A food safety plan for each new product, or are they all the same?
I'm a food packaging manufacturer going for my first SQF in April/May.
SQF 2.3.1.4 says that: "A food safety plan (HACCP Plan) and food quality plan shall be validated and verified for each new product and its associated process through conversion to commercial production and distribution, or where a change to ingredients, process, or packaging occurs that may impact food safety or quality."
We make rolls of printed flexible packaging material to package food. All of my products see the same basic process: Print/Laminate/Slit/Pack&ship, and use the same raw materials: inks/paper/plastic/foil. Because of this I was planning on only 1 HACCP (Food Safety) Plan.
That said, we have thousands of different product specifications. Each finished product will have a different graphic, different grades of materials, different physical properties, etc.
Is SQF expecting me to have a written HACCP Plan for each of the thousands of finished product specifications?
As SQF Practitioner, do I need to verify and validate and approve each these specifications? What about my raw material specifications? I've got thousands of those too.
I've got a group of packaging engineers who approve finished product specifications and raw material specifications. The are trained to only use Food Safe raw materials and can't contract out any processes.
We produce a variety of packaging from folding cartons to packing cases. Just completed our first SQF audit with only minors. Since we do not produce any packaging that comes in direct contact with food items, we were able to stay at level one. Level one does not require HACCP but you do have to have the prerequisite program varification and validation in place. We kept it general to cover all our different items, raw materials, etc. Let me know if this helps.
We have been SQF certified for 2 years now. While we are in the business of food manufacturing, not packaging, I would assume the same rules apply for HACCP. In my experience, it is ok to group similar products together under one HACCP plan.
Regarding the specifications, each individual specification must be reviewed and approved, both finished and raw. They do not need to be approved by the SQF Practitioner, but you should have a procedure in place that describes who is responsible for this function.
Good luck on your audit.
We have been SQF certified for 2 years now. While we are in the business of food manufacturing, not packaging, I would assume the same rules apply for HACCP. In my experience, it is ok to group similar products together under one HACCP plan.
Regarding the specifications, each individual specification must be reviewed and approved, both finished and raw. They do not need to be approved by the SQF Practitioner, but you should have a procedure in place that describes who is responsible for this function.
Good luck on your audit.
Great info. Thanks.
I will group my products under one HACCP plan. We did this under AIB and they were fine with it.
I'd very much lik to stay out of the approvals process for my raws and finished products. I train the approvers on what the food safety requirements are (only use food safe materials, and no outside processing) and they stick to it. The processes are well defined and controlled and there are records to prove this. The SQF code makes it sound like I have to "verify and validate" every specification and to changes to them.
I supposed I could double check that the material are indeed food safe and that the process doesn't deviate from what it in our HACCP plan, but I don't think it would add any value and would slow down my development process by adding yet another step. My Raw Material specialist knows to only spec food safe materials (we don't use any non-food safe), and my product specs all use the same process steps. Outside contracted manufacturing would be the only way to deviate and we don't do that.
It would depend on whether or not there is a change to the process flow chart. That is, does the new product incorporate different equipment or run on a different line than the others in that catagory. For example, we run chicken breaders all day on our "A" line with almost identical ingredients which only vary by degree of spices, salt and flour etc. You should not have to "reinvent the wheel" for each very similar product using the same ingredients, packaging, labeling and blending/batching process. Rather, do an indepth hazard analysis of each ingredient, package and flow chart and apply it to the new product. Remember, to always do a walk thru from receiving to shipping of the product to be sure that nothing has changed enough to warrant a reassessment of the HACCP plan. You need to do this when ever there is a failure or new equipment/product is added. No need to do a hazard analysis for black pepper over and over.
Taste Maker
Memphis, TN
Hello,
I will try my best to explain the way I see it and as short as possible. We had our SQF Audit 2 weeks ago and this part was very intense.
New Product comes into your Organization
Verification: Yes or No
Are raw materials, packaging materials, and ingredients from an approve supplier? Manufacturer specifications are according to legislation.( some of them)
Are specifications up to date for all raw materials and packaging materials?
Any hazards listed (You must have a register of all your raw materials and packaging materials and keep alike products or products families groups together) have 4 columns for Hazards BIO - CHEM- PHY- ALLERGEN.
Does the new product has been tested through current HACCP Plan? Does the current HACCP plan needs to be modified to run the product? This is done through your trial run process. You will have to have evidence of trials run process and records.
You must design a form to answer these questions. and signatures.
Verification is making sure the new product is done according to your R&D Procedures and they are executed consistently.
Validation
For every raw material and packaging material vendor you should have a L o G (Letter of Guarantee) and you should have requested those every year especially if you are having problems with the supplier. Validation for Suppliers.
New product validation - How many new products have you done last year? Pick one or two and follow the process. Have a form to check the process (This will be your Validation Form) including the HACCP Plan Process. This will validate your HACCP Plan for new products and perhaps your current ones as well.
Validation is testing your system and making sure your system and process is working.
Your Food Safety plan is clause 2.3 to 2.9.
This could take pages but it is my hope you get the basic Idea. Where I work, they still do not get it. :)
I hope this helps,
Kellio
If your packaging products are basically all the same, then you should be OK with one HACCP plan. When you introduce new materials, new suppliers or new finished product, you will likely need to review these against your HACCP plan to see if any new hazards are introduced. Any new hazards would have to be addressed with a revised HACCP plan.
If your packaging products are basically all the same, then you should be OK with one HACCP plan. When you introduce new materials, new suppliers or new finished product, you will likely need to review these against your HACCP plan to see if any new hazards are introduced. Any new hazards would have to be addressed with a revised HACCP plan.
A revised HACCP plan yes, but not a new / different plan. One plan can cover many products produced on a single production line provided hazards from all products are addressed. So no, SQF does not expect you to have a separate plan for each product. / specification.