32 replies to this topic

[IgaZawadzka]

Hello everyone!

 

Recently I have been hired to implement the HACCP in a bakery. Few years ago some external company wrote Food Safety Management System book which includes Food Safety Policy Statement, flow diagrams, some procedures and controls (not all), HACCP charts and a few monitoring records&forms. And that is all I have got.I can deal with adding new documents etc, but I am not sure how to implement Food Safety rules in the production. I mean, there is no clean/dirty flow, everything lies on the ground, there is a lot of inaccuracies.And there is nobody to help me.  

 

My question is: where should I start? Is there any guidance, steps?

 

I will appreciate it if anyone answers.

[Charles.C]

Hello everyone!

 

Recently I have been hired to implement the HACCP in a bakery. Few years ago some external company wrote Food Safety Management System book which includes Food Safety Policy Statement, flow diagrams, some procedures and controls (not all), HACCP charts and a few monitoring records&forms. And that is all I have got.I can deal with adding new documents etc, but I am not sure how to implement Food Safety rules in the production. I mean, there is no clean/dirty flow, everything lies on the ground, there is a lot of inaccuracies.And there is nobody to help me.  

 

My question is: where should I start? Is there any guidance, steps?

 

I will appreciate it if anyone answers.

Dear IgaZawadzka,

 

The degree of assistance we can offer may depend on yr own technical background and the specific Company objective, eg you have posted in the ISO22000 forum,  is the intention to get the process/Company certified to this FS Standard within 1 year? 2 years? etc

 

Are you familiar with Food Safety Systems / HACCP ? How big is the bakery ? Products ?

 

If not familiar, some professional assistance will probably be urgently required.

 

If yes, it will probably be logical to try and align yr setup with a standard haccp system, eg Codex.

 

As you may have already worked out, the initial requirement will, from yr description, probably be to (1) implement/document some basic Food hygiene, aka GMP / HACCP Prerequisites. (b) get someone to help, eg initiate a QA Department

 

Please revert with a little more background info.

 

Rgds / Charles.C

[fgjuadi]

Seems like you're trying to change culture which is a lot more difficult than changing documents.

 

Start with GMPs - hairnets, no cell phones, handwashing. 

Then move to ingredients - keep them covered, keep them off the floor, etc

 

 

It's important that they see you doing these things and that they know it is important to you - move stuff, cover stuff, check on stuff.  Being on the floor is more important than being behind the desk.

[IgaZawadzka]

Thank you very much for your replies.

 

Charles.C, I have some technical background, I used to work in Quality Departments as a Quality Inspector, but there were alwayes a few people "above" me and they taught. There were also implemented HACCP so I know how it supposed to look like. It is the first time I am on my own. It is a big challenge for me, I know, but it is also a great opportunity. They know that I don't know everything, so I have time to learn.

Company wants to get certified and they want me to determine how long will it take.

Company employs 150 people, so I guess it is average size? Products are breads, rolls,doughnuts and pastry, cookies and croissants, cakes, yeast dough, cream cakes.

 

Magenta_majors, everyone working in the production use hairnets and safety footwear. But you are right, I will have to change culture

 

Today I talked with Pastry Leader, she is really supportive and she told me that the main problem is no space. They prepare different type of confectionery at night, so the night shift just moves equipment all over the place.

 

There is so much to do that I don't know where to start I think that I should start with doing "To-do list".

 

 

Thanks again for help and replies!

[Mike Green]

Hello everyone!

 

Recently I have been hired to implement the HACCP in a bakery. Few years ago some external company wrote Food Safety Management System book which includes Food Safety Policy Statement, flow diagrams, some procedures and controls (not all), HACCP charts and a few monitoring records&forms. And that is all I have got.I can deal with adding new documents etc, but I am not sure how to implement Food Safety rules in the production. I mean, there is no clean/dirty flow, everything lies on the ground, there is a lot of inaccuracies.And there is nobody to help me.  

 

My question is: where should I start? Is there any guidance, steps?

 

I will appreciate it if anyone answers.

Hi- it sounds like you have a long journey ahead of you!

 

maybe it would help to have a little bit of structure to work with?

 

This link is to a haccp tool on the food standards agency website https://myhaccp.food.gov.uk/  it is primarily mean't for smaller businesses than yours (<50) -but you may find that it will help you in terms of breaking down the steps into manageable chunks- It won't do the job for you-but it will help you to identify what you have and haven't got in terms of policies /procedures etc etc in the first instance- and (if you find it's workable for you)-it does produce a fairly decent/useable set of documents at the end!......and it's free............!

 

Mike

[IgaZawadzka]

Hi- it sounds like you have a long journey ahead of you!

 

maybe it would help to have a little bit of structure to work with?

 

This link is to a haccp tool on the food standards agency website https://myhaccp.food.gov.uk/  it is primarily mean't for smaller businesses than yours (<50) -but you may find that it will help you in terms of breaking down the steps into manageable chunks- It won't do the job for you-but it will help you to identify what you have and haven't got in terms of policies /procedures etc etc in the first instance- and (if you find it's workable for you)-it does produce a fairly decent/useable set of documents at the end!......and it's free............!

 

Mike

Mike Green, thank you very much for link! I have already seen this but I thought it is not applicable in my situation. Anyway, I am registering right now, thank you!

[Charles.C]

Hi- it sounds like you have a long journey ahead of you!

 

maybe it would help to have a little bit of structure to work with?

 

This link is to a haccp tool on the food standards agency website https://myhaccp.food.gov.uk/  it is primarily mean't for smaller businesses than yours (<50) -but you may find that it will help you in terms of breaking down the steps into manageable chunks- It won't do the job for you-but it will help you to identify what you have and haven't got in terms of policies /procedures etc etc in the first instance- and (if you find it's workable for you)-it does produce a fairly decent/useable set of documents at the end!......and it's free............!

 

Mike

 

Dear Mike,

 

Thks for the interesting  link.

 

Sadly it's apparently only free in UK. Shades of the iplayer. (although its audio partner is admittedly a great gift already).

 

I found this website intro rather peculiar -

 

MyHACCP is a free web tool that will guide you through the process of developing a food safety management system based on Hazard Analysis and Critical Control Point (HACCP) principles as required by EU Food Hygiene rules.

 

I thought the avoidance of such "high-tech gobbledegook" was the justification of  the official UK  released, "dumbed-down" SFBB system (terms like HACCP guaranteed removed !). (not criticising the SFBB which is an ingenious system to meet a specific "end").

 

Or is this due to FSA attempting to (now?) insert themselves in the middle somewhere ? (the web-page appeared to be undated).

 

Rgds / Charles.C

[Mike Green]

Dear Mike,

 

Thks for the interesting  link.

 

Sadly it's apparently only free in UK. Shades of the iplayer. (although its audio partner is admittedly a great gift already).

 

I found this website intro rather peculiar -

 

 

I thought the avoidance of such "high-tech gobbledegook" was the justification of  the official UK  released, "dumbed-down" SFBB system (terms like HACCP guaranteed removed !). (not criticising the SFBB which is an ingenious system to meet a specific "end").

 

Or is this due to FSA attempting to (now?) insert themselves in the middle somewhere ? (the web-page appeared to be undated).

 

Rgds / Charles.C

Hi Charles,

 

Yeah it's a bit confusing but.........

 

The 'dumbed down' SFBB (which I must admit I also quite like!) is aimed at  cafes small scale caterers, small food retailers, restaurants etc- who it was deemed (correctly in most cases IMO) would never get anywhere with HACCP!- and as you intimate, we were not even allowed to mention the word-lest they be put off.... or confused... perhaps a little bit patronising -but mostly true(lol!)

 

 Food manufacturers in the UK (like everywhere else) have always had to embrace HACCP (complete with high tech gobbledegook!)

 

But then there were quite a few small manufacturing operations who 'fell between two stools' so to speak, and were basically not complying (perhaps the company in the OP is an example of this?)

 

Hence the development of the Myhaccp tool- (which (admittedly, only if you can have access to it ) is actually quite useful-!)

 

KInd Regards

 

Mike

[Charles.C]

Hi Mike,

 

But then there were quite a few small manufacturing operations who 'fell between two stools' so to speak, and were basically not complying (perhaps the company in the OP is an example of this?)

Hence the development of the Myhaccp tool- (which (admittedly, only if you can have access to it ) is actually quite useful-!)

Indeed that was my suspicion, another means to another end.

 

without revealing State Secrets, how much technology is actually included, for example any mention of Codex, or Risk Assessment ?

 

Rgds / Charles

[Mike Green]

Hi Mike,

 

Indeed that was my suspicion, another means to another end.

 

without revealing State Secrets, how much technology is actually included, for example any mention of Codex, or Risk Assessment ?

 

Rgds / Charles

Hi Charles,

 

It's actually quite like the real thing!!! (very similar to many 'online haccp tools'  I've seen -that you have to pay for!

 

You still have to do all of the work(!)-the tool just provides a framework to work to- and step by step guidance as you go-which I think makes it much more accessible-then it basically arranges everything you input into your ' food safety system' which you can save/print/amend etc

 

I'm sure the UK government wouldn't mind me sharing the attached with you! 

 

It's a copy the introduction section from myhaccp 

 

Kind Regards

Mike

Attached Files

•  Introduction to MyHACCP.pdf   316.99KB   220 downloads

[Charles.C]

Hi Mike,

 

Thanks for the sample. Interesting idea. I will do some ferreting around.

 

It looks to be inspired from another (same source i think) medium-tech HACCP documentation set which was issued several years back around same time as SFBB (possibly from the elements of its less successful [implementation-wise] precursor).

The preamble looks encouraging but, as usual, the devil may be in the details.

 

It seems to me that the weakness of many "do haccp" presentations is that they fail to explain the RA step which is the core of the hazard analysis. Followed by a similar defect if using a Decision Tree. Hazards are typically discussed quite nicely together with the associated control measure / risk formula and then a magical hazard analysis form appears all nicely filled in.

 

I guess the basic difficulty revolves around defining a significant safety-related event in respect to "risk subjectivity", neither readily packaged as a GO/NO GO procedure.

 

Thks again,

 

Rgds / Charles

[Mike Green]

 

The preamble looks encouraging but, as usual, the devil may be in the details.

 

It seems to me that the weakness of many "do haccp" presentations is that they fail to explain the RA step which is the core of the hazard analysis. Followed by a similar defect if using a Decision Tree. Hazards are typically discussed quite nicely together with the associated control measure / risk formula and then a magical hazard analysis form appears all nicely filled in.

 

 

 

Hi Charles,

 

I know exactly the kind of tool you are referring to- and I'm pleased to be able to report that IMO this isn't one of those! 

 

It's not really like an 'SFBB pack for Food Manufacturers' at all!-

 

 Unlike SFBB which dumbs down the whole deal from A-Z-The only thing that myhaccp simplifies is the process and organisation- the user still has to go through the same steps & decisions (and therefore has to have the same knowledge & experience) as if completing a 'manual system'- but  IMO  doesn't get so overwhelmed by the task in hand as I've often witnessed in the past

 

-there's not really any magic!!! (though it does present your decisions & data very nicely indeed!) & the help files are also quite nice ( part of one attached)

 

I suppose the user could just go through the thing 'half heartedly'  -but I don't think that it being an 'online tool' -would make that any more (or less) likely to happen than if it were a propietory paper or sofware based system-(unlike SFBB which positively encourages it!!!)

 

but..... I think that if it is approached diligently, it makes it w-a-a-a-a-y more likely that a useable outcome will be achieved (based on some of the attempts at paper based haccp systems I've come across over the years!!)

 

( As you can probably tell- I quite like it!!!!)

 

Kind Regards

 

Mike

Attached Files

•  Principle 1.pdf   270.23KB   378 downloads

[Charles.C]

Dear Mike,

 

Appreciate the additional sample. Even more interesting.

 

I fear I’m a hard (stubborn?) sell for a HACCP instructional, or perhaps I misunderstand the intention of this programme.

 

I initially got  the impression that this is supposed to be a self-teaching  program for, basically, HACCP newcomers. This seemed compatible with the presentation of the risk assessment procedure. But then I noted comments such as –

“Your decision should be soundly based on experience and professional judgement.”

This seems to imply designed for someone who has already had substantial HACCP training and would likely have seen all the basic RA stuff already? So I am slightly puzzled as to the targetted user.

 

I further have some disagreements / disappointments with  the RA procedure. Some (maybe most) are inevitably subjective (aka personal) but also reflect my own assessment of many threads on this forum.

 

Comments

 

(1) Section 1 was IMO rather well done. Better than many texts I have seen.

 

(2) I consider the 3x3 matrix ineffective for general haccp/RA use due to insufficient discrimination. (even after accepting that RA is anyway a probabilistic measure). I realize thousands (millions?) will disagree .

 

(3) I disagree with comments such as –

“all those hazards scoring 2 and below will be controlled and managed through effective prerequisite programmes”.

IMO a non-significant hazard may also simply not require to be controlled.

( I appreciate that the RA handling of PRPs is debated. I prefer the, IMO, pure RA viewpoint that a PRP is literally that, ie precedes the RA, although some retroactivity is, humanly, inevitable ).

 

(4) There is no mention as to the location of the reference point for the likelihood estimation. The current threads here have demonstrated that this aspect confuses people, and understandably so. One can find differing presentations in textbooks, also with no cross-comments. From memory, both Codex / NACMCF avoid this element. And one reason the discrepancy (if it is such) persists is Zero Examples (or glossed-over ones).

 

(5)  The significance of  “Significant score” is without any discussion, eg Why 3 and not 4 (or even 9)  ? The fact is that such  choices may have consequences. I give the program credit for at least emphasizing   that the options do exist (avoided altogether in some texts) but it then abruptly stops. Or perhaps this was amplified in further text.?

 

(6) A side-comment  - the approach given is, I guess, traditional Codex style. It might be argued that the ISO, control measure centric vision (other than the disastrous OPRP) is the future. But maybe not for UK - BRC.

 

I realize the above critique implies that  a fuller appreciation of RA may demand a further textbook . IMO, this is an unfortunate fundamental problem when one tries to present a condensed text on  “How to HACCP”. Very few texts go into the nitty-gritty of actual process details / RA so the examples given (if any) make it seem sooo straightforward. Maybe it is easier than FMEA but then again ......

 

Rgds / Charles

 

PS - Regardless of the above, i can see why the methodology could work for the OP. Especially if there is a suitable segment on basic Food Hygiene vis-a-vis HACCP. Just for once, maybe not Chicken or Egg.

 

PPS - I deduce this online feature is quite new as it is unmentioned in the FSA / Campden review of UK situation published in 2013 (added - looks like launched ca..April 2014) -

 

 FSA - Campden_report_final,2013.pdf   813.77KB   216 downloads

 

The contents of the report, eg with respect to HACCP,  perhaps explain the motivation / need behind the project, eg pgs 26-29.

 

3PS - i also noted this "quote" on FSA website -
 

 

Many firms we’ve spoken to often use consultancy firms to ensure that they have HACCP under control – this tool changes everything.

Hmmmm.

[Mike Green]

Dear Mike,

 

Appreciate the additional sample. Even more interesting.

 

I fear I’m a hard (stubborn?) sell for a HACCP instructional, or perhaps I misunderstand the intention of this programme.

 

I initially got  the impression that this is supposed to be a self-teaching  program for, basically, HACCP newcomers. This seemed compatible with the presentation of the risk assessment procedure. But then I noted comments such as –

“Your decision should be soundly based on experience and professional judgement.”

This seems to imply designed for someone who has already had substantial HACCP training and would likely have seen all the basic RA stuff already? So I am slightly puzzled as to the targetted user.

 

I further have some disagreements / disappointments with  the RA procedure. Some (maybe most) are inevitably subjective (aka personal) but also reflect my own assessment of many threads on this forum.

 

Comments

 

(1) Section 1 was IMO rather well done. Better than many texts I have seen.

 

(2) I consider the 3x3 matrix ineffective for general haccp/RA use due to insufficient discrimination. (even after accepting that RA is anyway a probabilistic measure). I realize thousands (millions?) will disagree .

 

(3) I disagree with comments such as –

“all those hazards scoring 2 and below will be controlled and managed through effective prerequisite programmes”.

IMO a non-significant hazard may also simply not require to be controlled.

( I appreciate that the RA handling of PRPs is debated. I prefer the, IMO, pure RA viewpoint that a PRP is literally that, ie precedes the RA, although some retroactivity is, humanly, inevitable ).

 

(4) There is no mention as to the location of the reference point for the likelihood estimation. The current threads here have demonstrated that this aspect confuses people, and understandably so. One can find differing presentations in textbooks, also with no cross-comments. From memory, both Codex / NACMCF avoid this element. And one reason the discrepancy (if it is such) persists is Zero Examples (or glossed-over ones).

 

(5)  The significance of  “Significant score” is without any discussion, eg Why 3 and not 4 (or even 9)  ? The fact is that such  choices may have consequences. I give the program credit for at least emphasizing   that the options do exist (avoided altogether in some texts) but it then abruptly stops. Or perhaps this was amplified in further text.?

 

(6) A side-comment  - the approach given is, I guess, traditional Codex style. It might be argued that the ISO, control measure centric vision (other than the disastrous OPRP) is the future. But maybe not for UK - BRC.

 

I realize the above critique implies that  a fuller appreciation of RA may demand a further textbook . IMO, this is an unfortunate fundamental problem when one tries to present a condensed text on  “How to HACCP”. Very few texts go into the nitty-gritty of actual process details / RA so the examples given (if any) make it seem sooo straightforward. Maybe it is easier than FMEA but then again ......

 

Rgds / Charles

 

PS - Regardless of the above, i can see why the methodology could work for the OP. Especially if there is a suitable segment on basic Food Hygiene vis-a-vis HACCP. Just for once, maybe not Chicken or Egg.

 

PPS - I deduce this online feature is quite new as it is unmentioned in the FSA / Campden review of UK situation published in 2013 (added - looks like launched ca..April 2014) -

 

FSA - Campden_report_final,2013.pdf

 

The contents of the report, eg with respect to HACCP,  perhaps explain the motivation / need behind the project, eg pgs 26-29.

 

3PS - i also noted this "quote" on FSA website -
 

Hmmmm.

Hi Charles,

 

Thanks for that-very valid points- I don't think it's perfect by any stretch of the imagination-but it is a very very solid starting place!

 

 I'm  just sorry that you can't see the whole thing!

 

IMO it makes it(fairly) clear that it should be completed by someone with the relevant experience/training-but maybe doesn't go far enough -and it's definitely not sold as a 'haccp training tool'

 

Ultimate responsibility for the HACCP based food safety management system rests with the food business itself; after all it is food business operators and their staff who know the process and product the best.

It is intended that MyHACCP will help to assist businesses on their journey to producing effective HACCP based food safety controls; it will not state what the business has to do.  Instead the tool will lead users through a structured step-wise process, encouraging them to think about their own process(es) and make informed decisions based on what they know or find out. MyHACCP will provide assistance at each step or point you towards more detailed background information to support your decision making

 

 

 

 

 

 

 

HACCP Training – It is recommended that all team members and individuals developing controls for their very small business have previously attended a HACCP training course.  There are various levels of HACCP training (Foundation, Intermediate and Advanced).  Core team members should consider taking a level of qualification at intermediate or beyond.  Refresher training should also be considered.

Consultants – Consultants may be helpful in developing a HACCP plan although we hope that MyHACCP will allow you to successfully work through the process.  Whilst the consultant may provide the necessary scientific/technical knowledge and HACCP expertise, ownership of the HACCP system and its implementation should lie with the HACCP business owner or team leader on-site.  Their involvement in preparing the system is paramount and essential to day-to-day management and maintenance of the HACCP system.

 

 

Small businesses may not have all the necessary expertise in-house that may be required to devise, implement and maintain a HACCP study.  It is imperative that small businesses take ownership of their HACCP study whether they take external advice (e.g. via a consultant) or not.

I think maybe in the final assessment, the tool for the companies who are 'falling between two stools' has maybe (to some small extent) 'fallen between two stools' ha ha!

 

-but I think the real target audience - those with very little in place 'haccp-wise' are certainly benefitting from it!

 

Kind Regards

Mike

[Charles.C]

Dear Mike,

 

Thanks for the additional quotes. Interesting clarifications / stings in the tail .

 

I agree with you that attempting to bridge the gulf between SFBB and full-blown HACCP is not a simple undertaking. Hence SFBB of course. However, in essence, the present work is no less complete than many other published hazard analyses / CCP pronouncements so I guess one must (reluctantly) make some allowances.

 

I had a further look within some visible portions, eg at a specimen haccp plan.

Assuming the specimen is an “approved” document in respect to the suggested website procedures, all I can say is that the intro and logic for  Risk Assessment  do not agree with mine, eg generalisations such as  –

 

 hazards.pdf   53.88KB   218 downloads

 

However disregarding the methodology for hazard analysis / CCP determination , the  precis of  recommendations for subsequent HACCP Principles / events is quite neat  IMO. Rather surprisingly (to me) the treatment retains the nesting of Validation within Verification.

 

Overall it’s a gallant effort IMO. Pity that (at least for me) it falters at the first step.

 

Rgds /Charles

[IgaZawadzka]

Hello everyone,

 

I just found out that there is no sampling plan which shows that we comply with Regulation No 2073/2005 (Annex I to be specific). I have read this regulation but I still don't know how to provide such plan. Any advice? 

[RG3]

Hi IgaZawadzka,

 

  I would be glad to help. I have worked in a bakery plant and co-wrote and maintained Quality Management Systems there. It's good that you already have one management person behind you. Now you just need the rest to buy into the program. I would assume the one that hired you and wants a timeline of when to complete this is behind you as well. I would say this will be 1 1/2 years to 2 years until you become certified given that you're starting from 0 and need to change culture.

 I recently took on a task similar and evaluated the "situation". My current employer wanted to get certified within 3 months and I told him impossible starting at ZERO (I know you're suppose to tell the interviewer what they want to hear "YES". But I keep it real.) I told him it would take me 1/2 to 1 month to evaluate and understand the process and get us registered for everything needed 3 months to write the programs and 3-5 months of at least having people following FSMS with documents (All the while training training training [THE BEST WAY TO INTRODUCE CULTURE TRAINNING) People on the shop floor were actually happy to get trained on something letting them know they are a part of something bigger. I let them know what we are trying to get is a letter grade as if you were going to a restaurant. If you go to a restaurant you want to see a letter A. Same thing our customers want to see...they want to see an A on our door. 8 months later from date of hire we have an "A" at our door. [I should put that on my resume]

 To make a long story longer, you're on the right path, your building your team and you're making a to do list (the elements), but keep the big picture in mind and one everyone else's mind that YOU WANT TO GET CERTIFIED. Most important thing you can do, besides training, is go into production and make your presence felt. Personally I would start with making my flow chart so I can understand the process and make the risk assessment because this is where all your important documents are going to stem from. And then go into production. Training and then go into production. Training and then go into production. Rinse Wash Repeat.

[IgaZawadzka]

Hi IgaZawadzka,

 

  I would be glad to help. I have worked in a bakery plant and co-wrote and maintained Quality Management Systems there. It's good that you already have one management person behind you. Now you just need the rest to buy into the program. I would assume the one that hired you and wants a timeline of when to complete this is behind you as well. I would say this will be 1 1/2 years to 2 years until you become certified given that you're starting from 0 and need to change culture.

 I recently took on a task similar and evaluated the "situation". My current employer wanted to get certified within 3 months and I told him impossible starting at ZERO (I know you're suppose to tell the interviewer what they want to hear "YES". But I keep it real.) I told him it would take me 1/2 to 1 month to evaluate and understand the process and get us registered for everything needed 3 months to write the programs and 3-5 months of at least having people following FSMS with documents (All the while training training training [THE BEST WAY TO INTRODUCE CULTURE TRAINNING) People on the shop floor were actually happy to get trained on something letting them know they are a part of something bigger. I let them know what we are trying to get is a letter grade as if you were going to a restaurant. If you go to a restaurant you want to see a letter A. Same thing our customers want to see...they want to see an A on our door. 8 months later from date of hire we have an "A" at our door. [I should put that on my resume]

 To make a long story longer, you're on the right path, your building your team and you're making a to do list (the elements), but keep the big picture in mind and one everyone else's mind that YOU WANT TO GET CERTIFIED. Most important thing you can do, besides training, is go into production and make your presence felt. Personally I would start with making my flow chart so I can understand the process and make the risk assessment because this is where all your important documents are going to stem from. And then go into production. Training and then go into production. Training and then go into production. Rinse Wash Repeat.

 

 

Thank you so much, it is really nice to know that I am not the only one who deals with this kind of problem. Today, I prepared a list of EHO findings since 2011. I have got 142 points. I went into production and found out that some of them are completed which is nice. I am just scared because I have nobody to show me the path, to teach me. So it has to take time..

Would you mind helping me with sampling plan? How should I prepare sampling plan?

Best regards,

Iga

[RG3]

Your sampling plan should involve your ingredients, WIP process, and your finished goods. Environmentals would be held separate. Because you are dealing with different profiles your sampling plan will be big. I suggest you sample:

 

• "high risk ingredients" such as eggs, sour cream, cheeses, and any topping.  (per lot of Raw Material/per day) CC/Y&M/APC no APC on live culture items i.e. cheeses
• Mix after mixing (per formula) CC/Y&M
• Mix after any hopper (per formula) CC/Y&M maybe for chemical pH and TA and solids
• Finished good after being packaged (per SKU especially if you're RTE) CC/Y&M/APC pathogen micro based on history
• Let me know if you need an environmental sampling plan in detail.

[IgaZawadzka]

Well, my respond disappeared. 

 

RG3, thanak you very much for sampling plan idea, if you can please tell me more about an environmental sampling plan. To be honest I thought it would  be simpler. Is it not acceptable to sample only one or two of cream cakes if they use exactly the same cream to all of them? I mean, they make cream once a day, in this large pot.

Best regards,

Iga

[fcchoi]

wish u all the best and good luck, always recommend u to buy the FSSC 22000 Implementation Package Assured to start off loud

[Charles.C]

Hello everyone,

 

I just found out that there is no sampling plan which shows that we comply with Regulation No 2073/2005 (Annex I to be specific). I have read this regulation but I still don't know how to provide such plan. Any advice? 

 

Dear IgaZawadzka,

 

You may find this link of  some relevance -

 

http://www.food.gov....id/microbiolreg

 

and the pdf included in link -

 

 uk-06001-micro-criteria.pdf   80.47KB   162 downloads

 

Rgds / Charles.C

 

PS - regarding env.sampling prog. there are many examples scattered on this forum, eg this recent one from another poster (I think) -

 

 Guidance for environmental sampling program.pdf   249.14KB   174 downloads

 

[IgaZawadzka]

Dear Charles.C,

 

Thank you for your help. To be honest, I have already known this General Guidance. And it did not help much.

Maybe I write down my inquiries and doubts. Please, let me know if I am on a good track:

 

1.since we produce bakery products and confectionery, we are not obliged to test for Listeria monocytogenes

2.we use Supplier Information Request Form and we only purchase from reputable suppliers. Should I test raw materials e.g. eggs, milk, cream, raw fruits? Or only finished products?

3.what about whipped cream we made? 

4.is there a possibility to create small "laboratory" and do some testing in site? 

 

Best regards,

Iga

[Charles.C]

Dear IgaZawadzka,

 

Well, this kind of recommendation in pdf is quite typical of FS standards although some are more prescriptive -

Where  testing  is  appropriate,  sampling  frequency  should  be  based  on  risk, taking  account  of  instructions  for  use  of  the  foodstuff  (e.g.  ready-to-eat, intended  to  be  eaten  after  cooking  or  other  processing).

Yr queries 1-3 all relate to the above generic comment in the context of yr actual processes.

 

Unfortunately I'm not in UK or bakery business so no direct experience with your product/situation.

Examples of sampling plans exist based on risk, the degree of sampling typically relates to the results. One common approach is to grade suppliers based on a standard initial sampling density then adjust based on the, for example, monthly average result. Several forms have been posted on the forum to handle such programs. A 2nd method is to categorize, eg L/M/H from the beginning and then set appropriate initial sampling levels. But maybe this complexity is too high-tech for yr operation.?

 

It was my understanding that the SFBB system (designed to be "nominally" compliant to 2073/2005 etc) was initiated for the smallest FBOs, eg restaurants, caterers etc. Appropriate documentation / training was then provided free.

I assume yr own manufacturing activity fits into a different, higher level, product-related segment. Other people here on such levels seem to get their info/advice through EHOs and related FSA hierarchy ?

 

Anyway, I presume the certification you originally mentioned as yr objective must be with respect to some standard ? If so, the usual first step is to determine the auditable requirements which I assume are documented ?

 

And the usual next step is to do a Gap Analysis which should highlights the major directions/details to be sorted out.

 

The appropriate response to yr previous post is then usually determined within the above framework which I am unfamiliar with. Other people here presumably are though.

 

Basically the whole certification operation revolves around the to-be-audited requirements although hygienic facilities should have implemented most of the basic GMP already. Yr original posts suggested this was likely to be the first focus but the exact range of implementations involved may relate to the future audit requirements.

 

Difficult (for me) to go much further without more background knowledge.

 

Rgds / Charles.C

[IgaZawadzka]

Dear Charles.C,

 

Thank you very much for reply.

 

The key is "sampling frequency should be based on risk". And I don't know, maybe I am stupid, but I don't know how to understand that. I mean, I know that higher risk = more samples, but HOW MUCH and what is more important, HOW OFTEN? I can do the risk analysis and for example it will say that cream storage is high risk (CCP). What then? Should I take sample of cream daily? Weekly? Monthly? We don't have a laboratory, so it will take time to send it to lab and get the results. I think it makes no sense.

 

I thought about contacting EHOs, and I actually did it.There was no response. I wrote to FSA and they send me links to food hygiene regulations and so on. My Manager said that it will be better if I do it by myself. He can pay for my training, but I did not found accurate course. I did only one, H&S lvl 2, and to be honest I was disappointed. I did not learn anything new. For me it was high school level.

 

If I understand you right, I did Gap Analysis. And one of "details to be sorted out" is sampling plan

 

Anyway, Charles.C, thank you soooo much for help and conversation :)

 

Kind regards,

Iga