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SFCA, SFCR, ECCP, GMP, third party certifications?


Best Answer Pepperfire, 20 January 2019 - 11:13 PM

Thanks for the detailed response. That really helps.

We make several different types of products, mostly sauces, condiments, cocktail mixes, dried spice mixes, etc. So far, all processed products, but we expect to expand, the ECCP is new to me.

Our consultant is an ISO Standard specialist, a 3-party auditor herself, she has been training me and helping me focus, but her background is NOT food, so it's complicated. She has been working with me since 2017. I got lucky.

We are not certified, we have as of now run three mock audits, I'm getting close to being able to nail our mock audit, but there it always something that is missed. The employees are always my weakest link. My head chef doesn't like to collect data. I am expecting to pass our next mock audit which is scheduled for June. My biggest lack right now are written documents that will stand up to scrutiny. (That's assuming the recent release of FSSC 22000:2018 doesn't kill me.)

We do custom manufacturing, so our customers tend to be little guys who are ordering less than 3 pallets of product at a time. We are four employees, 11 in the kitchen during peak manufacturing/harvest, but still just a little place. We have been working with the CFIA to ensure that we get it right, too, because we are a feeder pipeline for an ever expanding network of local farmers.

The trickiest part of our documentation is that we are the manufacturer. We do not own the brands, someone else does. IOW, tons of work writing individual processes. Also, because we do not own the brands, our sales are ALL at the back door. We don't do the exports, our clients do.

I am hoping the new license structure will fix the headache. Go to the full post


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#1 Pepperfire

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Posted 18 January 2019 - 07:58 PM

Quick intro, I've  been here a while and lurking while wading my way through benchmarking FSSC 22000 at my hand batch co-pack kitchen in Quebec. We have been manufacturing in our current location with the current name since 2004, but my partner had previous food manufacturing companies the all totalling 50 years of safe food manufacturing. My 500K (read little) revenue company custom manufacturers for multiple companies. We do not do wholesale, we simply manufacturer. HACCP is my introduction to ISO Standards, and in 2017 we began the process of benchmarking FSSC 22000 for when the certifications came into play so that we'd be above and on top of the situation. We are a 6 man company, so we are working on the KISS principle as our end goal, but in order to get there, we have to do it piecemeal with priority placed on food safety risk assessments.

Now, the rules and regs are kicking into gear and I am curious how to deal with this. This is threatening to get pricy. and we're only a little place.

One of our client's distributors has a purchaser who requested a HACCP certification for sale into their chain. Now, maybe I went about this the wrong way, but I assumed that if I successfully benchmarked the highest food safety standard, life would be simpler. I like simple. This isn't simple. Today we learned that we have to have an ECCP in order to ship into the US. Now, having read through what is required for said document, we comply with it in principle, my question is, do I need a completely written ECCP in addition to the written FSSC 22000 documents or is a simple policy statement that addresses exports, in addition to the FSSC sufficient, or what?

How do your companies deal with requests for certifications for standards that are similar to the ones you've benchmarked? Do I simply bring in an  auditor every time someone requests them?

Thanks for any thoughts and comments.



#2 Scampi

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Posted 18 January 2019 - 08:08 PM

Ok, can i ask what type of product so I can help-----different commodities have different requirements

 

HACCP certification is it's own and FSSC is a GFSI that is above and beyond a basic HACCP plan, so no need to worry there. Are you in fact FSSC certified? Have gone through an audit?

these are the requirements for an ECCP----you should already have all of this info, just not located all in one place, so you can do this yourself (please don't hire any more consultants----they rules are too new and I'm worried people are going to start hanging out shingles calling themselves consultants when they haven't a clue what they are talking about)

Elements of the ECCP plan

You should incorporate all elements of the export certification controls into your food safety system. The ECCP plan is the written document that describes the procedures and processes used to capture the following elements:

  1. Preventive control plan (PCP)
  2. Exporting roles and responsibilities
  3. Foreign country requirements
  4. Product compliance
  5. Certification
  6. Eligibility lists
  7. Inspections and fees
  8. Traceability

http://www.inspectio...5/1527252981753


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#3 Pepperfire

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Posted 20 January 2019 - 11:13 PM   Best Answer

Thanks for the detailed response. That really helps.

We make several different types of products, mostly sauces, condiments, cocktail mixes, dried spice mixes, etc. So far, all processed products, but we expect to expand, the ECCP is new to me.

Our consultant is an ISO Standard specialist, a 3-party auditor herself, she has been training me and helping me focus, but her background is NOT food, so it's complicated. She has been working with me since 2017. I got lucky.

We are not certified, we have as of now run three mock audits, I'm getting close to being able to nail our mock audit, but there it always something that is missed. The employees are always my weakest link. My head chef doesn't like to collect data. I am expecting to pass our next mock audit which is scheduled for June. My biggest lack right now are written documents that will stand up to scrutiny. (That's assuming the recent release of FSSC 22000:2018 doesn't kill me.)

We do custom manufacturing, so our customers tend to be little guys who are ordering less than 3 pallets of product at a time. We are four employees, 11 in the kitchen during peak manufacturing/harvest, but still just a little place. We have been working with the CFIA to ensure that we get it right, too, because we are a feeder pipeline for an ever expanding network of local farmers.

The trickiest part of our documentation is that we are the manufacturer. We do not own the brands, someone else does. IOW, tons of work writing individual processes. Also, because we do not own the brands, our sales are ALL at the back door. We don't do the exports, our clients do.

I am hoping the new license structure will fix the headache.



#4 Scampi

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Posted 21 January 2019 - 01:46 PM

Since you are NOT the exporter, merely the producer, the ECCP does NOT fall onto you. It is the exporters responsibility to ensure documentation meets the requirements of the importing country. This is based on you saying you sell to your customers and THEY export

HOWEVER, you obviously still need the license to manufacture.

 

Your chef is going to HAVE to start completing paperwork. It is a MUST, otherwise how do you REALLY know what lot went into what finished product....plus meeting time/temp/pH etc requirements. You will automatically fail a CFIA inspection if these things are not done

have you performed a mock recall yet? 

 

As for paperwork for sales...........you simply need

A) records that the product was safe (GMP inspections/sanitation/batch records (including all ingredient lots) and inspection of shipping containers oh and labeling (which should all be done during production with the exception of the shipping containers and trucks)

B) a record of which finished goods went to which customers...............this is the only piece you will have in the event of a recall on your products OR one of your ingredients/packaging

 

Having someone with ISO experience helps.....but food is very different than widgets


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#5 Pepperfire

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Posted 23 January 2019 - 06:35 PM

It is not MY exporter who is required to meet the requirements of the ECCP in order to qualify for their ECCP. So, I am, as the custom manufacturer on the hook should my client decide they want to export. In effect, it is my traceability, it is MY recall, it is my PRP, my PCP, my process, my formula, my allergen control etc. Trust, though, we will be passing these costs on to our clients as incurred, it's THEIR product. Also, as the CFIA so kindly pointed out, years ago, if I make anything at the top level, EVERYTHING we make, (170+ SKUs) even if they only sell at the local farmer's market, has to be at the top level, hence the choice of FSSC 22000 as our corporate Standard. The point of attempting to benchmark that is akin to the idea of covering all of my bases. Benchmark the highest standard and all lesser standards can be certified.
 
As for my chef, I am meeting all of my FS requirements, we created a "simplified traveller" which we keep adding fill in the blank lines to. He just grumbles and gripes, and then our operations' staff fills in the blanks and rag on him to do it until he finally gets on and does it. It took me WEEKS just to get two signatures on our shipping documents. Shoot me now.
 
We're considering creating, in essence, a video game/app sort of thing that will serve to collect my food safety datum. :) Pay them bonuses when they nail it all.
 
A and B... Good questions on the paperwork! We have completed all our traceability and recall documents, and our second mock recall is planned for the coming couple of weeks. I'm expecting a grand total of about 600 mock people to die because, I already know, that NONE of my clients have any such thing on their side, and if they did, that's the size of the batch recall. We batch label EVERY pot, because we can. Most manufaturers don't even know they need a MYCFIA account. Mine was opened and has been pending since last May. I also paid my manufacturer's license fee on the 17th, which includes our export and import activities.
 
As for my remaining FSSC policy documents, I believe at this point that a "food" expert, in my case, might be a hindrance. Our Food Safety Plan was the EASY part. We simply followed the templates that MAPAQ and the CFIA have given us over the years. Because we are so small, we operate from cash flow, so we had to identify our risks first, eliminate those, and then implement the requirements for the standard based on that as the primary principle. So, our employee manual, education and training is done as well. I am lucky that I am a geek and MAPAQ is very proactive with people who are serious about food safety, so we're amazingly head and shoulders beyond most in our position. We at least knew this was coming, so the food safety is in place and documented as manufactured, (2 final issues being completed this week), I am very proud of that.
 
What we require now is whittling all the written documentation required to get certified into personalized documents as the bigger documents are still based on generic templates. That is where we are. Hiring a standards specialist was a good compromise for us, because she already knows and understands standards and is effective in helping us follow the KISS principle with the personalizing of the plan. We really need to work with our employees in order to make this work. I do not have ease of turnover of employees, here. We need the plan to be as simplified as possible so that we can create and implement the processes for any new clients on-boarded as well and ensure all the data is documented. It is our goal to have the details in place so that we can become a multi-category manufacturer, we didn't start doing this because we thought we would have to, we started this because we knew it was the only way to do meat. Also, our target customers have revenues of 100K - 2MM, so, given an average 3-5 products per customer, simplicity becomes our best friend, we have so many formulas to work the various "HACCP" plans for, now, and because we need the ability to create and maintain those as our value as a custom small-batch manufacturer. (Chef not liking paperwork aside). Anyway the HACCP rules are all benchmarked for inspection purposes, they are just not certifiable to the standard. Our formulas are all done, and ready to file, the processes are ready for any country who wants them. Now we just need the novels written to be certifiable. And someone with excellence in standard writing was a Godsend. The fun part is that once the overalls are done, we only ever have to hire the food specialist back for the food safety part of any new products or new equipment. Easy peasy? I expect at one point we will have someone on staff full time for that.
 
I should thank you (and any other members reading this) for their activity here. As a small manufacturer in the middle of nowhere, THIS is the ONLY place anyone actually talks about food safety, most of my colleagues in food around here, aren't aware of this stuff. One colleague similar size to mine, different product class but 4 times my size hasn't even implemented an ERP yet. We're big fish in an otherwise teeny tiny pond, here, but we literally are the only two food manufacturers in the county who are aware this is even a thing.

Sorry for the novel.

My biggest task right now, aside from figuring out how many different plans I need to write for each customer, (hence the original question) this week, is finding and installing 2 door self-closers and a foot bath. Any recommendations?


#6 Scampi

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Posted 23 January 2019 - 06:47 PM

Ok, I have a couple of suggestions.................1 is an app called goCanvas (low cost cloud based paperless records that can push reminders et all)      or if you want to spend huge $$$  icicle software (canadian company)

 

https://www.thebuyin...oot-dip-mat.htm   These are ideal for dry areas (put in granular quat that breaks when you step on it)..........you can buy rigid black plastic trays with a grooved bottom at the local coop (cheap cheap) and use chlorine or a liquid quat

 

https://www.hogslat....-boot-scrubbers

 

https://www.google.c...iact=mrc&uact=8

 

The type you use depends on the hazards and whether or not it's a RTE facility


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#7 Pepperfire

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Posted 25 January 2019 - 08:26 PM

We went with Vision4 because they were designed for and by a manufacturing company with multiple product lines and it's bilingual. I just wish it was set up like Mario Kart, the employees'd be more interested in working with it. GoCanvas may be useful, I will check it out.

No meat. I think we'll be safe with the boot mats. They'll be delivered Monday or Tuesday. Thanks. Now I just need door closers.

Have a great weekend!






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