I am known to be impatient and I have done gap analysis between v6 and 7. Please help yourself to it. if any mistakes are found please let me know.
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Posted by agnes on 13 January 2015 - 02:47 PM
Posted by Charles.C on 30 April 2013 - 03:03 PM
I previously posted a table of various micro. guidelines for food contact surfaces which were mostly issued pre-2000 at this link –
To update the earlier info., the attached excel file presents guideline data I have accumulated for 12 countries issued in the period 2000 – 2012. The compilation demonstrates that for a range of food-related scenarios, some “average” opinions for various (just) cleaned surfaces are –
(a) For Aerobic Plate Count (APC) - the majority of data suggests that, for routine cleaning/sanitising, surfaces typically have maximum APC counts in the range 10-100cfu/cm2 .
(b) For factors like Coliform, (generic) E.coli, Enterobacteriaceae, S.aureus, the expected maxima are, predictably, low, eg 1-10 cfu/cm2, or undetected. The latter requirement also invariably applies for “zero-tolerance” pathogenic microbial species.
Hopefully of some interest. Further input / comments welcome as usual.
Compilation of International Micro. Guidelines for food contact surfaces, 2000 onwards.xls 993KB 3588 downloads
Rgds / Charles.C
Posted by ChocoTiger on 14 July 2015 - 08:37 PM
Here are generic examples of what is needed for 18.104.22.168-22.214.171.124, 126.96.36.199-188.8.131.52, 184.108.40.206, and 220.127.116.11-18.104.22.168. The programs I included in this are the prerequisite programs required by SQF.
Let me know if you need any additional help.
Posted by Wine Gum on 07 July 2015 - 07:22 AM
The PIGS diagram can be used to formulate hazards comprehensively:
P- presence (qualitative and/or quantitative evaluation of presence of hazards)
I-Introduction (Likely occurrence of hazards and severity of their adverse health effects)
G - Growth (Production or persistence of foods of toxins, chemicals or physical agents)
S- Survival (Survival or multiplication of micro-organisms of concern)
Hope this helps!
Posted by mgourley on 21 December 2015 - 10:30 PM
A lot of us have spent many hours writing policy to make sure that what we do is the right thing to do.
A lot of us have made sure that senior management is aware of said policy, and they always have input into the final product. We may go so far as to include approved exceptions.
Once they approve, or give tacit approval, that document states what we do in a certain situation.
That policy, procedure, whatever, then governs how "all" people act when that particular situation arises.
After the fact is not the time for higher ups to decide that the policy does not need to be followed.
Make your objections known, CYA, and move on. You are exactly right. You do not want to set precedent. If you do, what's the point in this rule, or that policy?
Posted by trubertq on 16 July 2015 - 03:39 PM
Since Storage and distribution is not my area I don't feel qualified to answer however I'm sure some one on here can help him.
I'd imagine his customers are looking for verification that his goods haven't been tampered with or substituted, as well as trying to pass the buck of VACCP onto him.....
I'd suggest going to his suppliers and requesting THEIR VACCP risk assessment and then add in his steps in the chain with his risk assessment.
Posted by fgjuadi on 05 March 2015 - 08:41 PM
2.5.3 is your verification schedule, I use this for verification activities - Verify the metal detector is working every 30 minutes . Verify chemical concentration every morning via titration.
Internal audits go on 4.5.2 (Validation schedule)
To make it easier, I combine the 2.5.3 form with 2.5.1 (methods and responsibilities) and 2.5.4 (Verification of monitoring activities) . Basically it's a chart with each monitoring and verification activity, frequency, and responsibility.
So maybe the QA Manager checks the visitor log once a week, but they only conduct a food defense audit annually. The check goes on verification of monitoring, the audit goes on validation.
It can get very "fuzzy" as SQF does not dictate which activity is which. I attached copies of both if it will help - but don't be surprised if you get some different answers.
Posted by Simon on 07 January 2015 - 09:44 PM
Over the last couple of day's it has become clear to me that I have made an almighty cock-up on MOTM and caused Mr I a huge injustice.
Mr I received the most reputation points in December (by a distance), but I did not award him MOTM because I (mistakenly) thought that once a member had won MOTM they could not win it again. When I checked the rules yesterday I realised I was wrong and a member can win it once per calendar year. I thought that was just an unfortunate, but simple mistake I had made.
However, (to my horror) I have now realized that MR I has NEVER won MOTM...I would have put my mortgage on that he had previously won it. To make matters worse it is likely that in previous months Mr I has scored the highest reputation points and won MOTM and I have overlooked him.
The upshot is I have dealt Mr I a real injustice and I am totally at fault and I have passed on my sincere apologies. Thankfully Mr I has graciously accepted my apology.
For the record Mr I did not want me to publish this apology, but I want to because it is right to do so. We have some great members around here and Mr I is one of them.
To this end MR I is the first ever recipient of the annual Member of the Year award. Apart from the title there will be some sort of badge of honour, but I’m working on that…ideas?
Posted by Charles.C on 18 November 2014 - 06:42 PM
Thank you for the detailed reply. Much appreciated. I have expanded a little on some of the comments in yr post / links.
I looked at 2 viewpoints, SQF/BCAS, on some desirable Quality characteristics of Compressed Air -
Purity is defined in the SQF Code (Appendix 2: Glossary) and means the absence of contaminants that could cause a food safety hazard. Pure air means the air is free of risk of cross-contamination to the products. Essentially, the air must not contribute any contamination to the product.
Strictly, use of the word “contamination” as defined by SQF implies that micro.standards based solely on APC limits could be regarded as safety (ie haccp) meaningless. (In a cleanroom context the situation would likely be rather different, limits derived for sterile scenarios are in some articles recommended as not being arbitrarily transferred into the food scene without due caution).
Similarly to SQF, BCAS implicitly defines contaminants in its introduction via -
Contaminants that may be a potential hazard in food for human consumption
In the context of the BCAS COP, hazard is presumably interpreted as safety hazard. On this basis, some difficulties also arise IMO, eg -
"6.2 Microbiological contaminants.
HACCP shall establish the risk of contamination by microbiological contaminants. The level of viable microbiological contaminants in the compressed air shall not be detectable using the method described in clause 7.6." Clause 7.6 refers to ISO 8573-7 test method for viable microbiological contaminant content.
The word "detectable" suggests that any microbial species other than what is (somehow) defined as "natural" to the specific product have zero tolerance. This seems inconsistent with basic haccp principles. Unless a list of accepably non-hazardous species exists ?
This post primarily focuses on micro. “B” factors, the “C, P” hazards are well over-viewed in the SQF faq (see Excel file/sheet3 below) and the Code’s Guidance documents, eg for parts 2/11.
I have done a little background searching regarding standards, micro.species, filters, etc and pasted some selected extracts into the attached excel book (the earlier studies in this area seem a little neglected these days, maybe justifiably ) . Most of the content will probably be (only too) familiar to you of course.
The source files are attached below, keyed to the excel sheet numbers.
added Charles.C, 21082018 - NOTE - URL Link on Sheet 2 of Excel is broken. File is available in Post 15.
sh1 - microbiological air quality.pdf 489.76KB 659 downloads
sh4 - Compressed-Air-in-the-Food-and-Beverage-Industry.pdf 3.82MB 473 downloads
sh4.1 - food industry compressed air systems,white-paper.pdf 196.81KB 335 downloads
sh5 - compressed air in food plants,white paper,Parker Balston.pdf 522.15KB 334 downloads
sh6 - ECFF.pdf 402.26KB 344 downloads
sh7 - tesco standard 2014.pdf 1.15MB 395 downloads
sh8 - air filtration systems.pdf 193.62KB 345 downloads
Rgds / Charles
PS - Two/three of the above documents are already in the thread linked in post 2 above. I re-used them to allow some convenient integration.
The mystery (to me) of why SQF's faq (typically) refers to 0.1micron filters whereas the guidance document specifies 0.01 micron remains. Nonetheless, if the cost/maintenance/implementation factors are comparable (?), the latter seems a logical investment for an easy audit (also see sheet5 in Excel file). For current purposes i assumed the faq is more "maintained" than the guidance and "acted accordingly".
PPS - the extensive collection of TA documents available via Laura's links in previous post(s) are remarkable and valuable. Highly recommended for browsees.
P3S – for those interested here are 5 more links, the first two look at typical air sampling devices/procedures (mainly food/cleanroom respectively), the next 3 focus on micro.aspects/standards as applied in pharmaceutical, cleanroom, sterile work scenarios. The similarities to concepts used (borrowed?) in the food business is clear but there are also significant differences in emphasis, eg the interest in viable/non-viable particles.
Posted by mdean1124 on 18 November 2014 - 02:43 PM
Try using the Human Error Assessment Tool (HEAT) system...
I'm incorporating it into a procedure for my supervisors to use in solving human errors. It comes from a now-defunct company called Talsico that was based in NJ. I don't know who to credit it to other than that.
Employee does not know or does not understand; no training or ineffective training.
c Employee did not have prerequisite qualifications
Provide employee remedial training in prerequisites or reassign employee.
c Employee not trained and qualified on task
Reassign employee until trained. Improve job specifications for task to include the training and qualification missed.
c First time employee performed task
Improve training to include "team paired" qualification with skill check for first performances.
c Employee did not perform task as trained
Reassign employee until retrained and re-qualified with skill check.
c Employee did not understand results of deviation from correct procedure
Improve training to include "scenario" to show results of deviation.
c Training was ineffective
Review and improve skill checks to show training is effective.
Employee made wrong decision or responded with inappropriate behavior or insufficient understanding of result.
c Situation not covered in procedure or training, incorrect logic used
Improve training to include the situation.
c Employee forced to make a decision without supervision input
Improve training to include "scenario" to show variations. Create a "decision tree" or "flow chart" for decision making; with feedback channels and embed it in the procedure.
c Situation unclear as to "normal operation" or "troubleshooting"
Improve training to segregate "normal operation" from "troubleshooting" in the task/procedure.
c Employee failed to make decision based on dilution of responsibility or blind eye ("not my job")
Improve training to include "scenario" for elevation of decision in chain of command.
c Employee did not understand results of decision or failure to make to decision
Improve training to include "scenario" to show results of failure to make decision. Change balance of results. Clarify expectations.
Employee trained, but failed to remember - unable to use skill or knowledge as required (e.g. change in a step/order forgotten).
c Extended time since employee last performed task
Improve training and qualification schedule to reduce extended time between task performances.
c Employee forgot or skipped task steps that are regularly performed without error
Improve work area to reduce interruptions. Confirm working environment is suitable. Create "error-proof" solution (task can only be performed one way).
c No "job aids" or "visual controls" available
Create "job aids" or "visual controls" to support recognition of tasks. Confirm they are readily available and changes highlighted.
Employee knew, but applied incorrect action or information (e.g. slips, wrong outcomes, transcription errors, mistakes).
c Several tasks involved simultaneously, i.e. too many things happening at once
Reduce or balance cognitive load. Re-order or re-assign tasks.
c Not enough resources or incorrect resources to perform task
Perform resource gap analysis and confirm employee has the resources to do the task. Confirm correct items are at hand each time before task begins (e.g. check list).
c Environment disorganized
Improve organization and structure the environment to the task.
c Health or fitness issues involved
Confirm employee is physically fit for the task.
c Data input or design of documentation
Error-proof the input system to prevent mistakes.
c Design of equipment
Error-proof the equipment and usage steps. Upgrade equipment.
c Employee knew the task, but applied the incorrect action/steps (e.g. perceived a color check incorrectly)
Provide symbols/signs/color standards/written descriptions in documentation and job aids.
Employee believed they did task correctly, but end result was variable or not desired outcome.
c Employee relied on "recall" rather than "recognition"
Provide recognition aids rather than relying on recall (e.g. use colors/sounds/symbols/signs). Prevent interference with operators.
c Distractions or disruptions present caused "recognition" failure.
Improve work area by minimizing distractions and disruptions. Isolate or rotate the task.
c Competing priorities caused loss of focus
Separate in-order tasks of a similar nature and of similar priority.
Employee knew, but forgot. Employee missed or did not verify the steps/actions or used wrong item (e.g. left a field blank).
c Employee had no double check of activity/information/results
Improve task an "over check" system. Have a second qualified person verify the activity/information/results.
c Distractions or disruptions present in schedule (break, shift change, holiday) caused failure
Improve task with "attention activators" (e.g. job aids, checklists, colored labels/highlighting, auditory/visual alerts, symbols, signs, form design). Activators must be appropriate in strength, number, and location.
c Not enough time in schedule to complete the task
Restructure or reschedule the type of task to fit time requirements.
c Employee perceived higher pressure than normal or concern due to unusual circumstance
Reduce pressure (e.g. restructure task with more personnel or other resources).
c Items required to complete task not available
Improve task with pre-work check list for required items.
Ineffective Documentation (e.g. batch records, procedures, job aids).
c Documentation not same as actual practice or unclear to employee
Improve document to reflect actual practice. Clarify practices used.
c Documentation missing step(s) or step(s) out of order
Improve document to capture missing steps or reorder steps to reflect actual practice.
c No "job aids" or "attention activators" available
Create a job aid with pictures to accompany the document, or include pictures or "attention activator symbols" in the procedure.
c Terminology of task unclear to employee
Improve document with help and input of end-user employee(s) to confirm clarity of terms.
c Order of action unclear to employee
Improve document with help and input of end-user employee(s) to confirm clarity of order.
Posted by cazyncymru on 23 October 2014 - 01:33 PM
Just released for draft consultation
Posted by cazyncymru on 09 June 2014 - 09:04 AM
I agree with Slab, yes I get paid more, but I don't just deal with Food Safety; under my umbrella comes Environment & Health & Safety!
Food Safety has changed so much in the last 14 years. I think its changed a lot in the last 5 years and if i'm honest, unfortunately (controversial statement coming), not all Quality Professionals have evolved along the way. Some times I see questions on here, and whilst we all have to start somewhere, I despair. I hold my head in my hands, wondering are they really serious or are they trolls! It does make me somewhat reluctant to respond to some post(ers). It would seem that some people are either unable to think for themselves or unwilling to! To be a quality professional you have to have at least a basic knowledge and I know it is difficult, but please if you haven't had a formal education in food safety, at least read a few books and try to learn something!
I think that we have now become more focussed in assessing risks with risk assessments becoming the backbone of a food safety system. As things have evolved, we are being asked to carry out more and more risk assessments; even if it doesn't truly affect our industry (I think Acrylamide!). Thing is, who's teaching people to do these risk assessments? And who taught them? their all subjective! as long as you can justify how you reached that conclusion, who's to say your right or wrong! In the latest version of the BRC, we are asked to carry out a vulnerability risk assessment. Now I work predominantly in Dairy, and I have interpreted this in risk assessing from the farm to the fork, so my study incorporates animal health as well as abuse by the customer. I'm lucky that in a previous life, I was involved in doing Farm Assurance, so I understand about what can potentially happen on the farm; but I bet I'm in the minority. We're asking quality professionals to assess something they may not have any idea about, and this is where mistakes can be made.
I also think we've become inundated with consultants. I probably get a request daily from either a consultant or a recruiter on LinkedIn!! If I need help I will ask, and if I want a new job, I'm sure I can find one myself! ( I've never used an agency to find a job)
So, those are my thoughts, I'm sure many will disagree.
Posted by Guy Spagnoli on 02 May 2018 - 08:29 PM
My name is Guy 'Grundy' Spagnoli
I have been in Quality Assurance since 1979
Worked for Space Shuttle NASA Rockwell
Litton Saudi Arabia Limited
Military and Private sector - hardware/software, Auditor from Suppliers to first article to application ( I call it from Womb to Tomb)
Got into the food side by accident working for Mrs. Fields Corporation for 10 years and now for Thrive Life LLC. so yes, I have 40 years now in QA (boy that went by fast) and have enjoyed the experience and learn something new almost everyday.
Posted by Simon on 08 August 2016 - 07:38 PM
CULTURE is the new buzzword in food safety management circles; it’s becoming a part of GFSI thinking and in fact BRC already have an optional Cultural Excellence module.
In a food safety context ‘culture’ has traditionally been about growing microbes, but now we are talking about working towards a positive organizational food safety culture that influences a business’s compliance with food safety.
Whether positive or negative every business will have a food safety culture, so I thought a poll would be a good place to start the discussion.
Posted by clbernard on 18 August 2015 - 04:11 PM
I also let my suppliers know that what I am asking for is what is considered standard among food processors so that by getting this information ready and made available they will broaden their customer base. I would be suspicious of any company that does not reply to this sort of request. I would also schedule an onsite walk thru if they do not have the basic information that you need. You do not need to import a pest problem with their supplies. I have found that a face to face visit is most helpful when dealing with newbies to this world of audits and required documentation. The onsite allows you to visually confirm that existing programs, even those that are informal are working to control your concerns.
As to the ranking, I would make the first 6-12 months of the supplier program a probationary period regardless of how long the suppliers have been servicing your account. I would include wording in the program that explains that no ranking occurs upon receipt of the information except for approval for probationary status. Then put together your criteria for rating, such as on-time performance, cost, complaint response, etc. and be ready to go.
One word of caution, do not put too much value in feedback from plant sources as to the suppliers performance, in my experience that information is often flawed.
Posted by That Guy on 07 July 2015 - 07:42 PM
I refer to pigs in my HACCP meetings all the time. I have only ever used it when assessing the risk of microorganisms and not other types of hazards.
P = The presence of a microorganism. Consider how you control materials when they enter your facility, is it possible that materials have microorganisms present.
I = Introduction of microorganisms. Microorganisms may not be present when the material is received but after storage and employee handling it possible that microorganisms have been introduced. (dirty hands, roof leaks)
G = Growth of microorganisms. If microorganisms or present or introduced, will it grow? Does it need to be refrigrated to prevent growth? What is the water activity? What prerequisite programs or preventative controls are in place?
S = Survival of microorganisms. Does the production process have a kill step? Is one needed?
My products and processes are very low risk and the water activity is extremely low. My HACCP Team has the bad habit of thinking that microorganisms are not a risk because of this. I frequently have to remind them about pigs.
Our supplier approval program, material inspection and storage procedures reduce the risk of P. Ingredient testing/analysis verifies this. GMP's, internal audits and environmental testing (among other programs) control and reduce the risk of I. Our water activity and storage conditions combined with the nature of our product control G. We do not have a kill step at our facility, but depending on your product and process you may need one.
I do not use PIGS to directly determine if a CP or CCP is required. I only use it to aid in critical thinking and to conduct hazard assessments. How is each letter of PIGS controlled, can we validate why a control would not be necessary? etc..
Posted by SpursGirl on 11 August 2014 - 06:51 PM
I faced a similar issue with decanting into pails from IBC's - and I ended up using grated racks for bucket stands that are kind of like cooling racks for cakes (see picture below). These racks are visually different and in my GMP's these are defined as floor bucket stands only.
Hope that helps!