In Edition 6, 4.4.2.4 specifically refers to the pre-requisites outlined in Section 6. However in Edition 7, 2.4.2.2 refers to the "modules" in 3-15 and 2.4.2.3 refers to "applicable pre-requisites". Are the applicable modules considered the pre-requisites? Or are we left to pick and choose which pre-requisite programs we feel are in need of a validation/verification and which are code requirements that only require verification?
Thanks,
Jason
This is the most confusing part (to me at least) of the change from V6 to V7. The way I understand it is that The Module numbers are based on food sector categories (for example Mod. 11 is for food processing and manufacturing facilities) and combine V6's Section 5 (Food Safety Fundamentals - Building and Equipment Design and Construction) and Section 6 (Food Safety Fundamentals - Pre-requisite Programs). It does make some sense in that quite a bit of Section 5 in V6 is really Pre-requisite program stuff. Both are Food Safety Fundamentals.
I think what they're saying is that whichever Module your comany's food sector categor fits into you need to go through that Module and determine which Pre-requisites apply to your companie's
food safety management system, and if they don't apply you need to have a risk analysis to show why they don't apply. The way I understand it, validation and verification is the same as V6; you need to have both for any Pre-requisite Programs that apply to your
FSMS.
I'm going through V7's Module 11 page by page and cross referencing each code number with the corresponding code number in V6 (and taking a lot of aspirin in the process). To me it looks like an almost complete rewrite of my current Pre-req. program will be necessary in order to make sense out of anything (to me
and the auditor!).
I hope this makes some sense. I will say that I'm really looking forward to a new V7 Guidance document!