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SQF FSC2 2.4.2 Module 18 - GAP SOP Template or ideas for Indoor Agricultural

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sinchitakapuria

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Posted 31 March 2022 - 04:33 PM

Hello everyone,

 

I have to write the GAP SOP for my facility. It is an indoor hydroponic agriculture facility for leafy greens. I am so lost in how to approach writing a GAP SOP (for SQF FSC2 2.4.2 Module 18). Does anyone have any template or their GAP plan that they can share so that I at least have a reference or an idea on how to proceed?

 

Thanks

 



Kara S.

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Posted 01 April 2022 - 04:29 PM

I am actually doing research on hydroponics and vertical farms for my company at the moment. It is related more towards sanitary design but I have found some good sources of information. Maybe we can assist each other?

 

For indoor farming, I think following a mix of regulations is the best method for indoor farming. I would recommend reading 21 CFR Part 112 Subpart B, C, and L as well as 21 CFR 117 Subpart B. I think a combination of using 112 for the growing areas and 117 for the harvesting, processing, and packaging equipment would be ideal. Some ideas include: 

  • Employee hygiene requirements (controlled shoe program, gloves, not working when sick, wearing a lab coat/secondary barrier in pack halls, etc.)
  • training on how to protect the product (not touching without gloves, if it touches the ag. water then to toss it or sanitize it)
  • tool storage and sanitation 
  • standard cleaning of the facility. 

Links to resources:

 

 

As a somewhat related question - we are trying to create a good flow for a facility that has some live plants that they sell in the growth media/ soil and some leafy green heads with the roots still attached. They also have salad mixes. They want everything to be packaged within the same room. We feel like because they are not having a sanitizing/wash/kill step - that the live and root plants should be separated from the other areas. Do you agree that there are biological hazards associated with (1) bringing the growth media in to the packing room that is shared with all processes and (2) keep the roots on the product and not washing it? (3) is the product from indoor farms truly RTE/ no need to wash if there was no wash or sanitizing step?


Kind regards, 

 

Kara

Food & Beverage Industry Consultant

IFSQN Business ListingLinkedIn  |  Webpage

 

 


sinchitakapuria

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Posted 04 April 2022 - 02:40 PM

I am actually doing research on hydroponics and vertical farms for my company at the moment. It is related more towards sanitary design but I have found some good sources of information. Maybe we can assist each other?

 

For indoor farming, I think following a mix of regulations is the best method for indoor farming. I would recommend reading 21 CFR Part 112 Subpart B, C, and L as well as 21 CFR 117 Subpart B. I think a combination of using 112 for the growing areas and 117 for the harvesting, processing, and packaging equipment would be ideal. Some ideas include: 

  • Employee hygiene requirements (controlled shoe program, gloves, not working when sick, wearing a lab coat/secondary barrier in pack halls, etc.)
  • training on how to protect the product (not touching without gloves, if it touches the ag. water then to toss it or sanitize it)
  • tool storage and sanitation 
  • standard cleaning of the facility. 

Links to resources:

 

 

As a somewhat related question - we are trying to create a good flow for a facility that has some live plants that they sell in the growth media/ soil and some leafy green heads with the roots still attached. They also have salad mixes. They want everything to be packaged within the same room. We feel like because they are not having a sanitizing/wash/kill step - that the live and root plants should be separated from the other areas. Do you agree that there are biological hazards associated with (1) bringing the growth media in to the packing room that is shared with all processes and (2) keep the roots on the product and not washing it? (3) is the product from indoor farms truly RTE/ no need to wash if there was no wash or sanitizing step?

Thanks for you reply Kara. I will look into those and start building our GAP plan. To answer your questions:

Bringing the growth media into the processing room shouldn't be a problem, but leaving the roots in might be. The media is teeming with microbiological activity, and probably also has pest activity in them. The produce grown in indoor farms are truly RTE provided everything is being tested (like water, etc.). But is hard to tell as I don't know their practices. In our facility it truly doesn't get in contact with human hands at any point of time.

 

Thanks, I would love to work with you regarding this subject



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Kara S.

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Posted 04 April 2022 - 05:24 PM

I am actually doing research on hydroponics and vertical farms for my company at the moment. It is related more towards sanitary design but I have found some good sources of information. Maybe we can assist each other?

 

For indoor farming, I think following a mix of regulations is the best method for indoor farming. I would recommend reading 21 CFR Part 112 Subpart B, C, and L as well as 21 CFR 117 Subpart B. I think a combination of using 112 for the growing areas and 117 for the harvesting, processing, and packaging equipment would be ideal. Some ideas include: 

  • Employee hygiene requirements (controlled shoe program, gloves, not working when sick, wearing a lab coat/secondary barrier in pack halls, etc.)
  • training on how to protect the product (not touching without gloves, if it touches the ag. water then to toss it or sanitize it)
  • tool storage and sanitation 
  • standard cleaning of the facility. 

Links to resources:

 

 

As a somewhat related question - we are trying to create a good flow for a facility that has some live plants that they sell in the growth media/ soil and some leafy green heads with the roots still attached. They also have salad mixes. They want everything to be packaged within the same room. We feel like because they are not having a sanitizing/wash/kill step - that the live and root plants should be separated from the other areas. Do you agree that there are biological hazards associated with (1) bringing the growth media in to the packing room that is shared with all processes and (2) keep the roots on the product and not washing it? (3) is the product from indoor farms truly RTE/ no need to wash if there was no wash or sanitizing step?

 

 

Thanks for you reply Kara. I will look into those and start building our GAP plan. To answer your questions:

Bringing the growth media into the processing room shouldn't be a problem, but leaving the roots in might be. The media is teeming with microbiological activity, and probably also has pest activity in them. The produce grown in indoor farms are truly RTE provided everything is being tested (like water, etc.). But is hard to tell as I don't know their practices. In our facility it truly doesn't get in contact with human hands at any point of time.

 

Thanks, I would love to work with you regarding this subject

 

 

Hope it helps! Those will at least give you some categories to structure your policy. The auditor is just looking for how you comply with the code's GMPs/GAPs (Module 18) since they may have not been to your facility. It's just an overview of employee practices and plant rules that you expect everyone to follow. You may show that GAP's are implemented by performing an internal audit against the policy. 

 

Thanks for your response! Most of the indoor farms I have worked with do not have a fully automated system and have to use some manual labor to move rafts or do some tasks in packaging. They do testing. Your comment about the media and its relation to microbiological activity is what worries us with having the live plant being packaging within the same room as salad mixes. We don't want to compromise hygienic zoning and have the risk of introducing & spreading microbes throughout the space because of the growth media and roots. We would rather design out the hazard than have it be managed through sanitation controls. 

 

Still in the process of doing our own internal risk assessments and research. Thanks for your input! 


Kind regards, 

 

Kara

Food & Beverage Industry Consultant

IFSQN Business ListingLinkedIn  |  Webpage

 

 


kingstudruler1

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Posted 05 April 2022 - 07:42 PM

Im not sure what you are asking.    Are you asking for how to meet 2.4.2?    Or, how to meet all of modules 10 & 18?  

 

I'm guessing all of 10 & 18 (which will be your GAP program) .   For that, you can certainly have policy statements stating for each section / clause.   For clauses that begin with/contain the "the methods and responsibilities", you need to have a specific procedure(s) and responsibilities  on how you will meet  each requirement of the clause.   

 

Don't overthink it too much.   For each clause or clause element ask your self, "how will I prove to someone else that we are complaint with this section"   It may me a policy, procedure, record, or an observation, or a combination of these.   

 

I have never worked in module 10 or 18, so I don't have any templates or examples that would make sense.    Hopefully some one can share some of their work.   


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Charles.C

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Posted 06 April 2022 - 12:54 AM

Hello everyone,

 

I have to write the GAP SOP for my facility. It is an indoor hydroponic agriculture facility for leafy greens. I am so lost in how to approach writing a GAP SOP (for SQF FSC2 2.4.2 Module 18). Does anyone have any template or their GAP plan that they can share so that I at least have a reference or an idea on how to proceed?

 

Thanks

If you are starting SQF from ground zero and have a budget, might be advantageous to consider a Consultant.

 

eg see this sub-Forum -

 

https://www.ifsqn.co...g-and-services/


Kind Regards,

 

Charles.C




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