12 replies to this topic

[cmarchand]

Hi there,

Can anyone help with PRPs ?
I had a customer audit earlier this week, and my prerequisites are not (all) yet in place since I joined my employer (flavor manufacturer) about 6 months ago and nothing was pre-existing. Of course we did not pass their audit and are not approved as a supplier....

Problem (good one in a way since they did not run away and still want to do business with us !...) : As they want/need to place their first order by end of January latest, they want me to have all PRPs implemented and monitored for at least 30 working days before they come to re-audit and approve us as a new supplier....meaning I have this coming weekend to write ALL missing documentation so it is ready to go on Monday....

What is my best approach ?

Thanks a lot for your help or suggestion

Carole

[D-D]

Are you going to work towards a certification - 22000, BRC, SQF etc? If so, get hold of the standard and use that as the driver for how you structure it all. If not, think about using one as a guide anyway and decide what procedures you need, the naming system and create the "blanks" as controlled document templates ready to fill out. You know, Security & Control of Visitors, Maintenance, Hygiene of Personnel, Allergen Control, Waste Management etc, etc (oh and HACCP too...!).
Even if you only put basic stuff in them at this stage at least you can say the procedures exist even if they are only rough draft Version 1. Then do some training against them to get training records signed off.
Hopefully you already do some of the things required even if you haven't called them "PRPs' in written procedures...

[Tony-C]

Hi there,

Can anyone help with PRPs ?
I had a customer audit earlier this week, and my prerequisites are not (all) yet in place since I joined my employer (flavor manufacturer) about 6 months ago and nothing was pre-existing. Of course we did not pass their audit and are not approved as a supplier....

Problem (good one in a way since they did not run away and still want to do business with us !...) : As they want/need to place their first order by end of January latest, they want me to have all PRPs implemented and monitored for at least 30 working days before they come to re-audit and approve us as a new supplier....meaning I have this coming weekend to write ALL missing documentation so it is ready to go on Monday....

What is my best approach ?

Thanks a lot for your help or suggestion

Carole

Hi Carole,

We sell a range of Food Safety & Quality manuals designed to meet BRC, SQF 2000, ISO 22000, FSSC 22000, IFS and HACCP requirements.

All of our manuals come with Free Technical Support to help you tailor the documents to fit your products and process and guide you to certification.

IFSQN Food Safety Manuals can be found here

If you want SQF specific then we sell an SQF Food Safety Management System for Food Manufacturers which can be found here

This system contains extensive documents covering all the relevant clauses in the SQF Code - Module 2: SQF System Elements and Module 11: Food Safety Fundamentals – Good Manufacturing Practices for Processing of Food Products saving you 1,000's of hours writing your own documents.

Also included in this package: Record Templates, HACCP Manual, HACCP Training, HACCP Exam, Validation Records, FSQMS Verification Audit Templates, SQF Code Training Modules, Internal Auditor Training and a Laboratory Quality Manual.

Kind regards,

Tony

[cmarchand]

Thank you D-D

I was aiming at working towards SQF and my goal was to implement all of it, starting of course with training.... It looks like I am thrown into it and have to go through the ''pre-audit'' phase without all the previous steps completed.....

Hi there,

Can anyone help with PRPs ?
I had a customer audit earlier this week, and my prerequisites are not (all) yet in place since I joined my employer (flavor manufacturer) about 6 months ago and nothing was pre-existing. Of course we did not pass their audit and are not approved as a supplier....

Problem (good one in a way since they did not run away and still want to do business with us !...) : As they want/need to place their first order by end of January latest, they want me to have all PRPs implemented and monitored for at least 30 working days before they come to re-audit and approve us as a new supplier....meaning I have this coming weekend to write ALL missing documentation so it is ready to go on Monday....

What is my best approach ?

Thanks a lot for your help or suggestion

Carole

[cmarchand]

Thank you Tony,

I hate to do it that way because I am afraid to just apply key-on-hands procedures and not get the full essence of them, which makes it then hard to train people on something you don't get yourself, but I guess I don't really have a choice, from the time perspective....Will submit to upper management for purchase approval.

Thank you for the links.


Carole

Hi Carole,

We sell a range of Food Safety & Quality manuals designed to meet BRC, SQF 2000, ISO 22000, FSSC 22000, IFS and HACCP requirements.

All of our manuals come with Free Technical Support to help you tailor the documents to fit your products and process and guide you to certification.

IFSQN Food Safety Manuals can be found here

If you want SQF specific then we sell an SQF Food Safety Management System for Food Manufacturers which can be found here

This system contains extensive documents covering all the relevant clauses in the SQF Code - Module 2: SQF System Elements and Module 11: Food Safety Fundamentals – Good Manufacturing Practices for Processing of Food Products saving you 1,000's of hours writing your own documents.

Also included in this package: Record Templates, HACCP Manual, HACCP Training, HACCP Exam, Validation Records, FSQMS Verification Audit Templates, SQF Code Training Modules, Internal Auditor Training and a Laboratory Quality Manual.

Kind regards,

Tony

[D-D]

That one is very clear with what you have to do (and a free download)!
I copy the clause numbers and text etc over to a spreadsheet then add columns that I fill in with the procedure / record reference numbers etc as I draft them. This way you create your index and gap analysis at the same time. Use a nice green color cell shading to indicate what is done as you work your way through.
If for whatever reason you are having audits before you are completely ready, bear in mind that having "something" is better than having "nothing" and can make the difference between major versus minor non-conformance in many cases... Nothing wrong with "work in progress"!
Good luck.

[SQFconsultant]

Sans hiring a consultant on short notice you could download the PDF for SQF Code Version 7 and also the Excel spreadsheet SQF audit version 7 - you'll find the audit format quite helpful and can use the SQF Code manual for backup.

Both documents are available for free at: http://www.SQFI.com

[Charles.C]

Dear cmarchand,

I find this thread rather confusing.

I thought the OP said the immediate priority was to pass a supplier re-audit of PRPs, not SQF. This may not be the same workload at all ?.

If only PRPs, the amount of work remaining, ie opportunity to complete PRPs within 2 days, will presumably depend on how much is missing, details of which are so far unstated as far as i can see , eg how many prerequisites are involved / already operational / what is missing / complex process or not? (I don't quite understand why only the prerequisites are required to be functional anyway for an audit, is the process very simple or ?).

Whatever, best of luck whichever route you select !

Rgds / Charles.C

[cmarchand]

Charles,
The immediate priority is to pass a supplier re-audit of PRPs and HACCP plan, but since I am aiming at SQF certification, I am trying to kill 2 birds at the same time.... maybe I shouldn't....
I have Cleaning / Sanitation, Pest Control, Receiving procedure, Shipping procedure, glass procedure / policy, recall procedure....but I have no layout, GMPs, allergens, maintenance, control of waste, etc
Maybe I am a bit confused about what my PRPs are/should be....
They not only audited the PRPs, they audited everything.
Our process is simple liquid blending for flavor manufacturing.

Thank you for your support

Carole

Dear cmarchand,

I find this thread rather confusing.

I thought the OP said the immediate priority was to pass a supplier re-audit of PRPs, not SQF. This may not be the same workload at all ?.

If only PRPs, the amount of work remaining, ie opportunity to complete PRPs within 2 days, will presumably depend on how much is missing, details of which are so far unstated as far as i can see , eg how many prerequisites are involved / already operational / what is missing / complex process or not? (I don't quite understand why only the prerequisites are required to be functional anyway for an audit, is the process very simple or ?).

Whatever, best of luck whichever route you select !

Rgds / Charles.C

[Charles.C]

Dear cmarchand,

As per previous posts, SQF is attractive but it all depends on yr time constraints. And, IMO, strongly on the level of experience you already have with HACCP, etc, if this is substantial the time will be reduced proportionately.

It sounds like yr audit was for the whole HACCP system which would be normal. This typically requires a composite set of features such as prerequisites, haccp plan, recall program, traceability program, etc. The specifically HACCP part is often based on a generic process in a famous Codex 2003 "Hygiene" presentation which you are probably familiar with.
Standards like SQF are intended to be a Food Safety Management System (ie HACCP + MS) so usually base their haccp portion on the Codex reference (usually with some local variations), add a Management System (eg ISO 9000 concepts) and other items (some HACCP related) which are included within the reference framework of the GFSI organisation.

Accordingly, IMO, matching SQF’s integrated requirements involves considerably more work (Tony's offer is a possible exception) than constructing a straight HACCP system although the HACCP part is a large chunk of any FSMS setup.

Just as an example, a complete, straight HACCP system (Canadian "style", 2007, anyway) is presented in the manual attached below which includes basic prerequisite procedures, forms, etc. Other countries / organisations / standards may have different styles for a straight HACCP system but the majority of content will probably be similar.
 Canada Manitoba HACCP advantage manual.pdf   2.44MB   280 downloads
(previously posted here [post #7], a thread which you may also find of interest )
http://www.ifsqn.com...dpost__p__51464

Rgds / Charles.

[Sharon (Dewsbury)]

Hi There, you have a busy weekend ahead of you don't you!

I have made a list of how I would do it and used Glass as the example. You would need to do this for each of the PRPs
My approach would be to

1. list all the PRP with the controls and monitors. This is mine for example below.
2. Create a policy /procedure for each (e.g. for glass would be how the company removes, substitutes, monitors and reports glass incidents).
3. Create an audit template for those needed.
4. Train those who need it (with records) Train the operators to do the daily glass checks on the high risk items.
5. Keep the records of all monitoring, auditing and reviews.


PreRequisites

 prp1.docx   18.71KB   275 downloads



Glass Policy

PURPOSE: All foreign matter in food is undesirable, butbroken glass is among the most serious hazards associated with food safety.

Thisrequires the company to identify all potential sources of broken glass/ glasslike material, to eliminate wherever practicable those sources and to properlymanage any incidents of glass breakage in an immediate and professional manner.

(NOTE:In the section "Glass Auditing and Recording" and subsequent sectionsof this document, the requirement includes any other fragmentable material suchas Perspex sited on food processing equipment or in the vicinity of rawmaterials, food packaging or exposed product, where fracture could result incontamination of foodstuffs).

SCOPE Raw materials Handling, Preparation, Processing Packaging and Storage Areas

RESPONSIBILITIES

Job Title / Function

Responsibilities / Accountabilities

All Personnel

Technical Manager

Glass audits are planned activities


PROCEDURE

TheTechnical Manager must ensure that regular glass audits occur and that anyglass present in manufacturing areas is eliminated or protected from breakageso as to minimise risk to product.

TheTechnical Manager must ensure that there is a programme in place to eliminateall glass in manufacturing, raw materials storage and product despatch areas asfar as is reasonably practicable.

Allemployees must be made aware of the need to immediately report any incidence ofglass breakage and the requirement to record any such incident.

2. Control of Glass

2.1 The following requirements apply to all areas wherefoodstuffs and packaging are stored, produced or awaiting despatch; engineeringstores and workshops; canteens; locker rooms; lavatories; clothing stores; and any other areawhere engineering, production, despatchand sales personnel may regularly visit while wearing or changing intoprotective clothing. Where requirements apply to the entire site this is madeclear.

2.2 Light fittings must be shielded with a plastic cover or thebulb/tube purchased with an integral shatterproof film. This includeselectronic fly killers.

2.3 External windows and skylights must be eliminated or fittedinternally with a shatterproof film which meets BS6206 or a Perspex sheet orother suitable material. All internal windows (including those in offices anddoors), must be of a Perspex type material or fitted with a shatter-proof filmon both sides, which meets BS6206. Theonly exception to this is armoured glass is fitted to the main windows withinthe packing hall which by there nature are not subject to a high probability ofshatter damage.

2.4 All instrument gauges must be free from glass. Glass incompressed air line filters should be replaced where suitable replacements areavailable.

2.5 Glass mirrors are not permitted on site. Mirrors inproduction offices, and production lavatories etc. must be coated withshatterproof film or replaced with a polished metal mirror.

2.6 Glass containers such as milk or soft drink bottles are notallowed in Production areas or Changing rooms, or Offices in the closeproximity to the factory. Within the canteen Canteen area Glass isrestricted where practicable.

2.7 All notice boards on site must be free from glass.

2.8 Where possible Glass will be replaced by shatterproof plastic material.


3. Glass Auditing and Recording

3.1 company has identified and recorded the location of allglass / brittle plastics on site on Glass &Hard Plastics – Register /Risk Assessment.

Glass Audit frequency and assessment of risk isdefined in by risk assessment. Some are daily and others are monthly


4. Glass Control and Incident Reporting


4.1 company has a systemised way of ensuring glass control andincident handling, this is defined in Section 5 below “Procedure to befollowed in the event of glass breakage” and records of activities recorded on “Glass and Hard PlasticsIncident Report” Doc P47.6

4.2 In the event of any glass being removed or disposed of, andprovided there is no product contamination suspected, removal and disposalshall be supervised by a person of line manager status or above. Supervisionshall include the time up to and including the clearance of the glass and anydebris off site i.e. outside the building to a compactor or other suitablemethod of contained disposal. .


5. Glass & Glass LikeMaterial Breakages

5.1 In the event of any glass or other fragmentable materialbeing broken or found to be cracked or broken, the prime duty is to preventdespatch of product that may have been contaminated. Any suspectmaterials/product must be scrapped.

5.2 Where any glass or other fragmentable material has beenbroken or damaged and does not pose any threat to product safety this should,following investigation, be highlighted insitu using marker pen so that futureglass audits can be used to monitor that its condition is not deteriorating. Arisk assessment must be completed to determine how quickly a repair needs to be made and agreed with theengineering team.

5.3 Contaminated plant/process must cease production until athorough clean down has been completed. The process may only restart with thepositive approval of a senior member of the Factory Management Team. On days this must be either the TechnicalManager or the Quality Systems Manager. This authority must be formallydocumented on the Glass breakage Clean Up incident report form.

All pieces of broken glass, etc. and any othermaterials involved in a possible contamination incident shall be retained untilinvestigations and any laboratory analysis is complete. A sample of the brokenglass shall be securely retained for x years.

5.4 In the event of a glass breakage incident potentiallycontaminating Retailers Own Label product then the customer may need to beinformed via the appropriate account management channels as specified inindividual retailer codes of practice.

5.5 In the event of a glass breakage, the area and all equipmentwithin a 10 metre radius, must be cordon off where space permits. Where spacerestrictions exist, precautions should be taken to cordon off an appropriatearea. No unauthorised movement through this area either in or out is permittedwithout the express permission of a senior site manager.

5.6 Consideration must be given to any persons PPE and shoes thatpotentially have been contaminated during the incident or during the clearingof the glass. Shoes soles should be inspected before leaving thequarantined / clean up area. All personnel within the designated “Risk”area, or who are involved in the clean-up following a breakage incident mustchange their overalls. Standard Garments must be bagged and marked as suspectglass contaminated and collection and launder arrangement made with the laundry.Under no circumstances must garments be placed in the soiled garment containersprovided by the laundry. Paper overallsmust be bagged and disposed of into external waste skips.

5.7 The production equipment that may have been affected must bedismantled for in-depth inspection and cleaning. Reassembly of the equipment must not takeplace until inspected by senior management. Any product and/or raw materials, which may have been contaminated, mustbe scrapped.

5.8 Personnel wearing glass spectacles orcontact lenses must report breakage as a glass incident.

5.9 All cleaning equipment used to clean up glass breakagesbagged and must be removed immediately from the department and thrown away.

5.9.1 Vacuum cleaners should not be used for glass clean-up operations. Where such a need exists to use vacuumequipment due to the nature and accessibility of the process / production areathen this must be authorised by the Technical Manager who both assess the needto use a vacuum and if considered unavoidable will issue instruction inrelation to the cleaning or disposal of the vacuum unit. In all cases as aminimum the hose and vacuum tools will be bagged and immediately thrown awayand vacuum cleaned and filters replaced before the vacuum cleaner is positivelyreleased back to process. Where this cannot be achieved immediately the vacuumcleaner will be made inoperable and secured outside processing or raw materialstorage areas.

5.9.2 Air lines must not under any circumstances be used during a glass breakageclean up, due to the risk of spreading the contaminate.

5.9.3 Pressure washers may not be used during a clean up incident due to therisk of spreading the contaminate.

Glass monitor /audit form

Basically just a list of the glass/brittle hard plastic items for audit. High risk for daily audits, and low risk for weekly or monthly depending on the risk assessment you do based on proximity to product, likelihood of breaking, likelihood of the breakage being noticed immediately or not. etc.

Good luck
Sharon ( Dewsbury England)

[Sharon (Dewsbury)]

Unfortunately the format of the PRP table was lost in the transcription. I should look much simpler than this as 3 columns. PRP, Control., Monitor. See attached.
Sharon (Dewsbury, England)

Attached Files

•  prp.docx   19.07KB   259 downloads

[Tony-C]

Unfortunately the format of the PRP table was lost in the transcription. I should look much simpler than this as 3 columns. PRP, Control., Monitor. See attached.
Sharon (Dewsbury, England)

Hi Sharon,



Think you just got the record for the 'longest' post !

You should be able go back and edit after you have posted.

Regards,

Tony

Edited by Tony-C, 23 November 2012 - 09:30 AM.