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Charles Chew

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Posted 17 June 2005 - 05:57 AM

Guidance to the use of the ISO 22000 standard indicates that Top Management should ensure that the org. establishes and maintain procedures to identify potential for and respond to potential accidents, emergency situations and incidents.

The Org. is also expected to review and / or revise where necessary its prepareness and response procedures after the occurence of an actual accident or emergency situation.

How far should we cover and in the case of BRC-Food where we address emergency incidents supported perhaps by contamination incident procedures, ISO 22000 appears to be very implicative particularly on potential situations such as bio-terrorism issues.

What are the programs, procedures and response models that we need to put in place under this requirement.

As ISO 22000 is expected to be formally published soon, it is inevitable that we need to take view of this impending standard some what seriously and hold a good grip of it to keep. This is the only forum that I am aware of that has so far make a decent effort in keeping the public in touch with this standard.

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Simon

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Posted 17 June 2005 - 10:26 AM

Guidance to the use of the ISO 22000 standard indicates that Top Management should ensure that the org. establishes and maintain procedures to identify potential for and respond to potential accidents, emergency situations and incidents.

The Org. is also expected to review and / or revise where necessary its preparedness and response procedures after the occurrence of an actual accident or emergency situation.

How far should we cover and in the case of BRC-Food where we address emergency incidents supported perhaps by contamination incident procedures, ISO 22000 appears to be very implicative particularly on potential situations such as bio-terrorism issues.

What are the programs, procedures and response models that we need to put in place under this requirement.

Hello Charles, this is an interesting area; let's take a look at some possible emergency situations:

Acts of God - such as fire, earthquake, tsunami, hurricane, flooding etc.

Accidents - such as fire, explosion, plane crashing on the plant etc.

Wilful Acts - such as bombs, toxic poisoning, terrorist threats and acts, giant three headed ‘factory eating' sea eel etc.

It is easy to become complacent and think ' that will never happen to us', but most of them (apart from maybe the sea eel) have happened and will happen again…and therefore it could be you.

You can prevent and minimise the opportunity for some emergencies to occur (mostly the ones committed by people) by having secure premises e.g. security guards, keypad entries, self closing doors, strict entry control procedures etc. You can also have in place sprinkler systems, fire drills and direct lines to emergency services such as the police, ambulance and fire service.

However some things are totally beyond our control.

The likelihood of a catastrophic emergency occurring is very low but the severity would be devastating and could completely end our ability to produce and supply goods. For the things we cannot prevent or control all we can do is consider what could happen very carefully and have systems and procedures in place for dealing with the immediate emergency and ensuring we get back to some sort of normality ASAP.

Procedures should cover what to do in the case of an emergency and who is responsible for what, you may have different levels of emergency and response depending on the severity, which would probably be based on the ability of the business to continue operating and supplying safe and legal products - these levels of emergency would be specified in the procedure.

Where possible you could endeavour to make mutual partnerships with competitors to ensure that you cover each others butts in an emergency and ensure some continuation of supply to customers. This is especially important to customers where you are currently the sole supplier. Obviously this is easier said than done because of things like tooling, raw materials etc. however, it should be explored. As well as protecting our customers supply line we should ensure that our suppliers are prepared for an emergency also.

People should be trained in what to do and when and just like Product Recall there should be an annual test of the emergency procedures, the results of which should be fed back into the loop to improve the emergency procedure.

As ISO 22000 is expected to be formally published soon, it is inevitable that we need to take view of this impending standard some what seriously and hold a good grip of it to keep. This is the only forum that I am aware of that has so far make a decent effort in keeping the public in touch with this standard.

It is Charles. I think so far it has been the ‘hawks' sorry consultants who have shown an early interest in the Standard and they are now busily preparing their portfolios. Once the Standard is published and users begin to visit the SDF for advice I'm sure the ISO 22000 forum will get busy again - and the hawks (and three headed eels) will no doubt return.

Cheers,
Simon

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Charles Chew

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Posted 19 June 2005 - 11:13 AM

Simon,

My mate and I discussed this issue over a cuppa the other day and thought that in light of the ever growing fear of "unforseen hazards" e.g. through a "taliban" sabotage or osama-type of emergency-crisis (was not thinking of the "factory eating eel" which undeniably could happen if there is known "giant killer squids", item 5.7 could well be an important area of compliant when placed "protect-on-demand basis".

It is an incredibly huge area but nevertheless needed to be narrowed down according to the nature of the specific production facility and food chain including transport and distribution.

To split it down the middle, we have "Internal Food Chain" and "External Food Chain" - imaginations can go wide here. You define the contingent and emergency risks and how you wish to repsonse to it.....including the response time. Of course, the longer the response time, the disastrous end result will be further heightened.

Maybe, its a good idea to first draw some comments from the forum members on what are the "simplest" of emergency risks we can think of within our own internal food chain BEFORE moving on to the outer circle of the "unknown universe" where "No Man Has Ever Been Before"

Note: I am ever present of the fact that the "hawks" are out there preparing for the next kill..........its already happening where I come from. Would be victims may just turn the table around by leveraging with knowledge gained from here. Getting in is a great start.

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Charles Chew


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Simon

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Posted 19 June 2005 - 07:44 PM

My mate and I discussed this issue over a cuppa the other day and thought that in light of the ever growing fear of "unforseen hazards" e.g. through a "taliban" sabotage or osama-type of emergency-crisis (was not thinking of the "factory eating eel" which undeniably could happen if there is known "giant killer squids",  item 5.7 could well be an important area of compliant when placed "protect-on-demand basis".

Yeah my mistake was discussing the issue with my mate over a bottle of single malt scotch whiskey. :beer:

To split it down the middle, we have "Internal Food Chain" and "External Food Chain" - imaginations can go wide here. You define the contingent and emergency risks and how you wish to repsonse to it.....including the response time. Of course, the longer the response time, the disastrous end result will be further heightened.

So is this more to do with deliberate acts - rather than so-called 'acts of god'?

Regards,
Simon

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Posted 20 June 2005 - 04:22 AM

Simon,

On a sober note, its all about "emergencies and unforeseen issues"...........and I guess, "Acts of God" and other "Spiritual Interventions / Interferences" are a wider scope of concern as well.

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Charles Chew


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Posted 20 June 2005 - 08:11 PM

If you are talking 'internally' most emergencies that could affect the safety of food for consumption should be covered by the HACCP plan and Product Recall Procedure. If we assume our factory is secure from intruders there could only be deliberate acts of sabotage or tampering of our food products by our own employees, which is very difficult to account for. In addition to this are the disasters, accidents, and acts of god that could occur and impact on our ability to supply.

Am I on the right page? :dunno:

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Simon


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Charles Chew

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Posted 21 June 2005 - 06:22 AM

Simon,

We are really on the same page all this while as the area of coverage is as wide as you can imagine.

If you take a step back, Draft ISO 22K mentioned 5.7 as "Contingency Preparedness...." while FDIS was revised to "Emergency Preparedness......"

To jusify item 5.7, it has to take into account the dynamic exposure of food safety impact from both external and internal interventions. Sure, Product Recall is one of them and so is, Power Outage, Walk-Out (stirikes), etc.

Issues that could be of concern are likely to be work-in-progress products, storages, sustaining customer satisfaction..........a whole lot more.

I then to believe that item 5.7 requires us to establish and document procedures for such emergencies and to demonstrate that there has been documented preparedness and control measures in place.

:dunno:
Charles Chew


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Posted 23 July 2005 - 08:50 AM

Charles,

I've attached a Business Continuity Questionnaire that was recently posted elsewhere on the forums. If you turn the questions into requirements for procedures it can provide a useful list. Admittedly it doesn't tell us what an incident is but it may help us to recover from one.

Attached File  Business_Continuity_Questionnaire.doc   62KB   877 downloads

Has anyone actually developed a holistic crisis management plan?

Regards,
Simon


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Charles Chew

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Posted 24 July 2005 - 12:57 PM

I've attached a Business Continuity Questionnaire


Simon,
This plan appears to be more suited for ISO 9K. Emergencies are more towards "unknown hazards" that needed suitable responses within a desirable time frame.

Have a look at attachment on one of the responses under ISO 22K

Charles Chew

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Simon

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Posted 25 July 2005 - 07:14 AM

Simon,
This plan appears to be more suited for ISO 9K. Emergencies are more towards "unknown hazards" that needed suitable responses within a desirable time frame.

Have a look at attachment on one of the responses under ISO 22K

Charles Chew

<{POST_SNAPBACK}>

If I were a customer of yours Charles I would be seeking assurance from you that your system had contingencies for recovering from emergencies at three levels:

1. Is the product / batch you made safe?
2. Can you continue to supply safe food?
3. Can you continue to supply at all?

Maybe this is beyond the scope of ISO 22000; perhaps you need another bolt on system for managing your business?

Regards,
Simon

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Charles Chew

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Posted 25 July 2005 - 09:16 AM

1. Is the product / batch you made safe?
2. Can you continue to supply safe food?
3. Can you continue to supply at all?

Simon,

These are what any FSM Systems are expected to deliver as the bare minimum. If you cannot fulfill any one of the above, the criterion is not met.

I am afraid "Emergency and Preparedness Procedures" are above all of the listed as described in the ISO 22K.

My question to you is:
What would you do if when you know your food is unsafe?


Charles Chew

Edited by charleschew, 25 July 2005 - 09:57 AM.

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Posted 25 July 2005 - 11:12 AM

These are what any FSM Systems are expected to deliver as the bare minimum.  If you cannot fulfill any one of the above, the criterion is not met.  I am afraid "Emergency and Preparedness Procedures" are above all of the listed as described in the ISO 22K.

So are you saying that ISO 22000 requires you to cover both ‘known' and ‘unknown' hazards whether they are directly considered food safety issues or not? My confusion exists because you said earlier the business continuity questionnaire I posted was more towards ISO 9000 - surely the items in the questionnaire are generic to most businesses for ensuring continuation of supply with the extra special recovery details determined by process, product etc.

I've got to admit to not studying the ISO 22000 Standard yet. :oops:

My question to you is:
What would you do if when you know your food is unsafe?

Do you mean me as the supplier? If so would I invoke the crisis management procedure? :uhm:

Regards,
Simon

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Charles Chew

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Posted 25 July 2005 - 01:49 PM

If so would I invoke the crisis management procedure?

Simon,
Yes, this is what is expected of you to do in a FSM System BUT the question now is do you have written procedures in handling these sorts of "identified" emergencies in your ISO 22K QMS (thats what ISO 22K is asking you to establish).

I know most would have procedures for P. Recall, Glass Breakages, Sharp Objects ....these are just some of the responses that need to be dealt with.

Do you have established procedures for Bio-Terrorism, Power Outage, HACCP Plan Breakdown both at your own premise and your Approved Suppliers etc, etc
If you refer to the FDIS, IMO this is what is required.........known and unknown!

Better still, ISO / TS 22003 would provide the explanations. IMO, ISO 22K is a very deep program

Cheers
Charles Chew

Edited by charleschew, 25 July 2005 - 01:52 PM.

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Posted 25 July 2005 - 08:35 PM

Do you have established procedures for Bio-Terrorism, Power Outage, HACCP Plan Breakdown both at your own premise and your Approved Suppliers etc, etc
If you refer to the FDIS, IMO this is what is required.........known and unknown!

<{POST_SNAPBACK}>

Where do you determine the risk for these items - is it in the HACCP plan?

Regards,
Simon

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Posted 26 July 2005 - 03:24 AM

U.S. Food Supply Vulnerable to Terrorist Attack, Experts Say

Source of Article: http://www.rednova.c...ource=r_science

21 July 2005

NEW ORLEANS -- America's complex food-supply system remains vulnerable to a terrorist attack, government and academic experts say, but they are embarking on a campaign to shore up some of the vulnerable spots.

Robert Buchanan, a senior science adviser with the U.S. Food and Drug Administration, said mounting an attack on the food system would not require a great deal of knowledge or sophistication, and the result could be catastrophic.

The number of biological or chemical agents that could be used in an attack "is huge," Buchanan told the Institute of Food Technologists, which is holding its annual convention here this week. "I'm amazed how many agents are available over the Internet."

Under a January 2004 presidential directive, the government is trying to identify vulnerable spots in the food-system infrastructure and also seeking help from American universities to develop inexpensive but accurate rapid diagnostic kits, Buchanan said.

The FDA is asking academics and industry professionals to identify highly vulnerable spots that terrorists might exploit _ on the farm, in machinery where food ingredients are mixed together in processing plants, and in the transportation system.

Buchanan urged food scientists to use greater caution in publishing in scientific journals information on making or altering dangerous pathogens.

"There's a level of detail we can be cautious about," Buchanan said, contending that scientific papers shouldn't give a road map to terrorists. "I'm not talking about major changes" in the exchange of scientific information, he added.

Francis Busta, director of the National Center for Food Protection and Defense at the University of Minnesota, said academics and food-industry professionals need to concentrate on developing new and cheap detectors for dangerous food pathogens _ particularly anthrax, botulism agents and ricin, which is a toxin easily made from castor beans.

Busta is heading a team of Institute scientists that has been examining food-industry vulnerabilities and this year prepared two classified reports for the FDA. Busta said the IFT will convene a two-day conference of academic experts this year to make recommendations for bolstering security.

He said the sort of pathogen that terrorists are likely to exploit are colorless, tasteless, odorless and resistant to heat and chemicals used when food is cooked or processed. "I'm not going to give the specific vulnerabilities," Busta said.

Busta said that in the wake of 9/11, many large food processors launched aggressive campaigns to improve security at their plants, installing fences and security systems where ingredients are mixed or vulnerable to tampering.

"But some said they weren't going to do anything until something happens _ the classic head in the sand," Busta said. "The further we get from 9/11, the less intense people get."

Cory Bryant, an Institute scientist working on the project, said the food supply is regarded as a potential terrorist target because an attack would have widespread effects on the U.S. population and economy.

"We all eat," Bryant said.

In addition, about 22 percent of the U.S. work force is connected to the food and restaurant industries. Bryant said one likely sign of an attack would be an increase of illnesses among food workers.

He said some experts concluded that prime targets for bioterrorism could be large food processors, which mix huge batches of food from different ingredients each day and transport products that are expected to be eaten quickly and have a short shelf life.

Bryant said academic researchers also are exploring cleanup and recovery issues, involving how the food industry can continue to feed the U.S. population after an attack.
Source: Scripps Howard


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Posted 27 July 2005 - 07:32 AM

Thanks for pointing us to the article Charles. :thumbup:

So are all the emergency situations prerequisites in ISO 22000? Or does the HACCP team also have to consider/identify other emergencies and carry out a risk assessment of them? :dunno:

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Simon


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Posted 27 July 2005 - 08:51 AM

does the HACCP team also have to consider/identify other emergencies and carry out a risk assessment of them?


Simon, This is a very good question. Known hazards "within the premise" i.e. glass breakages etc can be identified, pre-empted and if not procedures to deal with in the event of incidence must be documented.

Known hazards that are likely to occur "beyond the premise" should be identified and procedures documented.

These are GMPs and therefore risk assessment is largely on root cause analysis to establish whether product should remain in commerce or recalled or reworked etc

Charles Chew

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Posted 27 July 2005 - 12:40 PM

A lot of responses have linked ISO9K with the response process, you may find more help looking at the 14K guidance as this has the same clause for response.

I work as a third party auditor (but not a consultant)

If I was auditing your company I would expect to see that events such as bioterrorism to be captured by you verification system (7.8 of 22K).

emergency situations I would be looking at are failures of verification systems (metal detection, labratory testing equipment), failures in control equipment (refrigerators/pasturisers etc) and the so called acts of god (leaking roof, flooding etc).

Cataclysmic events such as a Tsunami or the production plant burning to the ground don't deserve much consideration because it is likley that there will be more serious problems than the food safety for the company.

Finally it is important in the IT age that the IT systems are included in this area, if your batch traceability and/or safety test results is maintained by a database then the computer getting a virus could be as harmful to the company as rats in the warehouse even though it doesn't have a direct impact on food safety.

Just an interesting asside, currently the standard doesn't require you to test or review these procedures so in theory you can make up whatever you want and as long as you don't actually have the emergency and the procedure fails you are in conformance with the standard. :dunno: (look out for this changing to bring in a requirement for testing the procedures periodically in the final edition)


"arguing with an auditor is like wrestling with a pig in mud, eventually you realise that the pig enjoys it"

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Posted 27 July 2005 - 12:59 PM

Hi James,

Thank you for adding gravity to the deep implicaitons of clause 7.8 ISO 22K and as we move forward into the potential of deliberate and ill-intent contamination of foods, clause 7.8 will likely to play a much wider and serious role in time to come as specific responses become more apparent.

Concur that the current FDIS does require some specific verifications but in these changing times, who knows.

Charles Chew


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Posted 23 September 2005 - 03:00 AM

A guideline by FDA from the aftermath of Katrina.

Relevancy to ISO 22000 - "Emergency preparedness and Response" to affected product disposal. You can go to the FDA Web Site for more infor if you wish.

Have a look!

Charles Chew

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Posted 05 November 2005 - 06:05 AM

Brings to mind the potential danger of food safety implications from the "bird flu" disease thats lurking practically everywhere today. Its a global situation and if the impact is significant enough, not only will we have a pandemic issue in hand but a lasting global economic recession and pandamonium.

Right now, blird flu has an impact on humans and humans work in process environment. Is this relevant? IMO it is.

Downsizing the issue from global to regional and to national level.....and to a smaller scale i.e. within your own organization, we would certainly need to look at the level of our contingency preparedness and repsonse programme NOW with regards to such an event breaking out in your region as far as YOUR FACTORY PREMISE and END PRODUCTS are concerned.

ISO 22000 encourages us to be pro-active and essentially, you would need to look at making such contingency plans and if you have made such a plan, tell us about it.

Oop! :doh: bird flu is about infiltration by birds. Have you considered reviewing your pest control program on birds.

Charles Chew


Cheers,
Charles Chew
www.naturalmajor.com

Franco

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Posted 23 January 2006 - 01:47 PM

What are the programs, procedures and response models that we need to put in place under this requirement.


ISO / TS 22004 states that
5.7 Emergency preparedness and response
The organization should be aware of potential emergency situations which may include, for example, fire,
flooding, bioterrorism and sabotage, energy failure, vehicle accidents and contamination of the environment.


The next question is: what does "organization should be aware" mean ?

Edited by Franco, 23 January 2006 - 01:48 PM.

An ancient Chinese proverb teaches that the person who waits for a roast duck to fly into their mouth must wait a very long time.

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Posted 23 January 2006 - 09:45 PM

The next question is: what does "organization should be aware" mean ?


Hey dude it just means you gotta get wised up! :cool:

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Franco

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Posted 24 January 2006 - 06:24 AM

Hey dude it just means you gotta get wised up! :cool:


What should an auditor look for ? How can it be assessed ? :dunno:

An ancient Chinese proverb teaches that the person who waits for a roast duck to fly into their mouth must wait a very long time.

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Posted 24 January 2006 - 08:27 AM

Hi Franco,

From my recent ISO 22K Pilot Scheme Audit experience, the Auditor would basically require you to mention policies and procedures on issues that are already outlined in the standard (i.e. such as.......) but you may as I had further included the issue of "loss of control on process equipment" etc and in my case, I had to add "earth tremor" including "tsunami" etc PLUS whatever you think could possibly occur in the area that your facility is located. Course this could be a nuisance as it may become an endless list (if you think hard enough of such unwanted events that may come your way)

Well - if you are in or near Turkey - you might want to consider a pandemic bird flu situation :lol:

You are right - such a damn nuisance that auditor may just have a field day on this one BUT you may want to add a generic clause "any unknown circumstances that warrant immediate responses" shall be dealth with through an immediate emergency meeting blah! blah! blah!................some thing like to that effect. You know what I mean :thumbup:


Cheers,
Charles Chew
www.naturalmajor.com



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