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What should the final GMP policy look like?

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Left the Building...

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Posted 30 July 2013 - 02:34 PM

Silly question...what should the final GMP policy look like? I've gotten a TON of info here, thank you BTW, but all of it seems to be direction on putting the policy together. What I mean, is it typically drafted as a document? or an outline? Or does it really matter? Just curious as to what the "norm" is. Thank you! :)

 



Charles.C

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Posted 30 July 2013 - 05:24 PM

Silly question...what should the final GMP policy look like? I've gotten a TON of info here, thank you BTW, but all of it seems to be direction on putting the policy together. What I mean, is it typically drafted as a document? or an outline? Or does it really matter? Just curious as to what the "norm" is. Thank you! :)

Dear krl,

 

There is no fixed format for "policy" but one interpretation is a statement of the overall objective. Alternatively it can be further expanded into  a series of operational  dos and don'ts. Taking the 1st option,  IMO there is no universal consensus for food although some integral components  are mainly agreed on.

 

Conceptually the wiki article mainly oriented to pharmaceuticals is fairly content representative of the overall genre  -

http://en.wikipedia....turing_practice

 

For food here are some examples ( file sources at end of post) –

 

1. GMP regulations are designed to control the risk of contaminating foods with filth, chemicals, microbes, and other means during their manufacture.

(gm1)

2. Prerequisite programs which will provide the basic environmental and operating conditions that are necessary for the production of safe and wholesome food.

(gm2)

3. Implemented procedures and practices undertaken using best practice principles

BRC6

4. Good Manufacturing Practices (GMP) and Standard Operating Procedures (SOP) are two tools for a meat processing facility that help for the production of high quality and safe meat products.

http://www.foodsafet...isites/gmp.html

 

5. Good Manufacturing Practices indicate conformance with codes of practice, industry standards, regulations and laws concerning production, processing, handling, labelling and sale of foods decreed by industry, local, state, national and international bodies with the intention of protecting the public from illness, product adulteration and fraud.

Company GMP Programmes cover both the safety and quality aspects of food production. They describe the principles, procedures and means needed to create an environment suitable for the production of safe food.

(gm3)

6. A system to ensure that products meet food safety, quality and legal requirements

(gm4)

7. That combination of manufacturing and quality control procedures  aimed at ensuring that products are consistently manufactured to their specifications.

(gm5)

8. Good manufacturing practices (GMPs) are sometimes referred to as ‘control points’ and are defined as the correct processes and procedures to be followed in the preparation of food to prevent microbial, chem-
ical and physical contamination of the finished product. In other words, GMPs define what has to be done
to prevent contamination, when it has to be done and by whom. GMPs do not address specific hazards.

(Arvanitoyannis, 2009)

 

Attached File  gm1 - ssop,gmp practices meat and poutry processors.pdf   301.13KB   258 downloads

Attached File  gm2 - Pt2, good manufacturing practices.ppt   261KB   378 downloads

Attached File  gm3 - fao, Introduction to Food Safety Management and GMP - Download.ppt   704.5KB   256 downloads

Attached File  gm4 - GMP in food.pdf   1.04MB   464 downloads

Attached File  gm5 - icd.pdf   127.53KB   235 downloads

 

Personally, I rather like Nos.2, 5, 6.

 

Rgds / Charles.C

 

PS - there are some extended threads here on drafting policy documents if you do a little searching


Kind Regards,

 

Charles.C


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charu13

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Posted 23 April 2014 - 05:09 AM

Hi,

I am doing HACCP documentation for implementation.I have already prepared PRPs for the same.Do I still have to document GMPs.Are these both the things same or different.

We are processing sheep casings.

 

 

 

 

 

 

 

 

Regards,

Charu



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Posted 23 April 2014 - 06:48 AM

I am doing HACCP documentation for implementation.I have already prepared PRPs for the same.Do I still have to document GMPs.Are these both the things same or different.

 

Dear charu13,

 

1. In general, the terms PRP and GMP are considered interchangeable although many people have many interpretations for each and IMO they are also right at their view point. If you are not going to follow/certify against ISO 22000 or any standard that uses the term - PRP, I recommend  you to use the term GMP as IMO it is of broader scope and covers more areas as compared to the term PRP's.

 

2. From your comments it appears that you have some undocumented procedures additional to PRP's which you are calling GMP's. If so, I recommend to document them too. Not necessarily to have procedures. Checklists are enough for better monitoring and control.

 

Muhammad Zeeshan Zaki.


Edited by Zeeshan, 23 April 2014 - 06:51 AM.


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charu13

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Posted 23 April 2014 - 07:12 AM

Hi,

Thanks for the swift reply.I have one more query.We are receiving frozen raw sheep guts and processing them into casings.I have found one CCP in the entire procedure.That is salt concentration.Do you think there should be more CCPs

We are only cleaning ,stripping,dipping in saline water and storing 5-8 degree.

I am stuck in its hazard analysis.

 

Please suggest.

 

 

Regards,

Charu Tyagi



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Posted 23 April 2014 - 06:46 PM

Dear charu,

 

Regarding PRP, it's a question of whose definition/interpretation you reference, or are required to reference.

 

For example, iso 22000-

 

(food safety) basic conditions and activities that are necessary to maintain a hygienic environment throughout the food chain (3.2) suitable for the production, handling and provision of safe end products (3:5) and safe food for human consumption
NOTE The PRPs needed depend on the segment of the food chain in which the organization operates and the type of organization  (see Annex C). Examples of equivalent terms are: Good Agricultural Practice (GAP), Good Veterinarian Practice (GVP), Good Manufacturing Practice (GMP), Good Hygienic Practice (GHP), Good Production Practice (GPP), Good Distribution Practice (GDP) and Good Trading Practice (GTP).

 

 

Take yr pick.

 

Regarding CCP, one can, up to a point, make the same observation as above again.

 

Curious to know how you decided that salt was a CCP.

 

Rgds / Charles.C


Kind Regards,

 

Charles.C




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