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Dutch777

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Posted 04 May 2018 - 11:14 AM

Hi all,

 

I'm new here on the forum and tried to look for this topic, but could not directly find relevant topics. 

My apologies, when I overlooked something.

 

I am an intern for a small vegetable processor, which wants to make the swith from Dutch HACCP (which I believe is similar to normal HACCP) to FSSC 22000. They hired me to write most of the procedures and recommend changes. 

 

I have checklists for the differences between HACCP and what the current FSSC 22000 certification entails.

However, I am lost how to start writing the procedures; is it necessary for every PRP? For example, Construction and Layout.

Do you have to describe where the company is established and such?

 

Thank you in advance for your help :biggrin: 

 

Regards,

Simone



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Posted 04 May 2018 - 01:02 PM

Hi Simone

 

Yes to all of above. For each PRP, PLUS the basic HACCP plan, there needs to be a policy/procedure/SOP/record 

 

It's best to try and use the same language as the standard when preparing documents. Make sure that you have document control in place and a change log where you put ALL documents (policy, program etc. ) including a version number, date and reason for the change.

 

What's your previous experience?  This is a big task ahead


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Dutch777

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Posted 04 May 2018 - 01:14 PM

Hi Simone

 

Yes to all of above. For each PRP, PLUS the basic HACCP plan, there needs to be a policy/procedure/SOP/record 

 

It's best to try and use the same language as the standard when preparing documents. Make sure that you have document control in place and a change log where you put ALL documents (policy, program etc. ) including a version number, date and reason for the change.

 

What's your previous experience?  This is a big task ahead

Hi Scampi,

Yes I am writing all documents in Dutch. I am planning on creating a master document list, but since I am only starting out, I am not there yet.

 

My previous experience has been with HACCP and writing some SOP/procedures, and I am aware of the size of the task  :headhurts:

Luckily, when I get stuck, my boss will call in an advisory bureau, but for now I am the cheaper option.

 

So what would you describe in the prp of construction and layout?



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Posted 04 May 2018 - 01:28 PM

I don't have the scheme in front of me for reference, but you should included that food contact surfaces are approved as such, walls floors and ceiling are capable of being cleaned repeatedly, the facility design allows for physical separation to keep the product cleaner as it moves through the process. Equipment has passed some sort of sanitary design checklist (i.e. if not made by a known manufacturer, that it was designed to be easily disassembled, cleaned and sanitized.

 

I hope that helps

 

Mine looks like this, but i'm SQF

Materials and Surfaces

All food contact and non food contact surfaces are of materials that do not pose a food safety risk to the product.    Product contact surfaces on site include stainless steel and other acceptable materials. 

 

Floors, Drains, and Waste Traps

Floors are of poured concrete, and easily cleanable. 

There are floor drains located in the facility.   The floor is sloped toward the drain(s).   Overflow is directed to the floor drains.  Water is used in the process, and for cleaning and sanitation. 

No waste traps are located inside the facility or near entrance(s).

 

Walls, Partitions, Doors and Ceilings

Internal walls and ceilings are covered with a light coloured, cleanable surface. Door and window frames are of solid construction and provide a good seal.    Ceiling and overhead structures will be visually inspected at least annually and cleaned as needed so as not to affect product, ingredient or packaging. 

Wall to floor junctions are concrete to concrete block and not coved.   They are readily cleanable. 

 

All piping will be visually examined annually at minimum to ensure no leaks or excessive accumulations of dust, and are cleaned annually.  Ducting, conduit and pipes are not recessed into walls or ceilings.  An annual inspection and cleaning protocol is in place to ensure ducting, conduit and overhead pipes do not contribute to a potential food safety hazard.  There are no lines/pipes carrying waste of any kind over processing/handling or storage areas

 

Doors and window frames are of solid metal construction. Policy based on a risk assessment of our glass breakage history states that if we ever have a large glass incident operator shall dispose of all exposed product.  Windows are located on all four walls of processing room. There are 3 small windows in the overhead door on the west side, 2 windows on the North side behind the cooling tunnel at eye level, 1 window at the top of the wall on the east side to the outside and one window that is to the lab as well as a window in the lab that opens to the outside.  There is also glass in the door that goes into the spice room and 3 small windows on the south side in the overhead door and a window in the man door on the south side as well as a window just to the left of the man door when entering the room.   See 11.7 Separation of Functions for control of foreign matter.   All glass is listed and inspected. 

 

Stairs, Catwalks and Platforms

Stairs and platforms present in the production areas are not constructed of materials that would contaminate the product and are cleaned as per sanitation schedule.  No product, food contact material or ingredient is stored under the stairs.

 

Lighting and Light Fittings

Adequate lighting is provided in all areas of the facility.   Annually, lighting levels will be checked in various areas and recorded on the REC 020 Lux Levels Record. 

All lights throughout the facility are shatterproof or have protective covers and are inspected regularly and cleaned as per the sanitation schedule.   

 

 

 

Inspection Area

Jars are inspected at the end of the processing line for coding of date and batch number. There is suitable lighting and easy access to hand washing facility, and is cleaned as per the sanitation schedule. Any waste generated as a result of inspection tasks shall be disposed as per waste program.       

 

Dust, Fly and Vermin Proofing

All windows, ventilation openings, doors and other openings through the exterior walls are sealed and/or screened to prevent pests and dust from entering the building. All man-doors are self-closing.    

 Employees are to enter at the authorized entrance door on the west side of the building that is closed but unlocked during operations. It is the door across from the office that has the window in it; the other man door across from the office will remain locked and is used as an emergency exit only as it opens directly into the processing area.

There are no bait stations using poison bait on the interior of the building.   Live traps are present on the interior.  Insect control devices are also present inside and located so as not to affect product.   See the pest control program for details, and the map for location of all devices. 

 

Ventilation

Adequate ventilation for this operation is provided throughout the facility.

Cooking operations are limited to the pasteurization line at this facility.  Adequate fans and vents are provided to remove heat and odour from this room and are exhausted to the outside.   The exhaust is screened where it passes through the exterior wall to prevent entry of pests.   Condition will be checked during the monthly REC 021 External Monitoring.    

 

Equipment, Utensils and Protective Clothing

See section 2.3 for specifications for equipment, protective clothing and utensils.

 

 All equipment is designed specifically for this process and was not purchased but manufactured from scratch.    Utensils in use for processing are made of appropriate food safe materials.   All equipment and utensils are inspected prior to use for integrity and are cleaned, sanitized and inspected at the end of each work day.   Process equipment is cleaned daily when used in season and inspected for any areas that could pose a food safety risk.

All equipment and utensils are easily accessed for cleaning.   Equipment is appropriate for use and regularly cleaned as per the Cleaning and Sanitation Program and the Daily Pre Operational Inspection Checklist.  Documentation of the Slicers and Choppers inspection will be made on the Batch Sheet when necessary.

Totes are in use for edible material and are non toxic, smooth, impervious and easily cleaned.  Waste containers are in place for spilled materials, edible product debris and garbage.   Waste containers are identified in Spanish and English.  No dedicated cleaning area is required.

Overflow water is discharged to the floor and the drains.

All protective equipment that may be used in the process shall be made from materials approved for direct food contact and are easily cleaned.

Rubber aprons may be worn for certain jobs and are washed and sanitized and hung on the appropriate rack at the end of the production day or at break/lunch.   Racks are located in an area that is close to employee entrance/exit  

All gloves shall be disposed of when they become torn and/or when they become dirty. Gloves shall be disposed of after handling an allergen. Gloves are not reusable and will be disposed of at breaks/lunch and end of production day.

 

Premise and Equipment Maintenance  See POL 029 Premises and Equipment Maintenance Program. 

Calibration

See POL 031 the Calibration Program. 

Management of Pests and Vermin

See POL 032 Pest Control Program. 

 

 

Cleaning and Sanitation

See POL 033 Cleaning and Sanitation Program, and SOP's. 

 

 

 

Corrective Action

  • If any deviation from expected program or procedure is identified, it is to be recorded and corrected as soon as possible.   Management is to be immediately notified of any major or critical finding, and processing stopped until corrected.   The corrective action need to be verified for effectiveness by trained designate.  
  • Minor issues will be recorded on the record in use at the time. 
  • All major and critical deviations are handled according to the Corrective and Preventive Action Program.    

 

Records

  • REC 030 PreOp and Sanitation Log
  • REC 020 Lux level checks
  • REC 038 Interior Monitoring Record
  • Internal CAR

Please stop referring to me as Sir/sirs


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Charles.C

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Posted 05 May 2018 - 11:11 AM

Hi Simone,

 

Actually i always thought Dutch haccp was supposed to be similar to iso22000 which (barring PRPs) is the haccp part of  FSSC22000.

Does Dutch haccp have an item analogous to the infamous OPRP ? If so you are off to a flying start !.

 

You will need to study the detailed PRP document for fssc22000 which is iso22002-1.

 

For BRC, I have never offered such magnificent descriptions as given in Post 2 but I have no experience for fssc22000.

(here is one PRP-ish collection from cfia -

http://www.inspectio...3/1352824822033

 

One common procedure for GFSI-recognised  standards is to initially prepare a so-called  "Quality  Manual" which cross-references things like PRPs (documented as per requirements of iso22002-1), the latter being compiled/detailed in a separate manual. Other approaches can also be used since the chosen layout/format is optional.

 

Examples for iso22000 Quality Manual and generic examples for SOPs for many typical PRP items are available on this forum however each FS Standard often has some quirks of its own which may demandr some adjustments.

 

Might also note that IFSQN offer a complete/assisted program to implement fssc22000 here -

https://www.ifsqn.co...ation-packages/


Kind Regards,

 

Charles.C


Nina_Mic

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Posted 04 October 2018 - 09:54 PM

I am admiring @Scampi's comment above. We are having a debate about how the policies should read at our SQF-certified facilities. One practitioner believes each program should read only the SQF code, exactly as the code is written. The other believes each program should be the company's actual policy -- what, how, who, etc. Program development seems to be going backward; what has been developed so far is being turned into the SQF code verbatim. The latter is a very quick way to have a food safety program, in a way. It seems to me, however, that requires a lot more explaining and legwork on the day of the audit to prove compliance. 

 

Who can mediate for us? 



Charles.C

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Posted 04 October 2018 - 10:00 PM

I am admiring @Scampi's comment above. We are having a debate about how the policies should read at our SQF-certified facilities. One practitioner believes each program should read only the SQF code, exactly as the code is written. The other believes each program should be the company's actual policy -- what, how, who, etc. Program development seems to be going backward; what has been developed so far is being turned into the SQF code verbatim. The latter is a very quick way to have a food safety program, in a way. It seems to me, however, that requires a lot more explaining and legwork on the day of the audit to prove compliance. 

 

Who can mediate for us? 

 

Hi Nina,

 

You seem to have some confusion regarding the differences between Policy / Procedure.

 

I suggest you sort that out first.


Kind Regards,

 

Charles.C


FurFarmandFork

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Posted 04 October 2018 - 10:09 PM

I am admiring @Scampi's comment above. We are having a debate about how the policies should read at our SQF-certified facilities. One practitioner believes each program should read only the SQF code, exactly as the code is written. The other believes each program should be the company's actual policy -- what, how, who, etc. Program development seems to be going backward; what has been developed so far is being turned into the SQF code verbatim. The latter is a very quick way to have a food safety program, in a way. It seems to me, however, that requires a lot more explaining and legwork on the day of the audit to prove compliance. 

 

Who can mediate for us? 

 

There is no point to having SOP's if it's just copy/paste of the code. Otherwise you could print out a copy of the code and put your letterhead on it and be done.

 

Any controlled documents must be written to help you meet your standards for food safety. It's QA's job to explain to the auditor how your companies policies and procedures satisfy the code, not the other way around.

 

Your two days a year is not more important than the other 363. Write your procedures for the company, not the audit.


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.

Nina_Mic

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Posted 04 October 2018 - 10:22 PM

Thanks FurFarmandFork. I agree with you to a great extent. The company has a great history of written procedures and policies that are reviewed annually while production is down. They are organized more or less to the SQF system, which we find comprehensive.



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Posted 04 October 2018 - 10:29 PM

Say what you do, do what you say, and be able to prove it.

Unless there is some magical requirement to format a document a certain way, it's all a waste of time.

Determine what is required by your standard and address those requirements.

 

I have seen so much time wasted by people arguing what the actual template of a policy or procedure should "look" like, when the real purpose of the document is to ensure people understand what they need to do to ensure that they are producing safe, legal and quality food.

 

Marshall

 



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Posted 04 October 2018 - 10:43 PM

Say what you do, do what you say, and be able to prove it.

Unless there is some magical requirement to format a document a certain way, it's all a waste of time.

Determine what is required by your standard and address those requirements.

 

I have seen so much time wasted by people arguing what the actual template of a policy or procedure should "look" like, when the real purpose of the document is to ensure people understand what they need to do to ensure that they are producing safe, legal and quality food.

 

Marshall

 

Hi Marshall,

 

I believe you have just offered a minimal template for the Factory's "Quality" Policy  :thumbup: 


Kind Regards,

 

Charles.C


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Posted 04 October 2018 - 10:58 PM

Charles, 

Perhaps, but it also goes for formatting paper.
 

Purpose:

Scope:

Responsibility:

Procedures:

Corrective Action:

 

etc....

 

If nobody reads the things, they are worthless, unless the person that wrote them is particularly proud of how they look  :rofl2:

Marshall



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Posted 04 October 2018 - 11:05 PM

To (recently) answer my own Post 7 -

 

https://www.ifsqn.co...th/#entry124014

 

(There are many other related threads of course)


Kind Regards,

 

Charles.C


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Posted 05 October 2018 - 12:35 AM

Charles, your interpretation of my post is most perplexing! And really not the issue at all.

Mgoumley, thanks. Our documents are used by employees at all levels, and during production they are seasonal, which is one reason why they are so important. We generally use a format as you wrote. My point is that the “programs” are only useful if they have substance, and not just some code formulation - which in many cases, does not even apply.



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Posted 05 October 2018 - 12:39 AM

Charles, your interpretation of my post is most perplexing! And really not the issue at all.

Mgoumley, thanks. Our documents are used by employees at all levels, and during production they are seasonal, which is one reason why they are so important. We generally use a format as you wrote. My point is that the “programs” are only useful if they have substance, and not just some code formulation - which in many cases, does not even apply.

 

Hi Nina,

 

Sorry you think i misunderstood yr Post.

 

I hope the detailed examples in my Link showed you a (generic) way to go.

 

PS - Do note that this thread was oriented to FSSC22000.

 

Regarding the << We are having a debate about how the policies should read at our SQF-certified facilities >> I suggest you  maybe open a new thread in the appropriate Forum and post the specific text for comments.


Edited by Charles.C, 05 October 2018 - 12:48 AM.
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Kind Regards,

 

Charles.C




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