I am known to be impatient and I have done gap analysis between v6 and 7. Please help yourself to it. if any mistakes are found please let me know.
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Posted by ChocoTiger on 14 July 2015 - 08:37 PM
Here are generic examples of what is needed for 184.108.40.206-220.127.116.11, 18.104.22.168-22.214.171.124, 126.96.36.199, and 188.8.131.52-184.108.40.206. The programs I included in this are the prerequisite programs required by SQF.
Let me know if you need any additional help.
Posted by Wine Gum on 07 July 2015 - 07:22 AM
The PIGS diagram can be used to formulate hazards comprehensively:
P- presence (qualitative and/or quantitative evaluation of presence of hazards)
I-Introduction (Likely occurrence of hazards and severity of their adverse health effects)
G - Growth (Production or persistence of foods of toxins, chemicals or physical agents)
S- Survival (Survival or multiplication of micro-organisms of concern)
Hope this helps!
Posted by Charles.C on 30 April 2013 - 03:03 PM
I previously posted a table of various micro. guidelines for food contact surfaces which were mostly issued pre-2000 at this link –
To update the earlier info., the attached excel file presents guideline data I have accumulated for 12 countries issued in the period 2000 – 2012. The compilation demonstrates that for a range of food-related scenarios, some “average” opinions for various (just) cleaned surfaces are –
(a) For Aerobic Plate Count (APC) - the majority of data suggests that, for routine cleaning/sanitising, surfaces typically have maximum APC counts in the range 10-100cfu/cm2 .
(b) For factors like Coliform, (generic) E.coli, Enterobacteriaceae, S.aureus, the expected maxima are, predictably, low, eg 1-10 cfu/cm2, or undetected. The latter requirement also invariably applies for “zero-tolerance” pathogenic microbial species.
Hopefully of some interest. Further input / comments welcome as usual.
Compilation of International Micro. Guidelines for food contact surfaces, 2000 onwards.xls 993KB 2989 downloads
Rgds / Charles.C
Posted by mgourley on 21 December 2015 - 10:30 PM
A lot of us have spent many hours writing policy to make sure that what we do is the right thing to do.
A lot of us have made sure that senior management is aware of said policy, and they always have input into the final product. We may go so far as to include approved exceptions.
Once they approve, or give tacit approval, that document states what we do in a certain situation.
That policy, procedure, whatever, then governs how "all" people act when that particular situation arises.
After the fact is not the time for higher ups to decide that the policy does not need to be followed.
Make your objections known, CYA, and move on. You are exactly right. You do not want to set precedent. If you do, what's the point in this rule, or that policy?
Posted by trubertq on 16 July 2015 - 03:39 PM
Since Storage and distribution is not my area I don't feel qualified to answer however I'm sure some one on here can help him.
I'd imagine his customers are looking for verification that his goods haven't been tampered with or substituted, as well as trying to pass the buck of VACCP onto him.....
I'd suggest going to his suppliers and requesting THEIR VACCP risk assessment and then add in his steps in the chain with his risk assessment.
Posted by fgjuadi on 05 March 2015 - 08:41 PM
2.5.3 is your verification schedule, I use this for verification activities - Verify the metal detector is working every 30 minutes . Verify chemical concentration every morning via titration.
Internal audits go on 4.5.2 (Validation schedule)
To make it easier, I combine the 2.5.3 form with 2.5.1 (methods and responsibilities) and 2.5.4 (Verification of monitoring activities) . Basically it's a chart with each monitoring and verification activity, frequency, and responsibility.
So maybe the QA Manager checks the visitor log once a week, but they only conduct a food defense audit annually. The check goes on verification of monitoring, the audit goes on validation.
It can get very "fuzzy" as SQF does not dictate which activity is which. I attached copies of both if it will help - but don't be surprised if you get some different answers.
Posted by trubertq on 26 February 2015 - 03:57 PM
Make up a code of practice for them to sign , something simple not full of jargon, what you expect from them, what your Hygiene rules are etc.. I have attached a template
Posted by Simon on 07 January 2015 - 09:44 PM
Over the last couple of day's it has become clear to me that I have made an almighty cock-up on MOTM and caused Mr I a huge injustice.
Mr I received the most reputation points in December (by a distance), but I did not award him MOTM because I (mistakenly) thought that once a member had won MOTM they could not win it again. When I checked the rules yesterday I realised I was wrong and a member can win it once per calendar year. I thought that was just an unfortunate, but simple mistake I had made.
However, (to my horror) I have now realized that MR I has NEVER won MOTM...I would have put my mortgage on that he had previously won it. To make matters worse it is likely that in previous months Mr I has scored the highest reputation points and won MOTM and I have overlooked him.
The upshot is I have dealt Mr I a real injustice and I am totally at fault and I have passed on my sincere apologies. Thankfully Mr I has graciously accepted my apology.
For the record Mr I did not want me to publish this apology, but I want to because it is right to do so. We have some great members around here and Mr I is one of them.
To this end MR I is the first ever recipient of the annual Member of the Year award. Apart from the title there will be some sort of badge of honour, but I’m working on that…ideas?
Posted by Charles.C on 18 November 2014 - 06:42 PM
Thank you for the detailed reply. Much appreciated. I have expanded a little on some of the comments in yr post / links.
I looked at 2 viewpoints, SQF/BCAS, on some desirable Quality characteristics of Compressed Air -
Purity is defined in the SQF Code (Appendix 2: Glossary) and means the absence of contaminants that could cause a food safety hazard. Pure air means the air is free of risk of cross-contamination to the products. Essentially, the air must not contribute any contamination to the product.
Strictly, use of the word “contamination” as defined by SQF implies that micro.standards based solely on APC limits could be regarded as safety (ie haccp) meaningless. (In a cleanroom context the situation would likely be rather different, limits derived for sterile scenarios are in some articles recommended as not being arbitrarily transferred into the food scene without due caution).
Similarly to SQF, BCAS implicitly defines contaminants in its introduction via -
Contaminants that may be a potential hazard in food for human consumption
In the context of the BCAS COP, hazard is presumably interpreted as safety hazard. On this basis, some difficulties also arise IMO, eg -
"6.2 Microbiological contaminants.
HACCP shall establish the risk of contamination by microbiological contaminants. The level of viable microbiological contaminants in the compressed air shall not be detectable using the method described in clause 7.6." Clause 7.6 refers to ISO 8573-7 test method for viable microbiological contaminant content.
The word "detectable" suggests that any microbial species other than what is (somehow) defined as "natural" to the specific product have zero tolerance. This seems inconsistent with basic haccp principles. Unless a list of accepably non-hazardous species exists ?
This post primarily focuses on micro. “B” factors, the “C, P” hazards are well over-viewed in the SQF faq (see Excel file/sheet3 below) and the Code’s Guidance documents, eg for parts 2/11.
I have done a little background searching regarding standards, micro.species, filters, etc and pasted some selected extracts into the attached excel book (the earlier studies in this area seem a little neglected these days, maybe justifiably ) . Most of the content will probably be (only too) familiar to you of course.
The source files are attached below, keyed to the excel sheet numbers.
sh1 - microbiological air quality.pdf 489.76KB 531 downloads
sh4 - Compressed-Air-in-the-Food-and-Beverage-Industry.pdf 3.82MB 402 downloads
sh4.1 - food industry compressed air systems,white-paper.pdf 196.81KB 275 downloads
sh5 - compressed air in food plants,white paper,Parker Balston.pdf 522.15KB 265 downloads
sh6 - ECFF.pdf 402.26KB 279 downloads
sh7 - tesco standard 2014.pdf 1.15MB 337 downloads
sh8 - air filtration systems.pdf 193.62KB 287 downloads
Rgds / Charles
PS - Two/three of the above documents are already in the thread linked in post 2 above. I re-used them to allow some convenient integration.
The mystery (to me) of why SQF's faq (typically) refers to 0.1micron filters whereas the guidance document specifies 0.01 micron remains. Nonetheless, if the cost/maintenance/implementation factors are comparable (?), the latter seems a logical investment for an easy audit (also see sheet5 in Excel file). For current purposes i assumed the faq is more "maintained" than the guidance and "acted accordingly".
PPS - the extensive collection of TA documents available via Laura's links in previous post(s) are remarkable and valuable. Highly recommended for browsees.
P3S – for those interested here are 5 more links, the first two look at typical air sampling devices/procedures (mainly food/cleanroom respectively), the next 3 focus on micro.aspects/standards as applied in pharmaceutical, cleanroom, sterile work scenarios. The similarities to concepts used (borrowed?) in the food business is clear but there are also significant differences in emphasis, eg the interest in viable/non-viable particles.
Posted by cazyncymru on 23 October 2014 - 01:33 PM
Just released for draft consultation
Posted by cazyncymru on 09 June 2014 - 09:04 AM
I agree with Slab, yes I get paid more, but I don't just deal with Food Safety; under my umbrella comes Environment & Health & Safety!
Food Safety has changed so much in the last 14 years. I think its changed a lot in the last 5 years and if i'm honest, unfortunately (controversial statement coming), not all Quality Professionals have evolved along the way. Some times I see questions on here, and whilst we all have to start somewhere, I despair. I hold my head in my hands, wondering are they really serious or are they trolls! It does make me somewhat reluctant to respond to some post(ers). It would seem that some people are either unable to think for themselves or unwilling to! To be a quality professional you have to have at least a basic knowledge and I know it is difficult, but please if you haven't had a formal education in food safety, at least read a few books and try to learn something!
I think that we have now become more focussed in assessing risks with risk assessments becoming the backbone of a food safety system. As things have evolved, we are being asked to carry out more and more risk assessments; even if it doesn't truly affect our industry (I think Acrylamide!). Thing is, who's teaching people to do these risk assessments? And who taught them? their all subjective! as long as you can justify how you reached that conclusion, who's to say your right or wrong! In the latest version of the BRC, we are asked to carry out a vulnerability risk assessment. Now I work predominantly in Dairy, and I have interpreted this in risk assessing from the farm to the fork, so my study incorporates animal health as well as abuse by the customer. I'm lucky that in a previous life, I was involved in doing Farm Assurance, so I understand about what can potentially happen on the farm; but I bet I'm in the minority. We're asking quality professionals to assess something they may not have any idea about, and this is where mistakes can be made.
I also think we've become inundated with consultants. I probably get a request daily from either a consultant or a recruiter on LinkedIn!! If I need help I will ask, and if I want a new job, I'm sure I can find one myself! ( I've never used an agency to find a job)
So, those are my thoughts, I'm sure many will disagree.
Posted by CLEMENT GRIFFITHS on 01 October 2015 - 12:18 AM
Brian is correct but he is losing a bit of clarity in his articulation. Bottom line is your incident clearly fits the second part of his statement , you have physical evidence of rodent activity and now the responsibility is on you to formulate your response so that you can make a powerful business case. Don't do quality control without making the business case, lay out the risk to the business and why they should support you and don't be guilty of making a "knee jerk reaction"
You should do a food safety risk assessment and much of the information you needs is captured in the treads associated with this post, then you need to reach a conclusion and issue the appropriate disposition.
I am back in the private sector but for the prior 3.5 years I have audited against ISO22000:2005, SQF and ISO 9001:2008 and in my opening meetings I always reminded management that for a QMS or FSMS the Food Safety Team Leader, SQF practitioner or BRC champion rules as King ( or Queen as the case may be). Its your "hill" defend it , it is your right and responsibility to explain to, coach and educate management as to why the disposition needs to be what it is. They have to get to trust you it takes time.
In Brian's scenario seeing a mouse running down the pack of an aisle among food ingredients would not be objective evidence of contamination or infestation; however finding a bag with the tell tale signs of rodent activity and maybe finding mouse droppings is objective evidence of a food safety risk and you should first move to "correction" which for me means a 100 inspection of the bags of concern and a removal and discarding of any and all affected bags, second, quickly get a non conformance issued and contact the pest control provider to start the process of containment and eradication. At the same tie do your root cause and identify the appropriate corrective action measures needed to avoid a recurrence.
Finally you need a safe way of reminding that upper management that the FSMS is driven my management commitment, skimming the bag and using what may appear to be the good fraction ( if I am understanding you correctly) is not an example of good management commitment nor is it sound food science.
My personal strategy is to issue non conformance's proactively in other words if the FSMS takes a hit I do not wait for the auditor I flag it and then deal with it as an audit finding. This means that in your case if this situation was repeated I would make a finding against management commitment. Seems risky but the truth is upper management also likes to know that they have competent technical support , that you are not afraid to make your case and hold your ground.
Hope this helps
Posted by trubertq on 10 September 2015 - 01:49 PM
OK , the standard says that you agree the scope with the CB before the audit, this is usually settled during a pre-audit and then they just ask each year if you want to change the scope. I know from experience that they are none too keen on exclusions for the obvious reason that they don't want people getting one product certified and then claiming certification for everything produced on a site. However, the company I work with HAVE exclusions but there are definite criteria and I quote:
" the excluded products can be clearly differentiated from products within the scope"
"the products are produced in a physically segregated area of the factory"
it further says:
The certification of products must include audit of the entire process from raw material to end-product dispatch. It is not possible to exclude either parts of the process undertaken at the site OR parts of the standard.
So ...if your bottling line is in a separate part of the site segregated from the bulk area then you should have no problem.....you could always risk assess the requirements for a end of line metal detection ( I think this what you meant bu 'end of line detection') and show that it isn't necessary if that's all that's holding you back from having the smaller packs in the scope.
The absolute best people to speak to about this are the Certification body... I don't know what your plant looks like but this is based on my experience in a site which has exclusions.
Posted by trubertq on 16 July 2015 - 02:24 PM
EU legislation requires allergen awareness as part of food handler training.
From the Food Standard Authority of Ireland website: "It is a legal requirement that staff who are involved in a food environment are trained and/or supervised commensurate with their work activity. The responsibility for the supervision and training of staff lies with the proprietor of the food business."
Allergen awareness comes in under hazards. Go to the fsai website they have lots of good information there on training.
Posted by gfdoucette07 on 10 June 2015 - 02:19 PM
Good day, Whitney
Here is the info I put forth for HACCP in my new hire program, for my annual training I use a combination of plant specific CCPs their limits, frequecy checks, and what to do ifs, plus a video from the "refridgerated foods corporation of america". I have also included the quiz that came with the video. The slides arent too deep but for a new hire its a good start with our pre requiste programs.
Posted by Avila on 17 October 2014 - 06:10 AM
I prefer not to offer a cup of coffee after lunch break as it will give fresh energy and concentration to ask many questions. A bottle of mineral water would be fine
Posted by Ekivlen on 26 August 2014 - 03:06 PM
Overall I'd make it very clear that you're most familiar with your process and have no issue adding a customer required CCP but that it is your plan and your goal is to produce the safest product possible and taking controls out from the food safety plan could potentially risk your product.
I couldn't agree more.
Unless this customer is going to take sole ownership of the facility, I would not surrender that control. I would "take their advice and consider it at our next HACCP meeting," but to immediately say "OK" wouldn't be advisable. Am I reading this correctly that the customer is requesting this before the audit has even taken place? Their argument holds no merit. Come, sit down, talk to me, learn the process, ask some questions, and then we'll endeavor HACCP revisions. Until then, I'd dig my heels in (Sounds really emphatic, but just as a principle). I generally find that when one change is made in haste, it causes nothing but a snowball effect.
I recently had a NYS Agriculture and Markets audit and had to deal with foot stomping that certain stages "need" to be CCP's. Mind you, this was approximately three minutes into the audit. We hadn't set foot on the floor. Eventually, common sense prevailed and the hazards were understood as controlled through pre-requisite programs. Easy-peasy. .
Your HACCP plan is just that, YOUR HACCP plan. In the end, with your customer, if YOU determine that it is a CCP, then make the adjustment. If the shoe fits, wear it.
Posted by Simon on 20 December 2013 - 07:12 PM
Here you go Merle...have fun.
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