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11.7.5.7 Control of Foreign Matter Contamination

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Chippy

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Posted 25 April 2017 - 06:48 PM

I have a question for a knife and cutting instrument control policy.

Our consultant wrote our Foreign Material Contamination Program and this is the knife policy:

 

"Knives and cutting instruments used in processing and packaging operations are controlled, kept clean and well maintained. 

As knives get dirty during the process, knives are cleaned. Typical cleaning occurs at the start of shift, breaks, lunch and end of shift.

Backup knives are availiable in the event of an issue or malfunction. Knives with defects are given to General Manager so they can be repaired/replaced."

 

So I just had my first SQF facility audit and he questioned our policy, then gave us a minor because there is no policy and facility does not monitor knives and cutting instruments in plant.

 

I am trying to come up with a good policy, and control record should be easy enough- we are a small bakery, and there are 3 knives in the mix area and 1 pair of scissors on the packaging line to cut shrink wrap.  

 

We do use metal detection on our packaging line.

 

Any suggestions?

 

 



FurFarmandFork

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Posted 25 April 2017 - 06:53 PM

You already have a policy, you copied it above. Minors are for lack of verification/enforcement.

 

If you have a daily pre-op, walkthrough, or monthly GMP audit, include a "knife check" on one of those internal audits, and note in your knife policy above that you verify it with one of the checks above. Done.


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

Chippy

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Posted 25 April 2017 - 07:17 PM

I have daily pre-ops per area, and can easily add it to the Daily or Monthly GMP audit.

 

Thank you! I think I was over thinking this... :)



FurFarmandFork

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Posted 25 April 2017 - 07:20 PM

I have daily pre-ops per area, and can easily add it to the Daily or Monthly GMP audit.

 

Thank you! I think I was over thinking this... :)

No problem.

 

IMEX, verification of these types of clauses is almost always tied to an existing audit activity, but auditors want it spoon-fed in your procedure to make filling out the audit form easier. To their point, if they found a broken knife and it wasn't on your procedure that would be an obvious corrective action (oh we weren't inspecting for that).

 

Make your internal audits robust and clarify on the SOP when they're used for verification, next audit will go much easier. :)


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.



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