addendum 2 -
Hi Andy,
I thought these edited snippets from SQF/AIB might usefully illustrate the relevance of "Specifications"
2.3.2 Implementation Guidance
What does it mean?
This element links with 2.4.5 Incoming Goods and Services.
Before an approved supplier program can be implemented, specifications must be in place for all materials that could impact product safety and quality. This relates to raw materials, ingredients, packaging materials, processing aids, additives and chemicals used within their facility including cleaning compounds. The supplier is required to keep Material Safety Data Sheets (MSDS) (added – now apparently “SDS” sheets) and labels for all chemicals that are in use on-site.
Specifications must also meet the standards set by regulation in the country of origin and the country (ies) of intended destination. This includes maximum residue levels, allergen declarations, and in particular, in-country labelling requirements (refer also 2.4.1). All current specifications for materials that could impact food safety and quality must be included on a register (list).
The auditor will seek evidence of the existence and currency of material specifications and a procedure for developing and approving specifications at the desk audit.
During the first and subsequent facility audits, the auditor will confirm compliance to this procedure; the material specification register and the process for checking compliance to specifications, validating specifications and ensuring relevant employees have access to current copies of specifications (refer also 2.2.1). Evidence will be sought by interview, review of specifications and record review, and may include:
• Review of the procedure for developing and approving specifications;
• Confirmation that the register of raw and packaging material specifications includes all on-site materials;
• Review of a selected sample of material specifications to confirm agreement with relevant legislation;
• Review of a selected sample of material specifications, in particular for high risk materials, to ensure potential factors impacting on product safety and quality are included;
• Availability of current copies of specifications to relevant staff;
• Interview of staff conducting validation activities;
• Review of records of validation checks.
3.2 Food Contact Cleaning Compounds and Sanitizers
Cleaning compounds and sanitizers are considered chemicals under the Chemical Control Program
Critical Requirements
3.2.1.1 All cleaning compounds and sanitizers used to clean food contact surfaces have food contact approval documentation.
3.2.1.2 Sanitizer concentrations are tested to make sure they are consistent with the product label.
3.2.1.3 All cleaning chemicals are properly labeled.
3.2.1.4 All cleaning chemicals are stored in a secure compartment away from production and food storage areas when chemicals are not in use.
3.2.1.5 The facility follows verification procedures and maintains records of chemical concentration testing, retesting, and Corrective Actions.
3.2.1.6 Equipment is rinsed as required by label directions to remove chemical residues.
5.9 Chemical Control Program
A written Program for managing all chemicals in the facility provides a centralized approach to identifying and controlling purchase and use of nonfood chemicals.
Critical Requirements
5.9.1.1 The facility has a written Chemical Control Program that addresses all chemicals used in the facility (e.g., chemicals for Integrated Pest Management, Maintenance, Sanitation, Hygiene, and Laboratories).
5.9.1.2 Procedures address, as applicable:
• Chemical approval
• Purchase authority
• Controlled and segregated storage
• Handling
• Labels/Labeling
• Identification of where and how the chemicals are to be used
• Concentration verification
• Training and education
• Actual usage
• Inventory control
• Chemical disposal
• Container disposal
• Spill containment and control
• Chemical Safety Data Sheet archiving
• Contractor chemicals
