.2 Protective clothing is made available: • provided in sufficient numbers for each employee • of suitable design to prevent contamination of the product 7.5.3 Clean and dirty clothing are segregated and controlled to prevent cross contamination. 7.5.4 Laundering of protective clothing is outsourced using defined and verified criteria to validate the effectiveness of the laundering process, or by an approved contracted and audited laundry. The effectiveness of cleaning is monitored. Washing of workwear by the employee is not allowed. 7.5.5 Where there is the risk of contamination, smoking and eating while wearing protective clothing is not be permitted. 7.5.6 All scalp hair are fully contained to prevent product contamination. 7.5.7 Based on risk assessment, snoods for beards and moustaches are worn to prevent product contamination. 7.5.8 Suitable footwear are worn within the production environment. 7.5.9 If gloves are used, they are replaced regularly. Gloves are suitable for food use; of a disposable type; of a distinctive colour intact, and do not shed loose fibres. 7.5.10 For operations involving high-risk products all visibly distinctive protective clothing (including footwear) are applied when entering, and removed when leaving, the high risk area and stored in a designated changing area. Section 8: Glossary of Terms BRC British Retail Consortium SOP Standard Operating Procedure FSP Food Safety Plan ANX Annexure FSTL Food Safety Team Leader PROD Production QA Quality Assurance WI Work Instructions GMO Genetically Modified Organisms CIP Cleaning In Process COM Commercial MKT Marketing PRP Pre-Requisition Programmes CCPs Critical Control Points