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Food Safety Plan and HACCP Plan Overlap

audit food safety fda fsma

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#1 larissaj

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Posted 12 June 2019 - 01:11 PM

Hello,

 

So I finally have an audit date for our annual GMP audit. I have been working on it on and off for a bit. One thing im confused on is a food safety plan. It asks for things that are in my HACCP plan. I am PCQI certified and everything that was said in the training were things I already knew and had already going but in my audit there is a section for a food safety plan and I dont know if I will get in trouble for showing them things that are in my HACCP plan that covers that section.

 

 

Advise or tips are greatly appreciated.



#2 Charles.C

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Posted 12 June 2019 - 01:24 PM

Hello,

 

So I finally have an audit date for our annual GMP audit. I have been working on it on and off for a bit. One thing im confused on is a food safety plan. It asks for things that are in my HACCP plan. I am PCQI certified and everything that was said in the training were things I already knew and had already going but in my audit there is a section for a food safety plan and I dont know if I will get in trouble for showing them things that are in my HACCP plan that covers that section.

 

 

Advise or tips are greatly appreciated.

 

FS Standard = ? SQF ?


Kind Regards,

 

Charles.C


#3 kfromNE

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Posted 12 June 2019 - 01:25 PM

Multiple threads on this topic - see below for previous threads.

 

https://www.ifsqn.co...d-safety-plans/



#4 The Food Scientist

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Posted 12 June 2019 - 01:32 PM

When the auditor asks you to show them your food safety plan, they are asking you to show them your HACCP program (the foundation for any food safety plan). Go through the code you are being audited for and check to see if everything in there is covered under your HACCP. 


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#5 HokeyPokey

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Posted 12 June 2019 - 01:40 PM

The new CFR 117. is base on preventive Controls in place which is your prerequisite programs and SOP and SSOP. The new Food Safety Plan have to be development to the CFR 117.  Hope is help.  I had a inspector from the FDA told me that I have one of the best she has seen. Good Luck. 



#6 larissaj

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Posted 12 June 2019 - 01:48 PM

It is for a normal GMP audit, not GFSI


Edited by larissaj, 12 June 2019 - 01:49 PM.


#7 HokeyPokey

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Posted 12 June 2019 - 02:12 PM

An In-house GMP audit or 3rd. party GMP audit.



#8 larissaj

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Posted 12 June 2019 - 02:32 PM

3rd party, sorry.



#9 The Food Scientist

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Posted 12 June 2019 - 02:38 PM

3rd party, sorry.

 

Scheme? 

 

edit: my bad you did say it is a 3rd party GMP audit. 


Edited by The Food Scientist, 12 June 2019 - 02:40 PM.

Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#10 larissaj

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Posted 12 June 2019 - 02:54 PM

Scheme? 

 

edit: my bad you did say it is a 3rd party GMP audit. 

 

Yea its a 3rd party GMP audit.

Im just still confused. I watched the first video, working on the second video. 



#11 The Food Scientist

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Posted 12 June 2019 - 03:00 PM

Yea its a 3rd party GMP audit.

Im just still confused. I watched the first video, working on the second video. 

 

What is the nature of your facility? Food packaging, processing, distribution? 


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#12 larissaj

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Posted 12 June 2019 - 03:02 PM

Food manufacture, we roast nuts and make mixes. We have 5 allergens in house as well. 



#13 HokeyPokey

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Posted 12 June 2019 - 04:27 PM

If you can send me your email address (PM) I will help you get going on this. 



#14 larissaj

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Posted 12 June 2019 - 04:41 PM

I unfortunately dont have that option.



#15 MsMars

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Posted 12 June 2019 - 06:34 PM

I'm confused, who is the third-party performing the audit? A customer or a accrediting body? 

Correct me if I'm wrong, but if you are regulated by FDA only (not USDA), then your plan would only need to consist of the FSMA Food Safety Plan.  This is easily translated from your existing HACCP plan with a few tweaks, as there are many similarities but they are not the same.  Unless your customer or certifying body requires you to also have a HACCP plan, you should only have to worry about the Food Safety Plan going forward.



#16 larissaj

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Posted 12 June 2019 - 06:54 PM

I'm confused, who is the third-party performing the audit? A customer or a accrediting body? 

Correct me if I'm wrong, but if you are regulated by FDA only (not USDA), then your plan would only need to consist of the FSMA Food Safety Plan.  This is easily translated from your existing HACCP plan with a few tweaks, as there are many similarities but they are not the same.  Unless your customer or certifying body requires you to also have a HACCP plan, you should only have to worry about the Food Safety Plan going forward.

 

It is an accrediting body, the scheme asks for HACCP, Food safety plan, food defence plan, fsma, etc. Its Merieux NutriScience. I dont know if saying the auditing body could hurt me lol



#17 MsMars

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Posted 12 June 2019 - 07:13 PM

It is an accrediting body, the scheme asks for HACCP, Food safety plan, food defence plan, fsma, etc. Its Merieux NutriScience. I dont know if saying the auditing body could hurt me lol

 

I would call Merieux or review your scheme - if you aren't subject to USDA jurisdiction, then I don't see any reason that you should have two different types of plans that accomplish the same objective. 



#18 larissaj

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Posted 12 June 2019 - 07:41 PM

I am not subject to USDA, thats why im asking because on their scheme for 2019 it says the different sections and HACCP and food safety plan are two different sections but it overlaps with my current haccp plan and so I want to know if i need to make a food safety plan that would have all the same stuff as my haccp plan. it doesnt make sense, I just dont know if an auditor would give me a hard time showing them my HACCP plan to cover the food safety plan. 

 

 

I feel like im going crazy



#19 MsMars

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Posted 12 June 2019 - 08:51 PM

I am not subject to USDA, thats why im asking because on their scheme for 2019 it says the different sections and HACCP and food safety plan are two different sections but it overlaps with my current haccp plan and so I want to know if i need to make a food safety plan that would have all the same stuff as my haccp plan. it doesnt make sense, I just dont know if an auditor would give me a hard time showing them my HACCP plan to cover the food safety plan. 

 

 

I feel like im going crazy

 

For FDA compliance (which should have overall precedence) you need to have a FSMA-compliant Food Safety Plan.  After you have created this, then you need to ask your certifying body if you are required to have both.  I am not sure how the scheme reads, but federal compliance should take priority over a third-party certification



#20 larissaj

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Posted 12 June 2019 - 09:12 PM

I will look into that scheme and in the audit's scheme it does ask for FSMA and our supplier approval. Which we also are compliant in.

 

Edit: So I started to fill out the food safety plan builder and like I stated earlier, all the things I already have in place. I just dont call it food safety plan. I call it HACCP, GMPs, FSMA, Food defense. etc


Edited by larissaj, 12 June 2019 - 09:15 PM.






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