Any surprises compared to the draft consultation version?
I foresee a fun evening of gap analysis for me tonight!
I have been looking mainly at the differences between Issue 7 and Issue 8 but here are the differences I noted between the draft and Issue 8.
Changes form Draft Nov 2017 to Issue 8
2.1.1 Removed (eg requirements for a PCQI in the USA).
2.3.1 Changed from target to maximum shelf life
2.7.1 Added consideration of the following types of hazard:
chemical and radiological
contamination fraud (e.g. substitution or deliberate/intentional adulteration)
malicious contamination of products
3.4 Maintained original section name Internal Audits not changed as per draft
There generally is reference to ‘primary packaging’ in Issue 8 rather than ‘packaging’ particularly in 3.5 SUPPLIER AND RAW MATERIAL APPROVAL AND PERFORMANCE MONITORING
3.5.4 MANAGEMENT OF OUTSOURCED PROCESSING
Packing of products by third parties (e.g. contract packing) has been removed from this section as this should not form part of the scope of the audit (the packing site is encouraged to have its own certification).
3.6.4 Specification review shall be sufficiently frequent to ensure that data is current or at a minimum every 3 years - retained (deleted in draft)
New 3.7.3 The site shall have a procedure for the completion of root cause analysis.
3.11.4 In the event of a significant food safety incident, including a product recall or regulatory food safety non-conformity (e.g. a regulatory enforcement notice), the certification body issuing the current certificate for the site against this Standard shall be informed within 3 working days.
4.2.1 The output from this assessment shall be a documented threat assessment plan…… review …… etc
The information in Issue 7 clause 4.2.3 has been transferred to the interpretation guideline for Issue 8. This is because the new clause 4.2.3 in Issue 8 has a wider remit.
4.5.3 Legislation re. water Removed - Legislative requirements are fully covered in Issue 8, clause 4.5.1.
4.5.4 Compressed air that is in direct contact with the product shall be filtered at point of use.
4.7.3 Where temporary repairs are made, these shall be documented
188.8.131.52 There shall be a documented policy for the controlled use and storage of sharp metal implements
4.10.1 changed to SELECTION AND OPERATION OF FOREIGN-BODY DETECTION AND REMOVAL EQUIPMENT
4.14.1 The frequency of inspections shall be determined by risk assessment and shall be documented. The risk assessment shall be reviewed whenever: ………………. there has been a significant pest issue.
Service provision regardless of the source shall meet with all applicable regulatory requirements.
4.14.4 Records may be on paper (hard copy) or controlled on an electronic system (e.g. an online reporting system).
4.16.2 All vehicles or containers used for the transport of raw materials and the dispatch of products shall be fit for purpose………………..
5.1.5 – 5.1.7 Moved to new section 5.8 PET FOOD
New 6.1.2 Where equipment settings are critical to the safety or legality of the product, changes to the equipment settings shall only be completed by trained and authorised staff. Where applicable, controls shall be password-protected or otherwise restricted.
6.2.4 The site shall establish and implement procedures in the event of a failure in the online verification equipment (e.g. a documented and trained manual checking procedure).
New 7.1.5 All relevant personnel (including relevant agency- supplied staff, temporary staff and contractors) shall have received training on the site’s labelling and packing processes which are designed to ensure the correct labelling and packing of products.
8.5.2 Microbiological limits for acceptable and unacceptable cleaning performance shall be defined for high-risk/ high-care production risk zones.
No 8.5.4 - Dedicated CIP system for high risk or high care
I would recommend purchasing the Guidance and Changes documents or viewing them if you have access to Participate.