8 replies to this topic

[fafleu]

Hello,

 

I work in a packaging manufacturing company (FSSC22000 certified).

 

During our last audit according to the new version 5.1 of the FSSC22000, the auditor recommended  a bacteriological test of the hands of the staff working in the food area.

 

My question is it required by the standard, for example if it is not done it will be a non-conformity ? but I am not sure if there is regulation on this regard as well as if there are guidelines / good practices about it. 

 

 

Thanks in advance

 

 

 

[Scampi]

No requirement

 

Auditor may have been referring to a verification of proper handwashing.....

[Charles.C]

Hello,

 

I work in a packaging manufacturing company (FSSC22000 certified).

 

During our last audit according to the new version 5.1 of the FSSC22000, the auditor recommended  a bacteriological test of the hands of the staff working in the food area.

 

My question is it required by the standard, for example if it is not done it will be a non-conformity ? but I am not sure if there is regulation on this regard as well as if there are guidelines / good practices about it. 

 

 

Thanks in advance

Hi farfleu,

 

Just to clarify, do you manufacture (a) food or (b) food packaging ?

 

If (a) what kind of food, what kind of product, how is it packed/stored, is it RTE, refrigerated, frozen  ?

if (b) what kind of food packaging, eg plastic intended for direct food contact ?

[Tony-C]

Hi fafleu,

 

This requirement isn’t specifically stated in any of the documents that are part of the FSSC 22000 Certification Scheme.

 

I would take the view that your verification of prerequisite programmes should be proportionate to the hazard and risk involved. For example, if your packaging is being handled by your staff and that packaging is in direct contact with ready-to-eat (RTE) then I would expect quite stringent hygiene controls and periodic verification of hand hygiene by microbiological testing would more than likely be wise.

 

If we are talking about a cardboard outer box for secondary packaging then I would not expect to see verification of hand hygiene by microbiological testing.

 

I have underlined what I see as the relevant requirements in the FSSC Scheme:

 

For Food Packaging, the FSSC 22000 Certification Scheme is based on:

ISO 22000 requirements for any organization in the food chain

Relevant prerequisite programs (PRPs) based on technical specifications for the sector (ISO/TS 22002-4 in this case)

FSSC 22000 Additional Requirements - FSSC 22000 SCHEME VERSION 5.1 Part 2 | Requirements for organizations to be audited

 

INTERNATIONAL ISO STANDARD 22000 Second edition 2018 Food safety management systems — Requirements for any organization in the food chain

8.8 Verification related to PRPs and the hazard control plan

8.8.1 Verification

The organization shall establish, implement and maintain verification activities. The verification planning shall define purpose, methods, frequencies and responsibilities for the verification activities.

The verification activities shall confirm that:

a) the PRP(s) are implemented and effective;

 

Technical Specification ISO 22002-4 Prerequisite Programmes on Food Safety – Part 4: Food Packaging Manufacturing Requirements

 

4.7 Measures for Prevention of Contamination

4.7.2 Microbiological Contamination

Where there is a potential for microbiological contamination measures shall be implemented to prevent or control the hazard.

 

4.10 Personnel Hygiene & Facilities

4.10.1 General Requirements

Requirements for personal hygiene and behaviour proportional to the hazard posed to the food packaging shall be established and documented.

 

Kind regards,

 

Tony

Edited by Tony-C, 06 November 2022 - 05:48 AM.

[fafleu]

Hi farfleu,

 

Just to clarify, do you manufacture (a) food or (b) food packaging ?

 

If (a) what kind of food, what kind of product, how is it packed/stored, is it RTE, refrigerated, frozen  ?

if (b) what kind of food packaging, eg plastic intended for direct food contact ?

Hi charles, 

it is b : cardboard food packaging, direct contact

[fafleu]

Hi fafleu,

 

This requirement isn’t specifically stated in any of the documents that are part of the FSSC 22000 Certification Scheme.

 

I would take the view that your verification of prerequisite programmes should be proportionate to the hazard and risk involved. For example, if your packaging is being handled by your staff and that packaging is in direct contact with ready-to-eat (RTE) then I would expect quite stringent hygiene controls and periodic verification of hand hygiene by microbiological testing would more than likely be wise.

 

If we are talking about a cardboard outer box for secondary packaging then I would not expect to see verification of hand hygiene by microbiological testing.

 

I have underlined what I see as the relevant requirements in the FSSC Scheme:

 

For Food Packaging, the FSSC 22000 Certification Scheme is based on:

ISO 22000 requirements for any organization in the food chain

Relevant prerequisite programs (PRPs) based on technical specifications for the sector (ISO/TS 22002-4 in this case)

FSSC 22000 Additional Requirements - FSSC 22000 SCHEME VERSION 5.1 Part 2 | Requirements for organizations to be audited

 

INTERNATIONAL ISO STANDARD 22000 Second edition 2018 Food safety management systems — Requirements for any organization in the food chain

8.8 Verification related to PRPs and the hazard control plan

8.8.1 Verification

The organization shall establish, implement and maintain verification activities. The verification planning shall define purpose, methods, frequencies and responsibilities for the verification activities.

The verification activities shall confirm that:

a) the PRP(s) are implemented and effective;

 

Technical Specification ISO 22002-4 Prerequisite Programmes on Food Safety – Part 4: Food Packaging Manufacturing Requirements

 

4.7 Measures for Prevention of Contamination

4.7.2 Microbiological Contamination

Where there is a potential for microbiological contamination measures shall be implemented to prevent or control the hazard.

 

4.10 Personnel Hygiene & Facilities

4.10.1 General Requirements

Requirements for personal hygiene and behaviour proportional to the hazard posed to the food packaging shall be established and documented.

 

Kind regards,

 

Tony

Hi,

 

Thank you Tony  for the justification. the food packaging (cardboard) is in direct contact with food: 

 

the Requirement 4.7.2, according to our hazard control plan, we have planned for the biological hazard:

- Staff awareness for reporting any illness or injury and good hygiene practices

- Display of instructions for good hygiene practices

 

plus we added an instruction : BACTERIOLOGICAL TEST PROGRAM FOR HANDS to confirm hazard control measures

[fafleu]

No requirement

 

Auditor may have been referring to a verification of proper handwashing.....

Hi,

 

Yes to improve that the verification is conform

[JensV]

plus we added an instruction : BACTERIOLOGICAL TEST PROGRAM FOR HANDS to confirm hazard control measures

 

Hi Fafleu

 

For the bacteriological test program, I would suggest a indicator parameter for hygiene, like coliforms.

 

In this context typical hand-contact surfaces are also useful to monitor, e.g. door handles, push buttons, ...

[Charles.C]

Hi,

 

Yes to improve that the verification is conform

 

Hi fafleu,

I assume this is a high temperature production process which will probably deliver a near sterile item.

 

For micro. hands/food see this attachment/post/thread -

https://www.ifsqn.co...ces/#entry71827

 

For micro.hands/packaging see Pg 831 et seq of 2nd attachment in this Post -

https://www.ifsqn.co...ing/#entry51214

(rest of thread may be of micro.interest also)

(can compare data to specs for food process/packaging product).