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Given NC in audit for not having product release procedure


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ntay96

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Posted 29 November 2021 - 02:06 PM

Just completed our annual third party audit and we received a NC for not having a product release procedure.

 

To give some context, we are a very small company (Owner, Operations manager, HACCP coordinator, Production Manager and 10 production employees). We process raw poultry and currently operate on automatic release. The production manager fills out and signs off on all the paperwork then the HACCP coordinator reviews it (typically the next day). 

 

The HACCP coordinator leaves an hour before production ends, which cannot be adjusted because she comes in an hour earlier to do pre-op. As a result, the HACCP coordinator is not able to sign off on documents the same day and thus not able to act as the designated employee responsible for release the product.

 

Could the production manager complete the product release? If so, is there a way of incorporating the product release sign off onto the production records instead of requiring another document to be filled out. 

 

Let me know if you have any ideas. 

 

We are not currently GFSI certified. However working towards SQF in 2022. 


Edited by ntay96, 29 November 2021 - 02:07 PM.


olenazh

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Posted 29 November 2021 - 02:28 PM

Whatever convenient for you - but you should have a written procedure describing what you're doing, who's responsible, frequency, etc.



kfromNE

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Posted 29 November 2021 - 03:31 PM

Just completed our annual third party audit and we received a NC for not having a product release procedure.

 

To give some context, we are a very small company (Owner, Operations manager, HACCP coordinator, Production Manager and 10 production employees). We process raw poultry and currently operate on automatic release. The production manager fills out and signs off on all the paperwork then the HACCP coordinator reviews it (typically the next day). 

 

The HACCP coordinator leaves an hour before production ends, which cannot be adjusted because she comes in an hour earlier to do pre-op. As a result, the HACCP coordinator is not able to sign off on documents the same day and thus not able to act as the designated employee responsible for release the product.

 

Could the production manager complete the product release? If so, is there a way of incorporating the product release sign off onto the production records instead of requiring another document to be filled out. 

 

Let me know if you have any ideas. 

 

We are not currently GFSI certified. However working towards SQF in 2022. 

I agree with Olenzah - it needs to be written down. I would use job titles or training (a HACCP certified person) and not names.

 

Not sure about the rules in Canada but for the US, the person signing off on the HACCP paperwork must have taken a HACCP class.

As for paperwork, we don't usually sign off on our paperwork until the next day (before the product has been shipped out).



Scampi

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Posted 29 November 2021 - 05:02 PM

we seem to have missed a step or two here

 

1) Document review CAN be part of product release, but is not required  (so are you talking about doc review or product release)

 

2) There is no federal requirement for poultry (unless it's deli style meat) to have a release program

 

3) If you're talking simply about product release (and your product is raw poultry) then you simply write a statement that says no positive release required.

 

What standard were you audited to?


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ntay96

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Posted 29 November 2021 - 05:50 PM

Given that we process raw chicken. What type of requirements would need to be satisfied in order to release the product?

 

Our products consist of (all raw)

 

1. Fresh and frozen chicken cuts (breasts, wings, legs, drum, tenders, whole birds) packaged for retail or bulk

 

2. Individual Quick Frozen injected chicken 

 

3. Frozen marinated chicken breasts and wings 

 

4. Repackaging of par-fried chicken strips and nuggets

 

 

Other than verifying that labels are correct, what would product release involve? 



Charles.C

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Posted 30 November 2021 - 04:03 AM

Given that we process raw chicken. What type of requirements would need to be satisfied in order to release the product?

 

Our products consist of (all raw)

 

1. Fresh and frozen chicken cuts (breasts, wings, legs, drum, tenders, whole birds) packaged for retail or bulk

 

2. Individual Quick Frozen injected chicken 

 

3. Frozen marinated chicken breasts and wings 

 

4. Repackaging of par-fried chicken strips and nuggets

 

 

Other than verifying that labels are correct, what would product release involve? 

 

Hi ntay,

 

Please answer Scampi's last question. This is a/the Key one ! .


Kind Regards,

 

Charles.C


ntay96

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Posted 01 December 2021 - 02:49 PM

SQF 



Scampi

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Posted 01 December 2021 - 03:19 PM

ntay, what standard gave you a NC?  You said your working towards SQF, or was this a prepartory audit (gap audit) ahead of certification audit

 

This is the question we need the answer to 

3) If you're talking simply about product release (and your product is raw poultry) then you simply write a statement that says no positive release required.


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ntay96

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Posted 01 December 2021 - 06:28 PM

ntay, what standard gave you a NC?  You said your working towards SQF, or was this a prepartory audit (gap audit) ahead of certification audit

 

This is the question we need the answer to 

3) If you're talking simply about product release (and your product is raw poultry) then you simply write a statement that says no positive release required.

 

Yes, preparatory. She said we currently have an automatic release and the HACCP coordinator reviewing the production paperwork the next day was not sufficient enough.  We needed same day inspection of the product. 



Scampi

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Posted 02 December 2021 - 06:07 PM

are you performing any in process checks? does production have a check for packaging?

 

as a side note: I thought that all coated/breaded product now had to be fully cooked or other controls (which would tie into the SQF requirements)

 

https://inspection.c...531254524999#a3


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Leila Burin

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Posted 03 December 2021 - 09:41 AM

Hello, it is mandatory for i.e IFSV7:

"5.7 Product release

5.7.1* A procedure for quarantine (blocking/hold) shall be in place that is justified by risk assessment. The procedure shall ensure that only raw materials, semi-finished and finished products, and packaging materials conforming to product requirements, are processed and dispatched."

 

best regards,

Leila



mgourley

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Posted 04 December 2021 - 06:57 PM

I'm not SQF, but a generic "Positive Release" program basically says that "someone" has reviewed production records and has determined that a particular lot/batch of product is safe to ship.
Since you already have the Production Manager reviewing the paperwork, and the HACCP Coordinator does a review next day. It should be simple enough to write up a policy that spells out what you already do. Thus, you now have a "Positive Release Procedure".
 

Marshall






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