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Must the HACCP Team Leader be a permanent member of staff?


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#1 vecdika

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Posted 20 April 2010 - 03:18 PM

Dear Friends,

In regard to article 5.5 of ISO 22000:2005 team leader ought to be assigned by the management. He/she represent the management. On the other hand, At new standart of Iso 9001:2008 It’s new obligation is “The Management assign the representative of the managment in it’s sources depend on the Article 5.5.2.”

For small business, one person can be represent the HACCP team in regard to CAC (Codex…) HACCP 7 prensiples and FAO HACCP implementation-guides.

ISO 22000: 2005 is reference the CAC Hygiene Standard issued in June 1997 and ISO 9000 series standards .

Now, Question is that;
Are all food business top managements who belong to the member countries of WTO, in the world who implement HACCP(CAC) or ISO 22000:2005 food safety systems. charged with the full employment or permenant staff of the representative of management to be assigned.? Or is it compulsory criteria? If it is, All goverments must be include this rule in it’s food law at least for small businesses, mustn’t it?

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Vecdi Karacaoğlu
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#2 GMO

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Posted 21 April 2010 - 07:07 AM

If I think I understand your question correctly, ISO standards are not legally binding anyway in the UK, I doubt they are elsewhere too. Also, and I can only speak for the UK here, the only requirement is a system based on HACCP principles. It doesn't have to be called "HACCP" nor have to follow every step as laid out by Codex.

In the UK as in many parts of the world, the major business which would struggle to implement HACCP as you would ideally want to would be catering. Very few caterers have HACCP qualifications and so because of that, the UK government has brought in a couple of schemes over the past few years to take HACCP and make it simple for caterers. This is a way in which, strictly speaking the HACCP "team leader" ie the person who designed the structure and approach isn't even part of the team let alone a member of staff! Also many small food manufactures buy in expertise as a contractor to get a system in place.

That all said, I suppose it depends on how you see the HACCP team leader. There is an argument that it doesn't have to be the person most trained in HACCP in the team, just the person who will ensure the resources and commitment is made available, so you could assign someone as part of your team as the HACCP Team Leader to own the process, but also have a "HACCP expert" who is not a permanent member of staff? Might be a way of getting round it but also avoiding the inevitable pitfall of contractors that no-one owns the plan as soon as they've left site!


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#3 vecdika

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Posted 21 April 2010 - 01:12 PM

Dear Friend,
In Turkey, Every food factory have responsible technical person who is responsible food safety and quality together with boss to comply with Turkish food law as an compulsory criteria. This goverment requirement has tried to change now. Together with your point of view, is it improvement to asign any person as voluntary instead of qualified person charged as compulsory? In quality systems, your view can be accepted but in food safety systems can it be? In EU,After the three big crissis which BSE, Dioxsin and Foot and mouth disease, EU Commission requirements is that “official veterinarians have assigned to slaughters as compulsory by goverments”. This is preventive measures for EU citizens to prevent them from hazards coming from animals. This is system for animal origin products. Also the same must be for other foods. Competancy and responsibility agains to third- persons is explained in ISO 9001:2008 Article 5.5.2 as responsible person is asigned based on its sources, isn’t it? It musn’t be differences between the Codex and ISO responsibilities and competancies.
Best Regards
Vecdi Karacaoğlu


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#4 Simon

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Posted 25 April 2010 - 09:07 AM

I would say no, but it is much better if the HACCP Team Leader is 'in-house'.

It may weel take some time working with outside support whilst getting relevant training and experience, but the goal should be to have an 'in house' HACCP Team Leader. Definitely.


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#5 vecdika

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Posted 30 April 2010 - 02:31 PM

Thanks Simon for your clear support.

Vecdi Karacaoğlu


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#6 Gourav

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Posted 16 May 2010 - 10:07 AM

Thanks Simon for your clear support.

Vecdi Karacaoğlu



Hi Vecdi,
As rightly pointed in one of the previous post ISO 22000:2005 takes reference from ISO 9000 series of standards.
In ISO 9000 series there is concept of Management representative (MR). In ISO 9001:2000 the MR is not required to be on the rolls of the organization.
In IOS 901:2008 (latest version) The MR has to be mandatorily on the rolls of the organization.

Now ISO 22000:2005 came when ISO 9001:2000 was still effective. And now ISO 9001:2008 is effective.
SO what ISO 22000:2005 requires - For Food Safety Team Leader to be on the rolls of the organization - Mandatory or Not.

May the forum please answer.

Thanks

Gourav
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#7 FSSM

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Posted 17 May 2010 - 06:29 PM

Hi Vecdi,
As rightly pointed in one of the previous post ISO 22000:2005 takes reference from ISO 9000 series of standards.
In ISO 9000 series there is concept of Management representative (MR). In ISO 9001:2000 the MR is not required to be on the rolls of the organization.
In IOS 901:2008 (latest version) The MR has to be mandatorily on the rolls of the organization.

Now ISO 22000:2005 came when ISO 9001:2000 was still effective. And now ISO 9001:2008 is effective.
SO what ISO 22000:2005 requires - For Food Safety Team Leader to be on the rolls of the organization - Mandatory or Not.

May the forum please answer.

Thanks

Gourav


Dear Gourav,

It is not mandatory.

Have you seen any paragraph in the standar that states it is?

But taking into account the responsibilities of the FSTL, it is quite complicated to have an external one, I think, but not impossible.

Regards,

FSSM
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#8 Abdul Qudoos

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Posted 18 May 2010 - 08:58 AM

I agree with GMO & Simon,

Anyone in the organization be the FSMS team leader if he trained for ISO 22000/HACCP awareness & auditor training,

i have seen few companies they keep consultants, the make yearly agreement/contract starts with documentation, implementation, nominating 1 person, to acquiring certification. they act as a mediator.


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#9 vecdika

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Posted 20 May 2010 - 08:49 AM

Dear Gourav,

ISO 22000 requires the food safety team leader to manage the work of the food safety team and ensure that the team members have relevant education and training. When we look at the comparison of ISO 9001 and 22000 which is Annex A of ISO 22000:2005 Standard at below;

ISO 9001 correspond to ISO 22000
5.5.2 Management representative 5.5 Food safety team leader .

This is the paragraph of standard which state the Food Safety Team Leader to be on the rolls of the organization as mandatory .
For small business can one person be food safety team ? and if it is, and you say it is easy and economical way to ensure the education of food safety to Anyone in the organization who will be the FSMS team and team leader . There is nothing to say. Okey?
Best Regards
Vecdi Karacaoğlu
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#10 LeanSixSigma

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Posted 16 July 2010 - 01:47 AM

It is straight forward: HACCP is preventive approach and ISO 22000 is voluntary requirements. It says what you are committing, just make sure it being done. It never says any things other than just to ensure the ability to maintained what has been committed and taking about the effectiveness of system in place. The major weakness of ISO 22000 is it just says, there is a Chapter HACCP in your Policy manual and audits what is written is followed or not. Unfortunately, it cannot judge, what has been written claiming as HACCP are meeting minimal criteria or not. Thus what I believe is, many company without having any valid HACCP plan also having this title just showing very basic generic HACCP plan stating in writing it is enough for that company. It says the team leader should have relevant education and training. But it does not says, what is relevant education mean? Grade 5 or Grade 8 or Certificate or Bachelor or PhD or DSc? What training means? One day class to understanding what HACCP stands for or 10 years training. It has so many grey area so, lot of possibility to mislead the business partner in quality capability.

It has nothing to do with full employment or permenant staff, however it is just looking commitment from top management to make the commitment valid. It does not mean the guy from always top management, but top management is expected to assign adequate authority and responsibility to monitor and ensure the system in place for the guy.


It is not compulsory criteria and please try to understand that food law are mandatory, ISO like stuff are voluntary. ISO is tool if you want you can use it. If you do not want, no one can say you you should have you. It is just a very basic standard, thus every where GFSI recognized standard being popular. Please note, above are my feelings what I have on it.

Narayan


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#11 Tony-C

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Posted 17 July 2010 - 03:13 AM

Hi Vecdi,
As rightly pointed in one of the previous post ISO 22000:2005 takes reference from ISO 9000 series of standards.
In ISO 9000 series there is concept of Management representative (MR). In ISO 9001:2000 the MR is not required to be on the rolls of the organization.
In IOS 901:2008 (latest version) The MR has to be mandatorily on the rolls of the organization.

Now ISO 22000:2005 came when ISO 9001:2000 was still effective. And now ISO 9001:2008 is effective.
SO what ISO 22000:2005 requires - For Food Safety Team Leader to be on the rolls of the organization - Mandatory or Not.

May the forum please answer.

Thanks

Gourav


It is not a requirement of the ISO 22000 standard for the Food Safety Team Leader to be a member of the management. However, it is difficult to see how an external person can fulfill this role:

ISO 22000:2005 Clause 5.5 Food safety team leaders role is:
to manage a food safety team (see 7.3.2) and organize its work,
to ensure relevant training and education of the food safety team members (see 6.2.1),
to ensure that the food safety management system is established, implemented, maintained and updated
to report to the organization's top management on the effectiveness and suitability of the food safety management system.

Perhaps the best explanation is this standard is 5 years old and any new revision will follow the path of ISO 9001:

ISO 9001:2008 Clause 5.5.2 Management representative - Top management shall appoint a member of the organization's management who shall have responsibility and authority.

So although an auditor would not be able to raise a non-conformance if the food safety team leader was not a member of the management but I feel that auditors would look for evidence that the role was not being adequately fulfilled if the food safety team leader was not a permanent employee. The key wording for me is "food safety team leader shall have the responsibility and authority" and it is difficult to see an external person having the necessary responsibility and authority although there may be odd exceptions.

Regards,

Tony

Edited by Tony-C, 17 July 2010 - 03:14 AM.

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#12 GMO

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Posted 18 July 2010 - 06:24 AM

I agree Tony Posted Image but I also think the food safety team leader does not necessarily need to be the HACCP expert on the team. When I did my level 4 HACCP at Campden, they in fact encouraged us to assign a production person as team leader even if they did not have as high level qualifications as us to ensure they had the management commitment to implement. After all, what ISO 22000 asks for from a food safety team leader are largely management skills and commitments to implement the HACCP system rather than specific knowledge.


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#13 Tony-C

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Posted 18 July 2010 - 11:41 AM

I agree Tony Posted Image but I also think the food safety team leader does not necessarily need to be the HACCP expert on the team. When I did my level 4 HACCP at Campden, they in fact encouraged us to assign a production person as team leader even if they did not have as high level qualifications as us to ensure they had the management commitment to implement. After all, what ISO 22000 asks for from a food safety team leader are largely management skills and commitments to implement the HACCP system rather than specific knowledge.


You may be right Posted Image Posted Image

I worked on production for 3 years managing 80 people a shift and found that management experience invaluable when having to manage large technical teams and trying to implement technical initiatives in the factory. As such I would prefer the Food Safety Team Leader to be expert and have management skills, although this is not always possible.

Kind regards,

Tony

Edited by Tony-C, 18 July 2010 - 11:42 AM.

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#14 GMO

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Posted 19 July 2010 - 10:52 AM

I also have production experience and think more techies should get their hands dirty and try the other side!


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#15 Simon

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Posted 20 July 2010 - 06:25 PM

You cannot outsource food safety.


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#16 Tony-C

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Posted 20 July 2010 - 08:26 PM

You cannot outsource food safety.


How true !
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#17 LeanSixSigma

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Posted 20 July 2010 - 09:08 PM

[For Food Safety Team Leader to be on the rolls of the organization - Mandatory or Not?]

Not.

However you must satisfy that top management commitment for that.

Here issue is if you want to satisfy ISO 22000. But you want to use it in company benefit, taking out side people will not help you to make your organization expert. To be very honest, as per Canadian CFIA "FSMS Manual", HACCP is also confidential / propritory plan of the company and is not auditable and will not asked to audit unless there will reasonable safety issues.

If you understand this issues, I believe why out side guy for your company is not expected for your sustainalble quality growth.


Narayan


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#18 Simon

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Posted 27 July 2010 - 08:34 PM

Here issue is if you want to satisfy ISO 22000. But you want to use it in company benefit, taking out side people will not help you to make your organization expert. To be very honest, as per Canadian CFIA "FSMS Manual", HACCP is also confidential / propritory plan of the company and is not auditable and will not asked to audit unless there will reasonable safety issues.

That's a new one for me Narayan, so HACCP manual does not have to be disclosed to customers or auditors? In practice is this possible?
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#19 GMO

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Posted 28 July 2010 - 06:43 AM

Might be the case in Canada but not in the UK (or at least not practicable in the UK). The EHO would not permit a site to open without visibility of a HACCP plan, customers would delist you and you would fail BRC!


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#20 vecdika

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Posted 28 July 2010 - 09:19 AM

Dear Sirs,

When we look at the articles of Iso 9001:2008 which about

6.2 Human Resources
6.2.1 Genel
Personnel performing work affecting conformity to product quality requirements shall be competent on the basis of appropriate education, training, skills and experience.
The revision above should not be viewed as a new requirement. Anyone performing, verifying, or managing work within the scope of the quality management system, including supporting services, can affect conformity to product requirements. A new Note has been added to 6.2.1 to explain this point.
NOTE: Conformity to product requirements may be affected directly or indirectly by personnel performing any task within the quality management system.

6.2.2 Competence, Training, and Awareness, and Training
a) determine the necessary competence for personnel performing work affecting conformity to product quality requirements,

All above explanation are reguirements for confirmity assesment of ISO 9001:2008 standard. On the other hand, in Turkey, New food law (5996 number) which was issued on the 13th June 2010. Safety team leader will be the member of the management and have at least four year university degree of food hygiene. It is compliance reguirements of food law which is support the requirments of ISO 9001:2008 standard completely. And now in Turkey, it will be very easy to implement of ISO 9001:2008 based HACCP systems. Turkey’s awareness is the only country in Europe now as SPS world supporting to TBT world Isn’t it?

Best Regards
Vecdi Karacaoğlu
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#21 vecdika

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Posted 28 July 2010 - 09:22 AM

Dear Sirs,

When we look at the articles of Iso 9001:2008 which about

6.2 Human Resources
6.2.1 Genel
Personnel performing work affecting conformity to product requirements shall be competent on the basis of appropriate education, training, skills and experience.
The revision above should not be viewed as a new requirement. Anyone performing, verifying, or managing work within the scope of the quality management system, including supporting services, can affect conformity to product requirements. A new Note has been added to 6.2.1 to explain this point.
NOTE: Conformity to product requirements may be affected directly or indirectly by personnel performing any task within the quality management system.

6.2.2 Competence, Training, and Awareness, and Training
a) determine the necessary competence for personnel performing work affecting conformity to product quality requirements,

All above explanation are reguirements for confirmity assesment of ISO 9001:2008 standard. On the other hand, in Turkey, New food law (5996 number) which was issued on the 13th June 2010. Safety team leader will be the member of the management and have at least four year university degree of food hygiene. It is compliance reguirements of food law which is support the requirments of ISO 9001:2008 standard completely. And now in Turkey, it will be very easy to implement of ISO 9001:2008 based HACCP systems. Turkey’s awareness is the only country in Europe now as SPS world supporting to TBT world Isn’t it?

Best Regards
Vecdi Karacaoğlu
www.nevgrup.com.tr


Edited by vecdika, 28 July 2010 - 09:29 AM.

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#22 Tony-C

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Posted 08 August 2010 - 02:40 AM

Dear Sirs,

When we look at the articles of Iso 9001:2008 which about

6.2 Human Resources
6.2.1 Genel
Personnel performing work affecting conformity to product quality requirements shall be competent on the basis of appropriate education, training, skills and experience.
The revision above should not be viewed as a new requirement. Anyone performing, verifying, or managing work within the scope of the quality management system, including supporting services, can affect conformity to product requirements. A new Note has been added to 6.2.1 to explain this point.
NOTE: Conformity to product requirements may be affected directly or indirectly by personnel performing any task within the quality management system.

6.2.2 Competence, Training, and Awareness, and Training
a) determine the necessary competence for personnel performing work affecting conformity to product quality requirements,

All above explanation are reguirements for confirmity assesment of ISO 9001:2008 standard. On the other hand, in Turkey, New food law (5996 number) which was issued on the 13th June 2010. Safety team leader will be the member of the management and have at least four year university degree of food hygiene. It is compliance reguirements of food law which is support the requirments of ISO 9001:2008 standard completely. And now in Turkey, it will be very easy to implement of ISO 9001:2008 based HACCP systems. Turkey’s awareness is the only country in Europe now as SPS world supporting to TBT world Isn’t it?

Best Regards
Vecdi Karacaoğlu
nevgrup.com.tr


Thank you for your comments Vecdi but this forum is about ISO 22000 (Requirements for Food Safety Management Systems) so the ISO 9001 standard (Requirements for Quality Management Systems) is not so relevant here other than ISO 9001 requires the Management Representative to be a member of the organisation whereas ISO 22000 does not state that the Food Safety Team Leader needs to be a member of the organisation.

INTERNATIONAL STANDARD ISO 9001 Fourth edition 2008 Quality management systems - Requirements

5.5.2 Management representative
Top management shall appoint a member of the organization's management

INTERNATIONAL STANDARD ISO 22000:2005 Food safety management systems - Requirements 'for any organization in the food chain

5.5 Food safety team leader
Top management shall appoint a food safety team leader who, irrespective of other responsibilities, shall have responsibility and authority


Interesting what you say about the law in Turkey. So are you saying that by law the food safety team leader for a hotel or catering outlet needs to have a four year university food hygiene degree? Posted Image

Regards,

Tony
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#23 Charles Chew

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Posted 08 August 2010 - 10:06 AM

Thank you for your comments Vecdi but this forum is about ISO 22000 (Requirements for Food Safety Management Systems) so the ISO 9001 standard (Requirements for Quality Management Systems) is not so relevant here other than ISO 9001 requires the Management Representative to be a member of the organisation whereas ISO 22000 does not state that the Food Safety Team Leader needs to be a member of the organisation.

INTERNATIONAL STANDARD ISO 9001 Fourth edition 2008 Quality management systems - Requirements

INTERNATIONAL STANDARD ISO 22000:2005 Food safety management systems - Requirements 'for any organization in the food chain


Interesting what you say about the law in Turkey. So are you saying that by law the food safety team leader for a hotel or catering outlet needs to have a four year university food hygiene degree? Posted Image

Regards,

Tony


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#24 Charles Chew

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Posted 08 August 2010 - 10:12 AM

All above explanation are reguirements for confirmity assesment of ISO 9001:2008 standard. On the other hand, in Turkey, New food law (5996 number) which was issued on the 13th June 2010. Safety team leader will be the member of the management and have at least four year university degree of food hygiene. It is compliance reguirements of food law


Regardless, since the food law states so, this automatically becomes a regulatory requirement. Frankly, whether it applies to ISO9001 /or ISO22000, I am not sure whether this law is practical / pragmatic for the smaller food community to comply. It does seem inhibitive and a four-year university degree holder of food hygiene may not necessary have the competency / experience to manage a food safety system.

Regards
Charles
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#25 vecdika

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Posted 09 August 2010 - 10:43 AM

Dear Charles,

You say that you were not sure if it was practical for small business”, you are right , Turkish food law requirement is compulsary criteria only for food businesses that have at least ten workers or at least 10 HP working capacity. Restaurants are not include but the factories are include. For small businesses , it can be convenient to assign officials like EU official veterinerian assigned to meat businesses

ISO 22000 does not state that the Food Safety Team Leader needs to be a member of the organisation. But in the future it can be.

Best regards
Vecdi Karacaoğlu
www.nevgrup.com


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