Do I need to create a new Food Safety Plan binder for FSMA?
I'm not sure if I need to create a new Food Safety Plan binder separate from SQF or if I can just use the SQF and give the FDA what they need out of there. At my PCQI certification I was told to create a new Food Safety Plan for FSMA but when I got back to work my boss told me SQF was enough and I did not have to. FSMA compliance is coming very soon and I want to make sure I have everything completed and done before the deadline.
Thank you very much for your help!
I appreciate it!
I think it depends on what works for you. The important part is to have the information for them. For myself I am not creating a separate binder. But I know other colleagues who are building or have built a separate binder for FDA and customers to see.
We are combining ours within the hazard analysis for our process / facility. I find this easier to manage than having separate programs and binders for different types of regulatory, certifications, audits, etc.
It seems though many auditors want to see specific binders, and programs just for that type of audit...e.g. non-GMO, gluten free, etc. We had a non-GMO audit a couple weeks ago and the auditor didn't know what Product Identity meant and was adamant we maintain an entire non-GMO program with a printed manual. Sheesh...
Do what is ever EASIEST for you to document, enforce and maintain.
For us, we simply added a column in our hazard analysis for:
PREVENTIVE CONTROL MEASURES FOR HUMAN FOOD (FSMA) REQUIRED (Process, Allergen, Sanitation, Supply Chain)
Ryan M,
Out of personal curiosity what body performed this "Non-GMO audit"?
As someone with a background in genetics entering the food safety world it pains me to see so many in the industry embracing this unfounded fear of genetic engineering just to make a quick buck off the whole foods crowd.
I was told the same thing to make its own binder, which I do think it will be easier, I have been told over the years you only want Auditors to have access to what they are auditing.
Ryan M,
Out of personal curiosity what body performed this "Non-GMO audit"?
As someone with a background in genetics entering the food safety world it pains me to see so many in the industry embracing this unfounded fear of genetic engineering just to make a quick buck off the whole foods crowd.
SGS, I was informed by our customer (we co-pack) who setup the audit is it being based on a European standard, not US. They modified it somewhat for US, but it was a very clumsy audit and quite repetitive.
I was told the same thing to make its own binder, which I do think it will be easier, I have been told over the years you only want Auditors to have access to what they are auditing.
Depends....if you maintain a separate binder then you have separate programs and policies. Then you have to verify (some) and validate (some) just for that. Then you conduct the training just for that. In my view I would rather have one group of policies / programs that cover the facility. For example, a "Identity Preservation Program" versus a "non-GMO Program".
To each their own...but I can tell you in almost every audit or inspection I have had the auditors have commended our written policies and programs for the ease of finding the information and the ease of understanding the policy or program. I get far more long-winded in my responses on this site than I do with our policies, programs, and procedures. :)
I was told by someone at SQF that if FSMA requires more than than what SQF requires, I will be audited on what FSMA requires since that is Federal Regulation. So I'm just making one binder to eliminate paperwork.