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SerenityNow!

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Posted 31 March 2015 - 08:34 AM

Hello Everyone,

So I'm starting over with a new company with new owners in a confectionery company; chocolate to be exact.

I have been tasked with getting the quality program off the ground and prepared for a BRC audit by July this year. At this time, I am the only person in Quality. Although I have not been given the go ahead to begin the hiring process, I was told I will be able to after our recent auditor turns in his report and recommendations for the facility.

And now to my dillema.... Or shall I say plea for help :-D
I am overwhelmed at where to start and what my plan of attack should be. This is our 9th day of operation and I have so many things to address all of which are important. We already have production started so my first priority has been employee training on several topics. Especially since I have no quality team.

Does anyone have any suggestions on how I can attack this without getting too weighed down with all the little details? I seem to start on one thing then I become a bit neurotic over all the details and not wanting to half ass things so I feel like I'm making things more complicated than I need to. Especially since I need to be BRC ready by July.

Any suggestions are appreciated.

Thanks,

Lisa



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Posted 31 March 2015 - 08:51 AM

Hello Lisa,

First off take a deep breath and try to relax; you’ve certainly come to the right place to get your ideas in order.

In any circumstance BRC Certification is a tough goal; it is a very rigorous standard.  My concern would be July is very close and you are the only person in quality, but maybe this is not an issue if your current Food Safety Management System is already in good shape and you are competent for the job.

A few questions to help us understand where you are at:

1. Is this a brand new manufacturing operation?

 

2. What is the current FSQMS system level, for example do you have a prerequisite program in place and a HACCP risk assessment?

 

3. Is the plant fir for purpose for food manufacture?

 

4. Have you had any previous audits such as AIB or customer etc.?

 

5. Are you saying you’ve already had some sort of BRC Gap analysis audit?

 

6. What is your own personal level of knowledge and experience of FSQMS?

 

7. Is the owner committed to providing you with the necessary support and resources to deliver the goal?

 

If you can provide a little more information it will enable us to be more specific with our advice.

Regards,

Simon


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SerenityNow!

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Posted 31 March 2015 - 09:55 AM

Hi Simon,

 

Thank you for the quick reply.

 

I agree, July is rather close when starting over from scratch.  Initially they were trying to keep the prescheduled date which was the end of April.  They did not want the audit changed but the third party auditor suggested that we move it out.  Scary!

 

We currently do not have any written FSQM program any longer.  When the old company closed, everything went with it.  I personally have some generalized documents on an external drive that i can use as a starting point for a few programs.  Everthing else needs to be created and put into place all while operations already started.  I currently have a list of items on QC hold. 

 

Below are some answers to your questions.

 

 

1. Is this a brand new manufacturing operation? This is not a brand new operation.  The previous company went bankrupt and the new owners purchased the accounts and equipment as well as leased the same facility.  Many of the old employees are now employed with the new company including some management.  We also have new employees as well.  Along with the bankruptcy went all of the paperwork, files, computers, and old QM documents and programs.  We basically have to start all over, blank slate.

 

2. What is the current FSQMS system level, for example do you have a prerequisite program in place and a HACCP risk assessment?  At this point we do not have very much in place at all.  I did manage to locate some of our old HACCP info on an external drive I had but it is imcomplete.  The actual assessment will need to be performed again.

 

3. Is the plant fir for purpose for food manufacture?  Yes, although it's not ideal and we could benefit from some improvements, it is fit for manufacture.

 

4. Have you had any previous audits such as AIB or customer etc.?  The new owners hired an independent auditor to come in and evaluate our entire facility including staff evaluations as well.  It was a three day audit that was closed last Friday.  I hope to see a report sometime this week.  The report is expected to list overall recommendations.  It wasn't necessarily a FSQM audit but rather more of an overall operations and FS audit for the new owners to have an idea of what to expect coming in.

 

5. Are you saying you’ve already had some sort of BRC Gap analysis audit?  Not specifically BRC Gap analysis, just an overall facility and operations audit.

 

6. What is your own personal level of knowledge and experience of FSQMS?  I have had some BRC exposure with the old company as well as general food safety audits (non GFSI).  However, we had a very broken system.  The previous owner, would often made executive decisions that would go against recommendations from Quality, and would often take the side of production vs. quality leaving many of our programs/procedures/records hanging out to dry.  My  intention is not to talk down on him as I was an employee and ultimately responsible as well.  I just want to give an honest portrait of our old processes and the extent of my work experience.  With that said, I can honestly say that i haven't had the proper working experience with the standard.  I have however read the standard and in theory have a fairly decent grasp.  I also feel that i am capable of writing policies/procedures to comply.

 

7. Is the owner committed to providing you with the necessary support and resources to deliver the goal.  The new owners have repeatedly stated that they are committed to improving quality within the facility.  I initially submitted some department needs including staffing and equipment needs along with a synopsis as to the why the company would benefit from these things.  However, they will not move forward with anything until the third party auditor has provided the report.  This is understandable and at this point, I don't see any signs that they would not provide the necessary support.

 

Thank you so much for your help.  I need to hit the ground running with this and the starting point is a bit fuzzy because everything needs attention.



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Posted 01 April 2015 - 04:55 AM

Hi Lisa,

 

My sympathies with your situation I can understand how you feel.... :uhm:

 

The Global Standard for Food Safety requires four key elements:
Senior management commitment
A HACCP plan
A quality management system
Prerequisite programmes - basic environmental and operational conditions

You will need to prioritise the how you tackle the elements of the BRC Global Standard for Food Safety:

1 SENIOR MANAGEMENT COMMITMENT
1.1 Senior management commitment and continual improvement
1.2 Organisational structure, responsibilities and management authority

2 THE FOOD SAFETY PLAN – HACCP
2.1 The HACCP food safety team – Codex Alimentarius Step 1
2.2 Prerequisite programmes
2.3 Describe the product – Codex Alimentarius Step 2
2.4 Identify intended use – Codex Alimentarius Step 3
2.5 Construct a process low diagram – Codex Alimentarius Step 4
2.6 Verify low diagram – Codex Alimentarius Step 5
2.7 List all potential hazards associated with each process step, conduct a hazard analysis and consider any measures to control identified hazards – Codex Alimentarius Step 6, Principle 1
2.8 Determine the critical control points (CCPs) – Codex Alimentarius Step 7, Principle 2
2.9 Establish critical limits for each CCP –  Codex Alimentarius Step 8, Principle 3
2.10 Establish a monitoring system for each CCP – Codex Alimentarius Step 9, Principle 4
2.11 Establish a corrective action plan – Codex Alimentarius Step 10, Principle 5
2.12 Establish verification procedures – Codex Alimentarius Step 11, Principle 6
2.13 HACCP documentation and record

3 FOOD SAFETY AND QUALITY MANAGEMENT SYSTEM
3.1 Food safety and quality manual
3.2 Documentation control
3.3 Record completion and maintenance
3.4 Internal audits
3.5 Supplier and raw material approval and performance monitoring
3.6 Specifications
3.7 Corrective and preventive actions
3.8 Control of non-conforming product
3.9 Traceability
3.10 Complaint handling
3.11 Management of incidents, product withdrawal and product recall
3.12 Customer focus and communication

4 SITE STANDARDS
4.1 External standards
4.2 Security
4.3 Layout, product low and segregation
4.4 Building fabric, raw material handling, preparation, processing, packing and storage areas
4.5 Utilities – water, ice, air and other gases
4.6 Equipment
4.7 Maintenance
4.8 Staff facilities
4.9 Chemical and physical product contamination control
4.10  Foreign-body detection and removal equipment
4.11 Housekeeping and hygiene
4.12 Waste/waste disposal
4.13 Management of surplus food and products for animal feed
4.14 Pest control
4.15 Storage facilities
4.16 Dispatch and transport
 
5 PRODUCT CONTROL
5.1 Product design/development
5.2 Product labelling
5.3 Management of allergens
5.4 Product authenticity, claims and chain of custody
5.5 Product packaging
5.6 Product inspection and laboratory testing
5.7 Product release

6 PROCESS CONTROL
6.1 Control of operations
6.2 Labelling and pack control
6.3 Quantity – weight, volume and number control
6.4 Calibration and control of measuring and monitoring devices

7    PERSONNEL
7.1 Training
7.2 Personal hygiene
7.3 Medical screening
7.4 Protective clothing: employees or visitors to production areas


In my view you should prioritise the Fundamental Requirements:
Within the Standard certain requirements have been designated as ‘fundamental’ requirements. These requirements relate to systems that are crucial to the establishment and operation of an effective food quality and safety operation. The requirements deemed fundamental are:
• Senior management commitment and continual improvement (1.1)
• The food safety plan – HACCP (2)
• Internal audits (3.4)
• Management of suppliers of raw materials and packaging (3.5.1)
• Corrective and preventive actions (3.7)
• Traceability (3.9)
• Layout, product low and segregation (4.3)
• Housekeeping and hygiene (4.11)
• Management of allergens (5.3)
• Control of operations (6.1)
• Labelling and pack control (6.2)
• Training: raw material handling, preparation, processing, packing and storage areas (7.1).
Failure to comply with the statement of intent of a fundamental requirement (i.e. a major non-conformity) leads to non-certification at an initial audit or withdrawal of certification at subsequent audits. This will require a further full audit to establish demonstrable evidence of compliance.


Quite clearly one person isn’t going to implement all of this on their own, in this situation I would be looking to develop a plan for the organisation to meet all the requirements of the standard highlighting the resources and assistance required. This plan can arise from a management meeting to discuss the requirements and who can contribute. All departments have responsibilities for quality and food safety and should be part of this plan and contribute.
Examples:
Purchasing – Purchasing procedures/Supplier approval procedure/Product authenticity etc.
Engineering – Maintenance schedules/Calibration/Utilities etc.
Production – Operational controls/Product Labelling etc.
Human Resources - Training/Medical Screening etc.

In the meantime I would also work on HACCP and Quality Plans based on the controls currently in place. These can be reviewed when you are further down the implementation process.

Good luck with this, one thing for sure is that you can’t do this all on your own so Senior Management and all other employees need to get on board with you.

Regards,

Tony
 



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wshirst

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Posted 01 April 2015 - 03:03 PM

Lisa,

 

If at all possible I would recommend hiring a consultant. I am in a similar situation and the company brought in a consultant that was of tremendous help. Fresh eyes help to focus on the larger picture and not sweat the small stuff. I too well understand the isolated system you are in. Good luck!

 

Regards,

 

Wendy



Simon

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Posted 01 April 2015 - 07:53 PM

A consultant is a good idea Wendy. IF they can deliver on time, on budget and on quality.

You should be very clear about those three elements before embarking on any project.

 

If the senior management are able to support this then it may be a possibility.

 

Once you get the report back from the auditor you should have a clearer picture on what needs to be done.

Could he/she (the auditor) have provided you with a prioritized action plan?

 

Keep us up to date and we will try to assist the best we can.

 

By the way does Tony's list help any?


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SerenityNow!

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Posted 02 April 2015 - 04:24 AM

Thank you so much Tony!  As suggested, I am going to focus on prioritizing the fundamentals and branch out from there while getting in some of the essential processes and documents for production, which is already in progress despite the completion of the FSQM system.

 

Simon and Wendy, thank you.  As for the suggestion of the consultant, it is definitely something that i will keep in mind.  I will wait to see the report from the recent auditor and see use that as a starting point to put a game plan together for a written proposal in which i will also include a budget.

 

I have started to put together a task list and was wondering if anyone might have some sort of project planning spreadsheet that they'd be willing to share with me.  I have the new President of the company flying in next week to review operations and would like to be able to present a timeline projection as well as the tasks.  This would be especially helpful to get the new owners a birdseye view of how large task is including all the elements that go into FS.

 

Thanky you so much for talking me away from the ledge.  :shutup:



Charles.C

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Posted 02 April 2015 - 04:45 AM

I forget what yr product/process is which may have some relevance to the text below.

 

IMHO, and, from memory, as previously discussed on this forum for BRC, unless you personally are a Magician or you involve something like a consultant/pre.fabricated FS system, the kind of existing set-up you are describing will typically require at least 6 months.

 

Unfortunately I also guarantee yr President will not believe this. It's against the Bigwig Principle.

 

The typical timeline Plan you need is a Gantt Chart. I believe there are some examples on this forum if you ever have time to search them out.

 

Good Luck !

 

PS - I also guarantee that if, as i understand is the case, a lot of the old employees, eg Production/QA are still involved, the previously used forms etc will not be totally lost. Known as the Squirrel Syndrome. :smile:


Kind Regards,

 

Charles.C


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Posted 02 April 2015 - 03:55 PM

Thank you so much Tony!  As suggested, I am going to focus on prioritizing the fundamentals and branch out from there while getting in some of the essential processes and documents for production, which is already in progress despite the completion of the FSQM system.

 

Simon and Wendy, thank you.  As for the suggestion of the consultant, it is definitely something that i will keep in mind.  I will wait to see the report from the recent auditor and see use that as a starting point to put a game plan together for a written proposal in which i will also include a budget.

 

I have started to put together a task list and was wondering if anyone might have some sort of project planning spreadsheet that they'd be willing to share with me.  I have the new President of the company flying in next week to review operations and would like to be able to present a timeline projection as well as the tasks.  This would be especially helpful to get the new owners a birdseye view of how large task is including all the elements that go into FS.

 

Thank you so much for talking me away from the ledge.  :shutup:

 

No problem Lisa,

 

Let us know what the auditor's report says. Hopefully it will support your position but keep on with your plans in the meantime.

 

Regards,

 

Tony



SerenityNow!

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Posted 03 April 2015 - 03:19 AM

Seems like the verdict is in as fars as help is concerned.  Although i have not yet seen a report, the new President is only willing to add one more person to Quality which makes a grand total of two of us.  I still dont know what type of salary they will approve so that still leaves to question the level of help this second person will be able to provide.  I am happy i am getting some help but the fact that they are only willing to approve one person is a scary sign.  Seems they may have the "just make it and send it" mentality. 

 

For now i am going to keep with my plans as this has now become somewhat of a personal challenge but i cant help but to feel that i am being set up for failure.  Athough i dont believe its intentional, i think they might just not understand the scope of what needs to be pulled off, and maintained.  Hopefully after i present a plan outlining all the details they will have a better understanding. 

 

Wish me luck!



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Posted 03 April 2015 - 05:35 PM

Seems like the verdict is in as far as help is concerned. 

 

For now I am going to keep with my plans as this has now become somewhat of a personal challenge but I cant help but to feel that I am being set up for failure.

 

Wish me luck!

 

Good luck!

 

Recruitment of a competent person at this sort of level can take several months so don't wait for the assistance, get on with it on your own for now.

 

As I said before, provide a plan that involves a contribution from everyone in your organisation including the 'President' and in the meantime work on the fundamentals.

 

Regards,

 

Tony



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Posted 03 April 2015 - 10:15 PM

Lisa_MG,

 

I was in exactly the same boat as you last summer, except we were going for SQF.  I dealt with the same attitudes and staffing levels (QA/QC dept. Population-2).  You're going to have to jump in the deep end of the BRC pool, but it can be done.  I started working on SQF prep my second day of work, and we successfully completed our Facility Audit one month ago, today (5 months, 9 days, to be exact!).  My advice is break up the different sections of the BRC Code into more manageable pieces, and start with the stuff you understand the best; I found this helped me get through quicker.  As a multi-tasker, I was always letting the next few things on my list percolate in my brain, so I'd see links and connections, and make notes as ideas came to me.



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Posted 18 December 2018 - 08:34 PM

Lisa,

I'm similar situation than you. Was your company HACCP certified before you or you did both in 5 months?





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