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