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Food Safety Plan Template (FSMA) - and also PCs + adulteration


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#1 FSQNNow

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Posted 12 January 2016 - 05:01 PM

Hi all,

 

Has anybody already designed a smart Food Safety Plan template.

 

I am working from an EU based site and I have a certified good working FSSC 22000 program.

1. I would like to set-up a smart Food Safety Plant template whereby I utilize most of our existing system infrastructure and refer as much as possible to existing FSSC, So the FSP would kind of look like an Extended Table of Content. For all key elements explaining the approach and how it (FSSC based) is compliant with FSMA.

Of course I am aware of examples where HACCP needs review, minor amending (radiation, CCP.oPRP vs Preventative Controls), Foreign Supplier Verification, etc.

 

Looking forward to hear ideas/examples from anybody.

 

2. IF you currently have FSSC 22000, would you think that you would want to extensively start measuring a lot of your Prerequisite Programs (PRP) as PCs? Or would you agree that CCP and oPRPs together are what you would want to consider as PCs. (meaning that some of the measurable oPRPs would now also need to be validated (but look at exceptions in law), but not anyfurther PRPs). I like to hear your views

 

3. What do you see as a bigger hazard/threat/risk: buying adulterated ingredients, or fearing adulteration by own or temporarily hired staff or other people that could gain access into your site/supply chain?


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#2 Charles.C

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Posted 12 January 2016 - 06:02 PM

Hi FSQN,

 

What is "PC" ? A new terminoogy for me. Self-generated ?

 

I have to admit that i found No.2 somewhat incoherent. Maybe lack of familiarity with the topic.


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Charles.C


#3 FSQNNow

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Posted 20 January 2016 - 11:31 AM

PC = preventative control (key element of the FSMA)

 

Key question:

a smart way to modify from a good quality existing HACCP plan and FSSC 22000 certification to a Food Safety Plan (FSP) required as now by FSMA.

 

Apart from FDA documentation I find this explanation as a summary very helpful. But it does not generate a simple FSP template.

http://www.aibonline...WhatYouNeed.pdf


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#4 Charles.C

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Posted 20 January 2016 - 08:27 PM

Hi FSQN,

 

Thks for the clarification/link. Quoting -

 

A PC (preventive control) is an appropriate procedure, practice, and process that “significantly minimizes or prevents” an identified hazard.

 

In addition, any other control that significantly minimizes or prevents a specific hazard would be considered a preventive control.

 

Incredibly imaginative !

 

Seems that FDA/FSMA are attempting to re-invent the haccp wheel.

 

The above mimics, from memory, a long-defunct  CCP phraseology which was quietly abandoned due to its ambiguity and consequent  confusion.

 

My own recommendation regarding "oprp" would be to simply delete all references to it in iso22000. IMO it's a totally redundant creation and an excellent example of how to generate chaos without really trying.

I shudder to think how many people-hours have been wasted attempting to understand the reason/objective for this entity.

But no doubt popular with Consultants.


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Kind Regards,

 

Charles.C


#5 Maltus

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Posted 18 February 2016 - 01:35 PM

To me, this PC is similar to CP (Control Point), as define on IFS.

 

Could it be hazards identificated as significatives thar aren't clasificated as CCPs?

 

Charles, I agree with you. I have wasted a lot of tiem trying to explain some clients the differences between PRP, CCP, oPRP...


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#6 usstigenj

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Posted 04 May 2016 - 02:05 AM

I attended FSPCA Preventative Controls for Human Food (PCQI) training course a few weeks ago. I would advise going to this website and getting the training manual as it is available for download at no cost:

 

http://www.iit.edu/i...fspca_materials

 

This is the manual that we got in the training course. There are examples or at least pieces of food safety plans in the material.


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#7 usstigenj

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Posted 04 May 2016 - 02:14 AM

Just noticed there were Food Safety Plan Worksheet templates there as well in addition to the training manual:

 

http://www.iit.edu/i....1_Fillable.pdf


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#8 Charles.C

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Posted 04 May 2016 - 03:17 AM

Hi usstigenj,

 

Thanks for the link and Welcome to the Forum ! :welcome:

 

Can also see -

 

http://www.ifsqn.com...al/#entry100905

 

http://www.ifsqn.com...al/#entry100636

 

http://www.ifsqn.com...al/#entry100903

 

http://www.ifsqn.com...ndpost&p=100220

 

http://www.ifsqn.com...indpost&p=98927

 

http://www.ifsqn.com...indpost&p=98195

 

It seems to me that the hazard analysis template is invalid since it lacks columns for severity and likelihood. AFAIK this data is now mandatory to be included.

 

The 64,000 $ question is when will the list of high risk products appear ?. Many people have attempted Procedures such as described in the FDA Draft and found it's not so easy, particularly with respect to weighting and justifying the scoring method.. Just like the USP's Procedure for Food Fraud -  superb presentation but not yet a practical methodology to be routinely implemented.


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Kind Regards,

 

Charles.C


#9 mgourley

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Posted 04 May 2016 - 09:04 AM

Charles,

Patience my good man. FDA has said that there will be guidance documentation forthcoming. 

There just is no timetable for its publication. :shades:

 

Marshall


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