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Who is responsible for Food Safety Plan


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Kendra B.

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Posted 24 October 2019 - 03:33 PM

Hi all, 


I am currently working for a company that is planning on selling a consumer product in the United States. I have received training on HACCP systems but seeing as we are just starting out there is a lot to consider and nothing is put in place yet. The main thing I am trying to figure out is what we are responsible for. The Company I work for doesn't actually produce anything (manufacturer) as we use contract manufacturers for everything. But at the end of the day it is our name on the product. 


Does this mean the responsibility of creating the food safety plan/HACCP plan is on the contract manufacturer? 


My best guess for what we are responsible for is the following:

- recall

- supplier approval

- contract manufacturing approval 

- labeling

- product release

- complaint management


But I would really appreciate some perspective on how to start implementing systems.





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Posted 24 October 2019 - 04:02 PM

You should have a HACCP analysis that identifies the potential hazards that can realistically and how they are accounted for.  That may be through your supplier control program, but you still need to identify what can happen and how it would be mitigated/controlled.  You would also want to consider what governmental regulations you might need to adhere to.  Also, the customers that you will be selling to may likely have their own requirements (such as a third party GFSI audit), etc.  Are you shipping to other countries, as that is another layer of regulations?  Are you considering food fraud and food defense?  Using third parties to make the product means you have to worry about their supplier controls, so you can trust your products' contents.


In terms of how to start, I would create flow charts that take the product from inception (farms to 3rd party manufacturers to storage facilities to distribution chain to consumers in what countries) through to consumption.  Consider how you would handle rejected loads, allergens, etc.  Are you storing product (aka warehousing) and if not, who is and what issues can that bring?  You may want to consider a talking with a consultant - even if you don't have them do all of the work, they can provide guidance on your industry, government, etc.  


It can be a lot.  Read and google and read some more.


Good luck,


Edited by tsebring, 24 October 2019 - 04:03 PM.


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Posted 24 October 2019 - 05:06 PM

Hi Kendra,


Not knowing any more about your firm than what you have posted, it appears that in practice you are more of a storage/distributor than a manufacturer.  Presumably that means your contract manufacturers are producing and packing your product in labeled containers (shipper cartons, 55-gallon drums?) for you to store and distribute from your warehouse.  If you look at SQF's program for distributors you might see get ideas about what you should be doing for your food safety programs.  BRC, FSSC22000 and other GFSI benchmarked schemes may have similar information.


Follow this link for more on the possibly relevant SQF code: https://www.sqfi.com...8.1-FINAL-1.pdf



Good luck!


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Posted 01 November 2019 - 10:21 PM

The manufacturing facility must be registered with US FDA and must comply with the requirements found in 21 CFR 117 (Good Manufacturing Practices and Preventive Controls) if you want to sell into the US. As the company that has its name in the product but is not manufacturing it, I think you are on the right track with what you have listed. As others have noted, you should also consider what further programs or documents your customer would require.

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