Cleaning and Sanitation: Verification activities
Hello everyone!
I would be grateful to know your valuable opinions about the verification activities for the cleaning and sanitation procedures.
It's clear that the personnel responsible for the following 3 tasks have to be different:
• Cleaning and Sanitation
• Monitoring
• Verification
What I'm asking is the "extent" of the verification.
In your opinion, is it enough if the monitors check on all that the operators do (and corrects if he finds any deviation), and then the person in charge of verification activities just verifies the records (checklists) that the operators and the monitor fill-in?
Or should the verification be performed on the actual tasks?
In this case, do you think that random days/checks would be enough? Such as 1 day per week, and/or some spots per day, or things like that.
Any suggestion?
Thank you very much!! :)
I forgot to mention: the thing is for CFIA inspection purposes.
Thanks again!!
Hi, NicoD;
This can be many things but due diligence really depends on your product and process. However, under no circumstance should a verification activity be random. Verification of PRPs should be the single most regimented activity of your business (of course this is the opinion of a QA mgr :shades: ). Whoever is monitoring and completing the records of the sanitation activities should be separate from those verifying the records and performing the function of said activities. A tier of conflict reduction so to speak...
At a minimum I would have the following;
- Daily GMP/Sanitation report (visual)
- Daily/weekly/monthly cleaning checklist (a visual inspection based upon your cleaning schedule)
- Titration/concentration report (drop kit, test pads/strips)
- Usage report
Additionally;
- ATP testing
- Rapid pathogen testing
Validation;
- Visual observation of procedures
- Environmental testing by certified lab
Hopefully this helps.
Great thank you very much Slab! I appreciate your thorough explanation!!!! (y)
Hi Nico
you should use the FSEP manual as your guide, CFIA is VERY sticky on frequencies and what is and is not acceptable
OH right!!!! I'm a fool.
Thanks Scampi!!! :)
Hi Nico
you should use the FSEP manual as your guide, CFIA is VERY sticky on frequencies and what is and is not acceptable
Hi scampi,
It's a fascinatingly impressive manual but it seems to consist of ISO-type "Procedures", ie it is totally generic.
For example I cannot see any specific required frequencies for anything.
Are any actual recommended/preferred numbers, eg for verification, detailed elsewhere or is everthing simply "risk-based" ?
i guess it may also relate to the product/process associated with the OP (eg 3.2.8).
No, the it doesn't. In Canada, we have more than one set of rules/regulations to follow particularly in meat slaughter/processing. We also need to follow a Meat Manual of Procedures, which in some cases has prescriptive requirements. HOWEVER, everything requires monitoring with a paper trail AND is monitored by CFIA on a Compliance Verification System. The operator may dictate what the frequency is, and if it proves to be insufficient the frequency must be changed to get back into compliance.
Hi scampi,
Actually i take back my comment that there are no numbers. Just noticed -
6.2 Frequency of verification
The verification frequency is once every two years and whenever the following situations occur.
• Submission of new HACCP plans.
• Follow-up after a food safety recall.
• When inspection results demonstrate that the establishment does not control the food safety related regulatory requirements.
i cannot see any specific numbers related to cleaning/sanitation as per the OP although this would generically appear to be included within the 2 years.
2 years is unusually generous IMEX. As you mentioned, exceptions controlled via Meat Regulations are noted on same page as my quote.
Charles, the frequency of verification you are quoting is the frequency at which the CFIA will verify compliance in a facility with is voluntarily participating in FSEP. In a facility where FSEP is mandatory compliance verification is an ongoing activity.
The Program is supposed to be outcome based so the operator sets the verification frequency they believe is necessary and as long as adequate to maintain compliance it is fine, if not the frequency needs to be changed to assure compliance.
Charles, the frequency of verification you are quoting is the frequency at which the CFIA will verify compliance in a facility with is voluntarily participating in FSEP. In a facility where FSEP is mandatory compliance verification is an ongoing activity.
The Program is supposed to be outcome based so the operator sets the verification frequency they believe is necessary and as long as adequate to maintain compliance it is fine, if not the frequency needs to be changed to assure compliance.
Hi Sandima,
You are correct. My error.
Strangely, from a quick look through the manual, i could only see reference to a requirement of Verification for CCPs and PCs, ie no mention of PRPs (PPs) as presumably designated for Cleaning in the OP.
Perhaps Verification of PRPs is detailed elsewhere ? (or I missed the linkage ?).
addendum -
I noted the cfia meat hygiene program does have specific references to Verification of the sanitation program.
http://www.inspectio...2/1300125482318
So perhaps it all depends.
Those are CFIA internal verification of an establishments written program and monitoring. As CFIA proceeds through the changes coming down the pipe over the next 1-2 years, ALL steps will be outcome based only and the compliance will fall squarely on the shoulders of the processor/producer to prove the program meets all required outcomes.
Each operator must have written programs that include frequency of tasks, monitoring of tasks, and verifications as well as written programs for corrective actions and deviations. I hope that helps
Thank you all! You gave useful advices, I really appreciate it!
Those are CFIA internal verification of an establishments written program and monitoring. As CFIA proceeds through the changes coming down the pipe over the next 1-2 years, ALL steps will be outcome based only and the compliance will fall squarely on the shoulders of the processor/producer to prove the program meets all required outcomes.
Each operator must have written programs that include frequency of tasks, monitoring of tasks, and verifications as well as written programs for corrective actions and deviations. I hope that helps
Hi Scampi,
In the context of the thread, i think "outcome based" can be directly equated with "Verification".
From the POV of the OP, the answer (if any) appears to have been somewhat "lost in translation". Not so unusual of course.
But an interesting thread nonetheless.