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What does the inspector expect to see in a Written Policy?


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#1 paconmatt

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Posted 29 April 2014 - 10:24 PM

I have been asked to be a food safety coordinator and creator and I have no prior experience.  My company makes food contact packaging but we handle no food products and we are trying to pass our first AIB audit and inspection.  Here is my question:  What do the inspector expect to see in a Written Policy?  Can I simply state that our goal is to make clean, sanitary, unadulterated product?  Or do I have to get into a bunch of legal stuff such as the Food Modernization Act of 2011.  In the consolidated standards it talks about producing safe and legal foods but all we do is manufacture food contact packaging.


Edited by Charles.C, 05 May 2014 - 11:12 PM.
moved aib forum

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#2 imadoughguy

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Posted 30 April 2014 - 03:24 AM

paconmatt,

I'm not sure if i should offer congratulations or condolences on your new job responsibilities. LOL :-)

A written policy should state several things, depending on what part of the food safety plan you are addressing. Are you talking about your Quality Statement or is it your policy on Food Safety?

For AIB you will need 20 or so "Written Policies" addressing everything from start (specification policy) to finish (distribution policy).

You can download the AIB Consolidated Standards and pretty much figure it out from that. If I recall the standard spells out pretty plainly what policies and records you need.

Best of Luck on your journey. Remember... you are getting paid to learn right now. :-)

Phil


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#3 Charles.C

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Posted 30 April 2014 - 07:51 AM

Dear paconmatt,
 

 

What do the inspector expect to see in a Written Policy?

 

i wouldn't know about AIB but you can see some general opinions/links here (mixed in with specific contexts) -

 

http://www.ifsqn.com...licy/#entry6063

 

http://www.ifsqn.com...ies/#entry41268

 

http://www.ifsqn.com...492/#entry58971

 

Rgds / Charles.C

 

PS-added - I agree with you about the (food oriented) text in the packaging standard. Urgently needs some editing. Not exactly encouraging as to the value of the standard.


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Kind Regards,

 

Charles.C


#4 Mr. Incognito

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Posted 30 April 2014 - 01:40 PM

AIB is pretty much just a GMP/PRP audit.

 

They are going to want to see things written up like cleaning and sanitation, pest control, infrastructure (hygienic design and maintenance of your structure), Shipping procedure (checking the container your sending your packaging in to make sure it's clean and not damaged)... things like that.

 

You'll need procedures, a cleaning schedule with signoffs when things are cleaned... etc.


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#5 Pizza&Sandwich

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Posted 30 April 2014 - 02:45 PM

Follow the AIB standard and write your policies using the same jargon that AIB uses. This was one thing that our AIB inspector told us. Use the standard to write your policies and procedures. AIB is very prescriptive: they tell you exactly what you have to do. Also keep in mind that if you cannot do something (our plant could not maintain the 18" rule behind our warehouse racks), use an alternative: we have painted white strip to show the cleanliness and any evidence of pests & the area is on a cleaning list.


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#6 Charles.C

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Posted 30 April 2014 - 03:17 PM

Dear All,

 

I'm sure the OP would love an example from actual users. A procedure tells a ......... :smile:

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C


#7 Taste Maker

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Posted 30 April 2014 - 09:57 PM

The auditor wants to know that he can trust you to produce a safe-legal product. One of the ways is to "audit" your programs and policies to see if they include the necessary guidance from the prerequisite and food safety programs to show that you have applied the standards to your unique facility. Whether you are following them or not, he needs to know that you can at least explain by policy and program that you in fact, know what to do. For example, the standard for inspection may state that you shall have an allergen control program. So, you would first state in a paragraph or two a brief discussion (rationale) of who, what, when and how the program will be handled (policy). Then, list in detail how the program will be conducted from arrival on truck to storage to handling to labeling. You may refer to the Consolidated Standards to be sure you are covering everything. We just scored 965 on our last audit in a 75 year old building. It would also to have a policy stating that you are constantly improving your understanding of food safety by attending AIB workshops or online courses. There are 5 catagories, go thru each one and see what needs improving and what is good. A good QA Manager puts programs in place to "guarantee a safe product to the end consumer".

 

Taste Maker

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#8 Charles.C

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Posted 01 May 2014 - 12:50 AM

Dear Taste Maker,

 

Thks yr input.

 

I don't disagree with yr suggestion (particularly due unfamiliar with AIB) but as illustrated in other threads here, the expectation of content in a "policy" can generally vary from exceedingly short/concise to an extended monolog. It may relate to the specific Policy also IMO.

 

It can semantically be a question of interpretative differences between Policy, Procedure, Work Instruction, etc. Just like in ISO and equally subjective. For example, some "Policies" contain essentially no procedural details at all, eg the first sentence of yr post + a facility precis.

 

Regardless, if AIB demand a monolog, i guess that's what must be given. Personally I prefer the more "Mission Objective" style but it's their Standard.

 

Rgds / Charles.C

 

PS- apologies to Paconmatt if I am pirating yr thread.


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Kind Regards,

 

Charles.C


#9 LWorden

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Posted 14 May 2014 - 04:59 PM

Hi there. I had my procedures mixed in with all other plant procedures and it is difficult to find what he (the auditor) is looking for. I am rewriting everything in a new book that follows the AIB standards numbering system. I had asked my auditor a few questions about the chemical control program and i am pasting his respone below which should help you with your question. The largest thing he looks for is the Owners, Actions and Timelines within a procedure. Each auditor has a different way of looking at the same thing so my auditor is looking for the below. At a different plant the auditor there didn't look for so much.

 

When you think you have a good system going and are ready, then maybe do an unscored audit and justify the expense as training. They will do the audit and show you all of the "holes" in your systems. Remember, what they look for is not only you have a procedure but do you (the plant) actually follow them. Hope the below helps!

 

That is a good question.  Please let me answer it this way…The easiest and most efficient way to start writing the product safety procedures is to put into procedure format (Owners, Actions, and Timelines) the activities that are already being completed at your facility.   

 

For example, remember that the Chemical Program is to be designed to provide a centralized approach to purchase and use of non-product chemicals.  Document who was authorizing chemicals at the site yesterday and what process they were using to determine the level of chemical risk to products prior to saying, ”O.K.-go ahead and buy it.”.    

 

After you have completed this step for each of the bullet points identified in the AIBI Standard, someone should review the procedure to ensure that it matches, and does not conflict with, any existing regulatory requirement, industry standard, or AIBI Standard.   The best group of people to perform this review is YOU and your Product Safety Team

 

You already have a team of Industry expert and a wealth of knowledge concerning HAZMAT and Employee Safety regulations.  The AIBI Standard is not an attempt to lessen the importance of those in any way.  The AIBI Standard is a supplement designed to incorporate the assessment of actual and potential product jeopardy to those other programs and to develop Prerequisite Programs to eliminate or reduce the potential product safety risks intrinsic in the running of a packaging manufacturing facility. 

 

If when you get done writing, then reviewing the program as a team, you still are unsure about your Program, contact our AIBI offices at 1-800-633-5137.  Ask the operator to connect you with our Regional Director on Call and run it by them.  Each of the Directors has had extensive experience with auditing the Packaging Industry and they are ‘on call’ to answer your questions.  If they cannot provide an answer immediately, they will hook you up with a Technical Expert, someone with specific work experience in Packaging who should be able to answer any questions that you still have in your mind.

 

I hope this is helpful – Good Luck with writing those procedures.


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