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Supply Chain Controls in a Food Safety Plan

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kettlecorn

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Posted 04 October 2022 - 10:10 PM

Hello, a non conformance we got was our food safety plan did not identify supply chain controls. I am looking for clarification on exactly what that means. We have a robust supplier approval program separate from our food safety plans for each individual supplier and ingredient go through an approval process but I am just not sure what needs to be included on the food safety plan.

 

 

Thank you.



Gelato Quality Lead

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Posted 04 October 2022 - 10:46 PM

Would definitely recommend to ask auditor, if possible.

 

My guess would be that you are missing supply chain controls in your hazard analysis.

 

Not sure what your supplier approval program details are, but this could be that items coming in from supplier can be contaminated (physical, chemical, biological). For us, we require COAs for high-risk ingredients and we ensure that packaging is intact upon arrival. 

 

Not sure if this is helpful in any way, we will need more details about your current procedures to really know what is missing.



Setanta

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Posted 05 October 2022 - 02:32 PM

Who gave you the non-conformance? What is the wording of the NC?


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kettlecorn

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Posted 10 October 2022 - 05:53 PM

NSF Auditors during our SQF audit wrote the following non conformance

 

"2.4.3.17 (minor) The facility is required to comply with an FDA FSMA Preventive Controls Plan. The Food Safety Plans do not identify all the preventive controls required by the FDS's Preventive Controls Legislation. For example, the food safety plans do not identify Supply Chain Controls"  


Edited by kettlecorn, 10 October 2022 - 05:53 PM.


Gelato Quality Lead

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Posted 10 October 2022 - 06:01 PM

So then what are your procedures for "controlling" the supply chain? Supplier approval is great but you have to talk about that in your Preventive Controls and how your supplier approval will prevent from possible issues caused by the supply chain.

 

First step would be to identify the most likely problems to occur. 



kettlecorn

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Posted 10 October 2022 - 06:07 PM

Would this include hazards such as food fraud, undeclared allergens, and microbial contamination(COA's)? 



Setanta

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Posted 10 October 2022 - 06:11 PM

Yes, among others.


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kettlecorn

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Posted 10 October 2022 - 06:13 PM

I understand, thank you everyone for your help.





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