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Is positive release for incoming ingredients required?

raw material positive release

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#1 Ken Bookmyer

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Posted 25 September 2017 - 02:30 PM

We purchased the IFSQN package and the draft document for 2.4.4 mentions positive release for ingredients. I read the SQF code and don't see positive release as a required element of it. I need to get certified and I don't want to get beyond the required elements until after we cross the first hurtle. 

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#2 FurFarmandFork

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Posted 25 September 2017 - 05:34 PM

Positive hold for both incoming and outgoing materials is not a strict requirement for SQF. It comes down to the amount of risk your company wants to assume and the risk of releasing a non-conforming product.

 

In general, if you plan to test your incoming materials for a food safety concern, that's fine as long as you're prepared to recall in the event of a positive test result. That tends to be the hiccup, as you will tend to get pushback from other departments when the consequence is recall vs. destruction. If you believe your company is prepared to accept the consequences of "bad" test results, then go ahead and pre-release items that are likely to have no problem.


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#3 Ken Bookmyer

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Posted 25 September 2017 - 07:38 PM

Thanks, none of the ingredients we use are likely to be considered even medium risk. They are all naturally resistant to pathogen growth and processed to remove any physical hazard, so I feel comfortable without a release on the them. We are moving into areas where that may not be the case in the future but right now I need to get us up and running and skipping an area that isn't mandatory will help.

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#4 Charles.C

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Posted 26 September 2017 - 05:17 AM

Hi Ken,

 

Can try these threads for some background -

 

http://www.ifsqn.com...release-policy/

http://www.ifsqn.com...elease-program/

 

also possibly depends on definitions, eg terms like "Positive Release (PR)", "Product", "Compliant"

 

In SQF (and BRC) "PR" appears to be principally applied to [Finished] "Products", eg in SQF Guidance 7.2 -

 

The  product  release  procedure  not  only  applies  to  positive  release  of  compliant  products,  the  supplier  must  also outline the procedure for releasing products from quarantine or hold status.

 

(Regarding "Product", I deduce from SQF Code text such as 2.4.8 and elsewhere that "Product" in SQF typically means "Finished Product" unless otherwise stated.)

 

I'm unclear how you can freely "release"  ingredients which are found not compliant with their documented specifications but this may depend on the actual items under discussion.

 

 "Look before you Leap". ?

 

PS - I noticed this SOP in the Literature -

 

Attached File  SOP, SQF - hold-and-release-of-nonconforming-product.pdf   155.54KB   27 downloads

 


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Kind Regards,

 

Charles.C


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#5 Tony-C

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Posted 26 September 2017 - 06:10 AM

Hi Ken,

 

Section 2.4.4 is the Approved Supplier Program (Mandatory), requirements include:

2.4.4.1 Raw materials, ingredients, packaging materials, and services that impact on finished product safety shall meet the agreed specification (refer to 2.3.2) and be supplied by an approved supplier.
2.4.4.3 The responsibility and procedure for selecting, evaluating, approving and monitoring an approved supplier shall be documented and implemented.
 
Section 2.4.4 should be considered in conjunction with 2.3.2 Raw and Packaging Materials:
2.3.2.4 Raw and packaging materials and ingredients shall be validated to ensure product safety is not compromised and the material is fit for its intended purpose.  Verification of raw materials and ingredients shall include certificates of conformance, or certificate of analysis, or sampling and testing.
 
The procedure QM 2.4.4 Approved Supplier Program states: A documented risk analysis of each raw material or group of raw materials to identify potential risks to product safety, integrity, legality and quality is carried out by the Food Safety Team taking into account the potential for:
Microbiological contamination
Chemical contamination
Physical contamination
Allergens and possible allergen contamination
Possible substitution or fraud
Effect on product quality
Consideration is given to the significance of a material to the quality of the final product. The results of the risk analysis dictate the criteria for supplier assurance, testing and acceptance of raw materials and procedures for supplier monitoring.
 
In the package there is also a Supplier Risk Assessment folder that may be useful. The package is generic and intended for a broad range of risks, As FurFarmandFork has indicated low risk materials may be accepted by COA/COC and a goods in inspection.
 
We do include technical support via email or Skype with the package which is available to provide guidance and answer any specifics you may have. I will PM you our contact details.
 
Kind regards,
 
Tony

 


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