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Do we have too many GMP policies and procedures?


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#1 lara_80

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Posted 10 October 2019 - 03:14 PM

Okay, I am new to the food manufacturing piece of SQF. I have done distributing and Food Packaging materials but in my new company we process oils. The problem I am seeing here is they have so many SOP's to me it is just overkill. For example GMP's have over ten individual SOP's. I have never seen this before, I have always just had one GMP policy for the facility that was inclusive. Am I missing something that would be different in a food production plant to have so many. I know they have passed past audits but barely and the auditor always had comments about the confusion and lack of organization of the system. Please help. Here is just a short list of the GMP's they have individual SOP's for: GMP overview, GMP attire, GMP color coding,GMP facility, GMP Hand washing, GMP illiness, GMP levels, GMP Staff amenities.......

 



#2 greencheese

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Posted 10 October 2019 - 05:20 PM

We sperate out our documents the GMP program we employ is a policy and covers all of the areas listed above. Then we have specific SOPs that are actual procedures that take place in the facility, some of the time these procedures are already listed in one of our policies but usually we just include a reference to the appropriate policy in the document.



#3 mgourley

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Posted 10 October 2019 - 08:58 PM

I'm BRC not SQF, so I am not familiar with what the Code says. However, we have one all encompassing GMP policy that addresses all the requirements of cGMP's mandated by the FDA under FSMA.
We do not have individual SOP's for things like hand washing, attire etc. 
We conduct intake and annual GMP training for all employees that covers the basics and break out specific training for things like hand washing or whatever needs a little more in depth content.

 

I know that may not be helpful, but I would encourage you to eliminate as many SOP's as you can. It's simply not feasible to have SOP's posted all over the facility. 

GMP's all come down to training, monitoring and re-enforcement. Documents may look impressive, but how many employees actually have access to them and/or read them?

 

Unless the SQF code requires them, simplification is the way to go.

 

Marshall



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#4 Charles.C

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Posted 11 October 2019 - 03:32 AM

Okay, I am new to the food manufacturing piece of SQF. I have done distributing and Food Packaging materials but in my new company we process oils. The problem I am seeing here is they have so many SOP's to me it is just overkill. For example GMP's have over ten individual SOP's. I have never seen this before, I have always just had one GMP policy for the facility that was inclusive. Am I missing something that would be different in a food production plant to have so many. I know they have passed past audits but barely and the auditor always had comments about the confusion and lack of organization of the system. Please help. Here is just a short list of the GMP's they have individual SOP's for: GMP overview, GMP attire, GMP color coding,GMP facility, GMP Hand washing, GMP illiness, GMP levels, GMP Staff amenities.......

 

Hi Lauraz,

 

It's a good question. I am also directly familiar BRC only and would echo Post 3.

 

Theoretically I think SQF adheres to the system levels in the  ISO structure of Policies/Procedures/Work instructions although the exact implementation is afaik optional as long as compliant to the Standard's text. eg this post/thread -

 

https://www.ifsqn.co...on/#entry122362

 

Actually "SOP" is not used in SQF Standard per se however  it  (arbitrarily) often equates to any of  "Procedure, Work Instruction, etc".

 

Nonetheless, for convenience purposes, SQF users do often seem to prefer many "Procedures" aligned to the Standard's text , eg see this post/thread - 

 

https://www.ifsqn.co...ual/#entry42836

 

Seems like yr own hierarchy have simply "maximised" convenience by defining  every conceivable level as an  "SOP", eg -

 

 SOP = (Procedures/Work Instructions/sub-Work Instructions),

 

ie a "lot" of SOPs  :smile:

 

Maybe you could (minimally) suggest incorporating some of the "subs"  into the next layer(s) up ?

 

(For BRC I did initially use the ISO "Top" level Procedural Concept but then simply started numerically (001,002 etc) defining "Procedures" as required by (a) Standard and (b) own HACCP/Process Interpretation(s). "Subs" such as you mention in OP were thereby, documentarily,  "uplifted").


Kind Regards,

 

Charles.C


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#5 LostMyMind

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Posted 11 October 2019 - 03:59 PM

It honestly sounds like someone who didn't really understand how to tie in cGMPs into your plant.  I had that when I got there.  Not sure what to do, just throw lots of random papers at it.  

 

Outside of sanitation (SSOPs), I put any "SOP/work instructions" right on the back of the related log.  Too many documents just confuses the heck out of people.  It's very hard for auditors to complain when you turn over the log to show them the instructions.  (SSOPs are too plentiful; those I just post in the plant.)

 

Keep it simple (cause they are stu***) KISS methodology. 

 

Anyway, don't think you can't change things - especially if you are making it simpler.

 

Good luck.

 

 



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#6 SQFconsultant

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Posted 11 October 2019 - 04:25 PM

Sounds like the write person was a snower.

As in, Auditors hate people that attempt snow jobs by presenting mounds of paper when all of it could have easily been condensed.

Either caused by someone that was justifying a job or imcompetence - or combo.


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