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Prerequisite programs for outsourced production


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#1 Stephenoloughlin2010

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Posted 29 June 2020 - 09:45 AM

Hi guys,

 

New to the forum and food safety in general.

 

I run a small startup (small as in myself and my business partner) based in Dublin Ireland making dairy alternatives. Our background is in restaurants and catering and have developed a product we love and think will go really well. We have had successful factory pilot runs and want to take to the market asap.

All our production, storage and transport of the product will be outsourced to various registered BRC compliant businesses in our region. I naively thought this would cover us for all FSMS. However when notifying the authorities of our business the Environmental Health Officer told us we still needed a comprehensive food safety management system in place. I have since been researching and am very confident we would be ok for just using PRPs. 

But I can not find an example anywhere of a PRP for a business using contractors for every step of the business. Would someone be able to shed some light on what this might look like? A lot of the standard topics on the PRP do not seem relevant to us and when they are the writing always seems to be specific to a plant etc. 



#2 SQFconsultant

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Posted 29 June 2020 - 11:18 AM

Is the product shipped back to your facility for storage and distribution?


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#3 Stephenoloughlin2010

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Posted 29 June 2020 - 11:25 AM

No, it is couriered from 3rd party plant in a refrigerated truck to a cold storage facility operated by a third party.



#4 Mathieu Colmant

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Posted 29 June 2020 - 11:47 AM

Hi Stephen,

 

Welcome here,

 

I think there are 3 aspects you should look at.

1. The split of responsibilities. What you are responsible for, what they are responsible for.

2. The selection of outsourced companies : You already mention they are all BRC, so you can make it mandatory.

3. How you will check that your operators are doing it the way you want (follow-up of recipes, using the correct ingredients, ...)


Mathieu Colmant

Consultant in Food Safety - Brussels & London

Director

FollowFoodLaw.eu ltd


#5 Stephenoloughlin2010

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Posted 29 June 2020 - 11:57 AM

Thank you Mathieu. It's really quite overwhelming the information out there and a lot of it comes across quite convoluted (for good measure I'm sure) and very specific and completely vague and open to interpretation at the same time  :lol:

 

I have an outline of some of my wording and topics below. Perhaps you can let me know if this is the type of document expected. I have replaced the company name with X. 

 

Prerequisite Programs

 

These practices are the basic conditions and activities necessary to maintain good food safety practices for all products offered by X. 

This document is property of X.

 

Food safety regulations and legislation

 

X will follow all Irish and EU laws in any activities undertaken and ensure the proper maintenance of food safety management systems, prerequisite programs and guidance from relevant competent authorities (the HSE, Department of Agriculture Food and The Marine, Food Safety Authority of Ireland etc).

 

Food Safety Training

 

All persons working for X will receive required food safety training by the FSAI. 

 

Production contractors and approved suppliers list

 

X outsources all production to contract manufacturers.

All contractors used in the production, storage and transport of product are notified food business operators to competent authorities (eg, HSE, Department of Agriculture, Food and the Marine).

 

X will inspect HACCP plans by contractors and any releveant certificates (eg BRC) deemed neccessary to gain approval on our Approved Suppliers List before engaging their services. 

This will include where necessary investigating and checks on:

 

  • Premises and Structure e.g. design and lay-out of workspace allowing for one-direction production flow; sufficient lighting especially in food preparation and inspection areas; suitable employee facilities; hand-washing facilities; external and interior construction of walls, floors, doors

  • Plant and Equipment e.g. refrigeration services/systems; equipment fit for purpose, operated in accordance with its instructions and accessible for cleaning

  • Technical maintenance and calibration

  • Cleaning and Sanitation

  • Zoning e.g. physical separation of activities to prevent cross contamination with allergens or biological hazards such as harmful microorganisms from raw to cooked food

  • Procedures to control and prevent physical and chemical contamination from the production environment  e.g. what to do in the case of breakage of glass, hard plastic etc.

  • Supplier control e.g. supplier selection and agreement on specifications for raw materials, additives, processing aids, packaging material, food contact material

  • Services e.g. water, ventilation, electricity, gas etc.

  • Storage, Distribution and Transport (including temperature control)

  • Waste Management

  • Pest Control (i.e. prevent entry of pests and implement suitable pest control program)

  • Personnel Hygiene and fitness to work e.g. procedures for personnel suffering with gastro-intestinal infections, hepatitis, wounds or other relevant health problems

  • Training and Supervision

  • Working instructions (i.e. provision of clear and simple work instructions which are visible or easily accessible)

 

We will only use suppliers and contractors on our Approved Suppliers List.

 

Product specification and where appropriate safety data sheets will be required for all food ingredients and food additives prior to gaining approval on our Approved Ingredients List.

 

All bottles and packaging used will require production specification sheets and any relevant food safety certification before use on the product to ensure they are fit for purpose.

 

All transport services used will have accurate temperature controll, GPS tracking and use drivers trained to the highest level.

 

All vendors, contractors and items on our approved supplier list and approved ingredients list will be regularly monitored and updated where necessary. 


 

Maintenence of the Cold Chain

 

X is a fresh product that needs to be kept refridgerated at 0-4 degrees celcius.

 

Transport of raw materials requiring refrigeration will only be done so using contractors from our Approved Suppliers List.

 

Storage of raw materials and finished product before entering the market will only be done so using comtractors from our Approved Suppliers List.

 

All transport and storage services used by X will require approval on our Approved Supplier List

Suppliers will need to provide evidence of operation and maintenance of refrigeration systems of all storage and transportation services used and any certification required to demonstrate this.

 

Allergens

 

X will ensure all allergen controls are implemented by contractors engaging in production on behalf of X 

 

This includes keeping allergens out of the premises through good supplier control, or

by implementing strict measures to minimise the potential for cross-contamination.

 

All labels will have allergens clearly indicated according to Irish and EU legislative needs and updated to reflect any changes needed by law.

 

Tracability

 

X will keep record of all product batches with unique code identifying each batch produced as well as all raw materials used in creating X. Each batch will also record any raw materials supplied from our approved supplier list and approved ingredient list so we may identify any person from whom we have been supplied with a food or any substance intended to be, or expected to be, incorporated into a food so we have systems and procedures which allow for this information to be made available to the competent authorities on demand.

All batch codes and product information will be recorded onto a master batch sheet with any ingredients used, where they were supplied from and any accompanying lab microbiological results necessary for full traceability.

All products made which is placed on the market or is likely to be placed on the market shall be adequately labelled or identified to facilitate its traceability, through relevant documentation or information in accordance with the relevant requirements of more specific provisions.

 

Product Recall Program

 

In any instance where a product is deemed unsafe or not to be complying in General Food Law a product recall will commence.

This will follow a clear sequence of events:

  • 1. Initial information management

Gathering of all information on a food safety problem to determine scope, scale and issue of complaint. Sources of initial information may be:

  •  Quality and production records

  •  Sales representatives

  •  Employees

  •  Food suppliers

  •  Packaging suppliers

  •  Competent authorities

  •  Distributors/business customers

  •  Consumer complaints

  •  Media reports

 

  • 2. Applying the decision tree and identification of unsafe or other non-compliant food

  •  
  • 3. Compilation of information on distribution

  • 4. Removing food from the market and associated communication

  • 5. Closing a food recall/withdrawal

  • 6. Disposal of unsafe food

  • 7. Reviewing the food recall/withdrawal




 



#6 pHruit

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Posted 29 June 2020 - 02:14 PM

It might be a bit of a pain in the derriere for you, but I have to say I'm somewhat encouraged to see EHOs picking up on this - too many distribution businesses seem to escape their obligations under Regulation (EC) 852/2004, IMO...

 

How comprehensive (or complicated ;) ) do you want/need to make your program?

To an extent this may depend on the types of client with whom you'll be working, as the retail end of things seems to set the expectations in the market for much of western Europe.
The BRC Agents & Brokers standard might be overkill for you at present, but as it is sort of intended to define retailer expectations for non-manufacturing food suppliers it's perhaps not a terrible place to start as a trigger for further thoughts and ideas. If you're not implementing it for certification then you wouldn't need to worry about some of their more arcane requirements, what they really mean, and how you're supposed to implement them, but equally it may give you ideas for things to think about and incorporate into your "HACCP" plan and associated systems. You can download a copy for free from the BRCGS bookshop here: https://www.brcgsboo...ue-2/c-24/p-286

 

You may work your way through some/all of this and conclude that your business has very limited direct impact on safety or quality, which is reasonable given that you're not physically making or transporting anything, and thus your controls are primarily in relation to choosing the right partners and being able to determine that their controls are suitable. Nonetheless for the purposes of your EHO and your own legal position, the act of going through this process and documenting your conclusion, how you've approached it, the associated supplier records etc. are all going to be very useful.  



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#7 Stephenoloughlin2010

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Posted 29 June 2020 - 02:22 PM

Thanks for the reply pHruit! It's definitely a pain especially when it is a completely new area for us but 100% something I want to get right and take responsibility for. I will certainly check out BRCGS. Thanks for the help.

 

I guess one of the main issues I'm facing is just determining the language/layout I am using is correct and to the standards required. But from what I can see there is no single blueprint that companies use so once I am including the neccessary topics and systems we should be ok?



#8 pHruit

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Posted 29 June 2020 - 02:38 PM

Yes, layout and language to an extent is up to you.
There are some areas where you'll find that larger customers will probably expect to see some sort of specific policy statement per topic (Food Safety, Allergens are two ubiquitous examples), but beyond that the procedures behind them are very much up to you to tailor to suit your business, as long as they cover the relevant areas and are clear about it. You'll then also want to train your colleagues against your procedures and policies, and record this so you can prove that not only do you know what you should be doing as a business, but that everyone in the business knows how to do their part in it ;)

 

You could also try the tools from the FSA for HACCP and associated bits - "Safer food, better business" and MyHACCP (sic). The former is very much focussed on smaller caterers/restaurants and the latter for small food manufacturers, but that doesn't mean that you can't misappropriate lots of bits of them and adapt to your own purposes. It's designed to be an entry into food safety management systems for those who may not have the most experience of them previously, so I certainly can't see why you couldn't borrow as much of it as you needed, if any of it is useful:

https://www.food.gov...better-business

https://myhaccp.food.gov.uk/

 

Obviously you'll also need to make some adaptations, but that's effectively what BRC have done with the standard I suggested - its stolen a lot of content from their own BRC manufacturing standard, changed a few words, removed a couple of bits that aren't relevant if you don't have a factory, but many of the principles are otherwise identical.



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#9 Stephenoloughlin2010

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Posted 29 June 2020 - 02:43 PM

Thank you so much for the help! I honestly am feeling much better about this now!






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