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ukOTLuk

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Posted 15 February 2022 - 11:13 AM

Hi I'm looking for some advice on this area of the standard.  As the company is not invovled in any actual manufacturing alot of the items within the plan will be convered by pre-requisites covered by the manufacturer who supploes the finished products.  Is it acceptble to show this as a PRP and refer to the Manufacturer or service providers contract or suplier approbal process?  For example - Hygeine - as the company does not produce or actually handle any unpacked product, and all distribution and warehouseing is outsourced, there are no intermal documents or procedures that cover this, but obviously the service providers the company entrusts this too have been approved to ensure they comply with GFSI accreditiations etc.....

 

I just want to make sure I'm not missing something....  Thanks!

 



Brendan Triplett

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Posted 15 February 2022 - 12:37 PM

Are you building this out against a HACCP Plan?  In distribution and warehousing I was able to have this covered under a PRP and reviewed further in the company GDPs.  It was not a CCP for us (only time and temperature).  We mention in the plan that all product is packaged under manufacturer specifications and at no time is product removed from the primary or secondary packaging.  Any damaged product would be recorded and destroyed per manufacturer guidance.

 

Robust PRPs and GDPs (or in some case GMPs, depending on what you are doing) will cover a lot of sins and save you from making a bunch of CCPs.

 

Hope this helps.

 

Cheers!


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pHruit

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Posted 15 February 2022 - 02:21 PM

This is an interesting section of the standard to try to get to grips with, if you're used to HACCP in terms of manufacturing applications or even storage & distribution, where there is at least something tangible physically in your control that you're assessing.

In some ways you can perhaps view the A&B safety plan requirements as a HACCP plan for the processes that are either directly or indirectly in your control - some of it might be paperwork related, a lot of it will be steps that are subcontracted to service suppliers, but which you are responsible for organising / specifying.

You'll still need to go through the hazard analysis process, but it's not unreasonable to conclude that many of the potential risks are managed via your supplier approval system - if they weren't, then you'd potentially have to wonder if your supplier assessment process was fit for purpose!

 

There are quite a few threads on section 2 (or parts thereof) in the Agents & Brokers section of the forum that may be worth a look through - circa 50% of the first twelve threads are on things related to this: https://www.ifsqn.co...ts-and-brokers/



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Foodworker

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Posted 19 February 2022 - 04:48 PM

I have to admit that I think that this section is risk assessment for risk assessment's sake. You have to work hard to find anything which is not under the control of a sub-contractor.

 

For food I can see some aspects that may be important, eg the A&B's Purchasing and Sales people making sure that foods are sold within shelf life and that any temperature issues are within contracts, but for non foods it is even less relevant.

 

This is what I dreamed up for a non food operation which had the auditor's attention for less than 5 minutes before ticking the box and moving on. He had the same opinion as me.

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Edited by Foodworker, 19 February 2022 - 04:49 PM.


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