32 replies to this topic

[Suzie B]

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!

 

Hello IgaZawadzka,

 

I am in a very similar situation.  I've been hired to implement SQF. Like you, I came from a state-of-the art manufacturing facility with SQF procedures and Certifcation in place.  My job was to maintain it.  As many more companies attempt to comply with FSMA, there will be more of us who are thrust into positions that never existed before.  Fortunately, I am at a frozen storage facility.  Unfortunately, the place is 100 years old and is barely standing.  Some of the freezers have wooden floors.  Walls have holes.  Many deficiencies and the employees have never even heard of SQF or food safety.  I am writing our manual, creating the SOPs, making the forms for tracking, creating HACCP plans, and I honestly feel overwhelmed at times. There is so much to do.  Management does not understand what it takes to get ready for a Certification Audit.  They just want it done.  My best advice is try not to look at the whole picture at first.  Focus on one task at a time.  You will make progress if you concetrate on the path to your goal.  A checklist is a good idea.  Start with the basics.  Read the Code.  Whenever you see the words, "The method and responsibility for..." you know you need to write a procedure to spell out the details and identify who, what, how, when, and the method for verifying/validating the information.  Hang in there. 

 

suzie

[Suzie B]

Hello IgaZawadzka,

 

I am in a very similar situation.  I've been hired to implement SQF. Like you, I came from a state-of-the art manufacturing facility with SQF procedures and Certifcation in place.  My job was to maintain it.  As many more companies attempt to comply with FSMA, there will be more of us who are thrust into positions that never existed before.  Fortunately, I am at a frozen storage facility.  Unfortunately, the place is 100 years old and is barely standing.  Some of the freezers have wooden floors.  Walls have holes.  Many deficiencies and the employees have never even heard of SQF or food safety.  I am writing our manual, creating the SOPs, making the forms for tracking, creating HACCP plans, and I honestly feel overwhelmed at times. There is so much to do.  Management does not understand what it takes to get ready for a Certification Audit.  They just want it done.  My best advice is try not to look at the whole picture at first.  Focus on one task at a time.  You will make progress if you concentrate on the path to your goal.  A checklist is a good idea.  Start with the basics.  Read the Code.  Whenever you see the words, "The method and responsibility for..." you know you need to write a procedure to spell out the details and identify who, what, how, when, and the method for verifying/validating the information.  Hang in there. 

 

suzie

[fgjuadi]

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.

 

http://asq.org/quali...t-sampling.html

 

This can help you determine how often to take samples - if you're already determined risk, you can decide how confident you want to be in catching the defect and plug n chug from there.

[IgaZawadzka]

Hello IgaZawadzka,

 

I am in a very similar situation.  I've been hired to implement SQF. Like you, I came from a state-of-the art manufacturing facility with SQF procedures and Certifcation in place.  My job was to maintain it.  As many more companies attempt to comply with FSMA, there will be more of us who are thrust into positions that never existed before.  Fortunately, I am at a frozen storage facility.  Unfortunately, the place is 100 years old and is barely standing.  Some of the freezers have wooden floors.  Walls have holes.  Many deficiencies and the employees have never even heard of SQF or food safety.  I am writing our manual, creating the SOPs, making the forms for tracking, creating HACCP plans, and I honestly feel overwhelmed at times. There is so much to do.  Management does not understand what it takes to get ready for a Certification Audit.  They just want it done.  My best advice is try not to look at the whole picture at first.  Focus on one task at a time.  You will make progress if you concetrate on the path to your goal.  A checklist is a good idea.  Start with the basics.  Read the Code.  Whenever you see the words, "The method and responsibility for..." you know you need to write a procedure to spell out the details and identify who, what, how, when, and the method for verifying/validating the information.  Hang in there. 

 

suzie

 

Hello Suzie,

 

Thank you so much for reply and nice words. It is really comforting to know that I am not the only one with such problem/challenge.

You said "Read the Code", I found it on FDA website but I am not sure if it is applicable in UK. What do you think?

It would be a huge help if it was applicable in the UK as well. I found Food Law Code  of Practice, but I think it is for enforcement officers.

My main problem is that it is hard for me to focus on one problem. So sometimes I sit down and I don't know what to do. This Code thing would be huge help..

 

Anyway, thank you very much Suzie!

 

Iga

 

http://asq.org/quali...t-sampling.html

 

This can help you determine how often to take samples - if you're already determined risk, you can decide how confident you want to be in catching the defect and plug n chug from there.

 

Thank you magenta_majors, I will ready carefully and write sampling plan.

[RG3]

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

Yes it is acceptable to sample one cream cake from one lot/batch. However, if the one batch last you all day (6+hrs) I would recommend taking a beginning middle and end sample. I would think cream that sits idle on top of the of a hopper has a higher chance of micro.

 

As for your environmental find out what your target organism is. When I worked in a bakery it was Listeria because of the type of ingredients used and it was a wet clean with quite a few change overs. 

 

5 sites of what we called Zone 1 = This is any machinery, tables, utensils, slicers, valves, chill rollers, pumps, transport racks, filling and packaging equipment, conveyors, that directly touch the product.

 

5 sites of what we called Zone 2 = This is any machinery that may indirectly come in contact with product such as exterior of machinery or framework, overhead piping, refrigeration units, catwalks, etc. 

 

5 sites of what we called Zone 3 = These sites are your drains, floors, legs of machinery, walls, wheels of transport carts, forklifts, etc. 

 

Try to make a master list of the possible sites for each of these zones you can possibly swab.

 

Good Luck!!!

[IgaZawadzka]

Yes it is acceptable to sample one cream cake from one lot/batch. However, if the one batch last you all day (6+hrs) I would recommend taking a beginning middle and end sample. I would think cream that sits idle on top of the of a hopper has a higher chance of micro.

 

As for your environmental find out what your target organism is. When I worked in a bakery it was Listeria because of the type of ingredients used and it was a wet clean with quite a few change overs. 

 

5 sites of what we called Zone 1 = This is any machinery, tables, utensils, slicers, valves, chill rollers, pumps, transport racks, filling and packaging equipment, conveyors, that directly touch the product.

 

5 sites of what we called Zone 2 = This is any machinery that may indirectly come in contact with product such as exterior of machinery or framework, overhead piping, refrigeration units, catwalks, etc. 

 

5 sites of what we called Zone 3 = These sites are your drains, floors, legs of machinery, walls, wheels of transport carts, forklifts, etc. 

 

Try to make a master list of the possible sites for each of these zones you can possibly swab.

 

Good Luck!!!

 

Thank you for tips! I have one more question, can I do micro swabs and test without fancy laboratory? Do you know any literature about that?

 

Thanks again!

[Charles.C]

Dear IgaZawadzka,

 

A few more thoughts . Previously you noted –

Post #16

 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?

 

post #17

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

 

With all due respect I disagree. IMO the Guidance is an excellent interpretation of the massive original. It emphasizes that  there is flexibility in the sampling plan for yr own process as compared to 2073/2005 and mentions the associated requirements which are logical. The suggested options will inevitably be general (ie non-exact) because the specifics will vary with the particular process. I agree that an example would have been very useful but these official  documents always tend to avoid this for fear of being borrowed, re-used out of context, then quoted as an officially approved option.

In the original document 2073/2005. items like the following particularly relate to the Guidance's clarification -

 intro para (23)

article4, sec.2

article 5,secs. 3-5above

 

 

post #25

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.

 

Here I agree with you that the meaning is not immediately obvious. This question comes up time and time again on the forum, particularly in relation to BRC standard. One convenient  re-interpretation is to reverse the text and “risk assess your  (chosen) frequency” so as to formally demonstrate that the frequency "works", ie enables "control" of the particular target.. This method (which can be generalised to other objectives) appears auditorily acceptable. A nice worked out example/template (see pgs 13-14) is given in the attachment in this post  –

http://www.ifsqn.com...ate/#entry56043

Another appplication using similar idea/layout is discussed/illustrated in this short thread –

http://www.ifsqn.com...sk-assessments/

 

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.

 

I deduce from post #18 that you are already being “audited” by Local Authorities (I presume a legal production requirement). I am surprised that this/yr other interactions has not provided much value as I have seen a few hygiene  audit reports (somehow) getting published on the net and the comments seemed quite good/informative. AFAIK the EHO is not necessarily the direct responsible within  the hierarchical FSA tree ?

 

I have seen some FS training courses in UK  recommended on this forum, eg , from memory RSPH which is multi-level.

 

I’m still puzzled that there seems to be no specific Loc.Aut.  Guidelines for a Hygienic/HACCP acceptable operation (other than SFBB or via MyHACCP of course. The latter may not be a bad option if accessible to you). It’s not exactly directly relevant but i noticed this document which analyses in some depth a model process (egg production) in respect to the individual hygiene/haccp phases given in the 2073/2005 document. The document also details operational requirements which would enable compliance. The micro.risk assessment is slightly unorthodox but an interesting approach.

 EEPA. 2011 - GMP egg products.pdf   453.3KB   35 downloads

 

IMO post #30 is giving you good practical advice but the crucial test is when you evaluate yr own data results. This will tell you whether yr conditions are varying substantially or not / sample size inadequate. If a lot of variation and a potential CCP, the sampling frequency immediately becomes relevant (and maybe improving the control !).

 

As far as environmental sampling goes, some specific frequency ideas (for L.mono) are here –

 guidance-listeria-monitoring.pdf   528.06KB   29 downloads

(eg see pgs 19 et seq, and surrounding text) (note the Food Risk category is also relevant in above approach).

 

Rgds / Charles.C

 

PS – some raw material sampling schemes are attached here –

http://www.ifsqn.com...ecs/#entry73057

(I suspect none are directly useful in yr case but they illustrate a variety of options, from statistical to ad hoc )

 

PPS - added - I have attached an example of a (very) basic sampling program for input materials. This is describable as risk-based.

 Overview Raw Material Sampling Program.xls   16KB   51 downloads

 

If a more detailed format is required, can have a look at the examples in this thread (eg posts #5,7) -

http://www.ifsqn.com...-6-clause-3511/

[IgaZawadzka]

Thank you very much for excellent tips, Charles.C!

 

Right now I am dealing with reorganizing production area. We are buying second egg separating machine and I requested to find a separate space to work with eggs. How should this place look like? Does it has to be specially protected with fence/wall or anything else? I think there should be sink or UV lamp to wash them properly. Any suggestions?