Louise Manning, PhD
 Legislation
 Due
diligence defence
 Validation
 Monitoring
 Verification
 The role of the audit
Main responsibilities:
 Ensure
you do not treat a food in any way
which means it would be damaging to the
health of people eating it;
 Ensure
food sold is of the nature, substance
or quality which consumers would expect;
 Ensure
that the food is labelled, advertised
and presented in a way that is not false or
misleading.
 Legal
defence designed to balance the
protection of the consumer against the right
of food businesses not to be convicted of an
offence they have taken all reasonable care
to avoid committing.
“took all reasonable
precautions and exercised
all due diligence”
 Defence
of due diligence also applies to
offences under the General Food
Regulations 2004 and the Food Hygiene
Regulations 2006.
Own label
Branded
product
Offence was someone else’s fault (not
under retailer's control) or resulted from
their relying on information supplied by
that person;
Yes
Yes
they had no reason to suspect that they
were committing an offence; and
Yes
Yes
they made reasonable checks on the food
or reasonably relied on checks made by
the supplier;
Yes
No
Not required
PREVENTION
 Assurance
CONTROL
 Detection
Quality Management System
Total Food Safety
HACCP
Pre-requisite Programmes
HACCP Study
HACCP Plan
HACCP Team
Training and Awareness
Commitment
Hygiene
SQA
GMP
SPC
Complaints Management Sanitation
Crisis/Incident/Recall
Pest Control
Preventative Maintenance
SQA – Supplier Quality Assurance
SPC – Statistical Process Control
GMP – Good Manufacturing Practice
Food safety within a quality management programme (Mortimore,
2001)
 Validation
 Monitoring
 Verification
 Validation
is the activities undertaken to
demonstrate that the scientific and
technical content of the food safety
(HACCP) plan is designed to be and
continues to be effective in minimising
food safety risk.
 Product
development
 Product and process changes
 Routinely to identify “shift” or variability
which will impact on the effectiveness of
control measures
 System failure
 New scientific or regulatory information
 Monitoring
is the act of conducting a planned
sequence of observations or measurements of
control parameters to assess whether a CCP is
under control
 Verification
is the application of methods,
procedures, tests and other evaluations, in
addition to monitoring to determine
compliance with the HACCP plan
(CAC, 2003).
 Review
of the FSMS, PRP, HACCP plan
and associated records;
 Review of deviations and product
dispositions; and
 Confirming that CCPs are kept under
control and that critical limits have not
been exceeded .
System
audit
Compliance
Internal
External
audit
Third
Investigative
audit
party
(intrinsic)
 Objective
evidence i.e. qualitative or
quantitative information, records or
statements of fact pertaining to the safety
of a product or process or to the
existence and implementation of a FSMS
element, which is based on observation,
measurement or test and which can be
verified
(adapted from ISO 10011:1 1990)
 Valid,
 Auditors
 Authentic,
 Current; and
 Sufficient
.
must also
be able to
demonstrate their
food safety
knowledge and
their technical
competence and
their skills
 Obtain
objective
evidence that the
FSMS and HACCP
plan and PRP are
appropriate,
implemented and
effective through the
collation of data,
observation and test.
 Systematic
analysis of
process, product and
organisational
performance in
meeting food safety
objectives
 Legislation
 Due
diligence defence
 Validation
 Monitoring
 Verification
 The role of the audit
 Louise
 Email
Manning PhD, MIFST, NSc, PGCHE
l.manning@btinternet.com