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ISO 22000: 2018 Clause 8.4.2 - Emergency Preparedness Testing

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ft.tgif

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Posted 23 December 2022 - 02:56 AM

A little background about our manufacturing facility:

- Products manufactured in this facility: confectionery products (e.g. Rainbow sprinkles, colored sprinkles, chocolate covered nuts) 

- FSSC 22000 and Kosher certified. 

- Geographical information: Southeast Asia, tropical climate (temperature ranges from around 25c to 36c with very high humidity all year round).

- Possible natural disasters: floods only, and due to being on the west coast of the country, we don't even get affected by the monsoon season like the east coast, so even when we do have floods, it's nothing severe. We also do not have any earthquakes or volcanoes too, no snow, no hurricanes, no yearly bush fires.  

 

We currently do mock drills for only these scenarios (annually): fire, power failure, and water supply disruption.

 

And we always find a way to relate this to food safety by performing stock checks on our WIP materials and finished products as part of the emergency response plan. The thing is, we always perform these mock drills as a simulation, and we try to make it as close to reality as possible, as if it is actually happening. So like for a power failure, we would turn off the electricity for the section, or in the case of water supply disruption, we would turn off the water supply intentionally. These are all recorded in our emergency activity log and we specifically mention that they are turned off intentionally to simulate the actual scenario. For fire, of course we don't set up a fire in the plant, we would just specify that an imaginary fire is happening at a specific location of the plant, and as a simulation we would evacuate all employees out of the building. 

 

My question is, is performing only these scenarios that were listed above, sufficient? or do we have to do mock drills for some other scenarios like floods, environmental contamination, workplace accidents?

 

We were told by our consultant to not "lie" or "pretend as things really happen" when recording mock drill activities in the log, which is why I find it hard if we were to do mock drills for any other scenarios that we can't really simulate in real time, as we can't just "pretend" like "oh, there's a huge flood incoming, water levels are getting high and it's starting to enter our production area and warehouse. 

 

The point being, please let me know if it's okay for me to continue doing just these 3 mock drills annually (fire, power failure, and water supply disruption), we are not really looking to add more mock drills unless it's mandatory/necessary based on the ISO/FSSC standard. 


Edited by ft.tgif, 23 December 2022 - 02:59 AM.


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Evans X.

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Posted 23 December 2022 - 09:28 AM

Greetings Ft,

 

No there is no actual need to perform other scenarios and the way you perform it is more than adequate. Many companies don't actually cut the power or stop the water flow, they just call it out and then observe! The point is to measure reaction times and the actions you do during and after regarding the safety of the personnel and the products.

Also, mock drill is a "lie" in on itself, a scenario meaning to test the reactions of an event in case it happens in real time, so what does don't "lie" mean ?!!

Simplest example is fire scenario. You will measure reaction time of personnel to evacuate and if it was done orderly, the reaction time of the appointed fire extinguish team and how they handled the equipement they were trained at, the reactions of those in charge to emergency shut down the equipment. Afterwards the actions taken after the "fire" is gone like checking freezing chambers temperatures, how and if the products were affected, do they need to be withdrawn or even tested microbiologically, what are the steps taken to ensure that they are safe for consuption and if not what happens, were the approrpiate interested parts notified, are their contact info readily available.

Point is that you act like something happened and check out if all went accοrding to the established procedure/method.

Don't do more mock drills than what you already do, but include in your procedures actions for every possible scenario you have identified.

Also, you didn't mention pandemic scenario, since it was a hot issue the last 2 years. This time we got lucky, but what will you do if the next one is a foodborne virus?!!!

 

Regards!



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ft.tgif

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Posted 23 December 2022 - 02:05 PM

Greetings Ft,

 

No there is no actual need to perform other scenarios and the way you perform it is more than adequate. Many companies don't actually cut the power or stop the water flow, they just call it out and then observe! The point is to measure reaction times and the actions you do during and after regarding the safety of the personnel and the products.

Also, mock drill is a "lie" in on itself, a scenario meaning to test the reactions of an event in case it happens in real time, so what does don't "lie" mean ?!!

Simplest example is fire scenario. You will measure reaction time of personnel to evacuate and if it was done orderly, the reaction time of the appointed fire extinguish team and how they handled the equipement they were trained at, the reactions of those in charge to emergency shut down the equipment. Afterwards the actions taken after the "fire" is gone like checking freezing chambers temperatures, how and if the products were affected, do they need to be withdrawn or even tested microbiologically, what are the steps taken to ensure that they are safe for consuption and if not what happens, were the approrpiate interested parts notified, are their contact info readily available.

Point is that you act like something happened and check out if all went accοrding to the established procedure/method.

Don't do more mock drills than what you already do, but include in your procedures actions for every possible scenario you have identified.

Also, you didn't mention pandemic scenario, since it was a hot issue the last 2 years. This time we got lucky, but what will you do if the next one is a foodborne virus?!!!

 

Regards!

Hi Evans, 

 

Thanks for the clarification.

 

I guess by "don't lie", what my consultant meant was to make sure we word our sentences in our activity log in a way that shows that the scenarios during our mock drill did not actually happen in real life. This is due to our previous mock drill logs where they were worded in a way as if it really did happen, I saw one of our old logs for a fire drill, and the previous QA person literally wrote that there's smoke everywhere and they used a fire extinguisher to extinguish the fire (yes, it was a fire drill, not actual accident). 

 

Something that still confuses me about mock drills is that, like what you said, after the fire drill, we would have to "notify the interested parties", how can we test on these sort of activities though? Do we actually have to call them? Same for the checking of finished products to determine whether we need to recall/withdraw or test microbiologically, do we actually have to check our finished products during the mock drill and measure the time taken? Because since it didn't really happen, if we were to actually check our finished products, how would we even check on those things since basically all our finished products would have no issues. We do have these activities included in our response plan for fires, but during our mock drill we don't actually do these activities, what we do is just counting the quantity of finished products and WIP materials we have in our inventory. 

 

We actually do have a response plan for pandemics, but it was written in a very general way to cover everything like monitoring for any announcements and adhering to any rules implemented by the government or health authorities, prepare for any mandatory lockdowns, and notifying customers of any delays of shipment due to the pandemic affecting our production output. I just couldn't really think of a way to test this response plan. 

 

And thank you for reminding me about foodborne viruses/pathogens, we only do mock recalls on that but it's not included in our emergency response procedures. I'll be updating our procedure to include it. 



Charles.C

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Posted 25 December 2022 - 01:11 PM

Hi ft.tgif,

 

There are many related examples on this  Forum which you can study.

Post 2 gives useful advice.


Kind Regards,

 

Charles.C


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Evans X.

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Posted 27 December 2022 - 08:54 AM

Hi again and Merry X-mas,

 

No there is no need to call the interested parties or actually check the products. Since you mentioned these two examples, what you need to check out in your list are things like:

1. Is the list of interested parties readily available/easy to access and does the personnel responsible for the contacting know where to find this list if you ask them? And maybe even what is the priority eg Fire department before calling even your boss !!!

2. For the products you can do a minor traceability check to identify which lots are in the storage at the time of the drill and report something like "The lots 1, 2, 4 were in storage at the time of the drill and samples from those would be sent for checking" (if needed, depending on the drill).

 

There is no real need to do a mock drill for pandemic, as it is mostly guided by the national authorities and according to medical reports on the nature of the virus. So even if you tried to do something it could be far from the issued guidelines and it can vastly differ between foodborne/non-foodborne/human transmitted/animal transmitted/pandemic/endemic etc. The procedure for the general response alone is enough documentation.

 

As Charles C. mentioned with a search around the forum you can find other ideas too, that other members have kindly contributed!

 

Regards!



Vasilis Theodossiou

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Posted 17 May 2023 - 10:38 AM

Hello to all i thought not to start a new topic with the same title and I would like to address a incident during an audit concerning 8.4.2 : 

 

An auditee during an iso 22000 audit was asked to show his preparedness testing and he showed his traceability mock recall instead. He said that his mock recall covers the requirements of 8.4.2 (the recall happened because of an emergency situation and can affects food safety). So he thought under this notion covered both requirements (8.3 & 8.4.2). 

 

I would like to hear some opinions please on the matter. Is his approach acceptable? 

 

Thank you very much in advance for your opinions.  

 

P.S. As for the initial post of Ft I will say that the three scenarios are efficient. However it would be good for the company to be proactive for the future and practice in different emergency scenarios. You do not when and where the crisis will burst. It is a good practice to have a wide range of tests. 

 

Vasilis Theodossiou


Quality means doing it right when no one is looking - Henry Ford


Evans X.

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Posted 17 May 2023 - 11:15 AM

Hello Vasilis,

 

As per their descriptions in their respective paragraphs of the ISO 22000 standard, they are different things. Traceability (and mock recall) covers situations that are within the company's control and if they go wrong then the product is unsafe (e.g. insufficient pasteurization temp/time, cold storages not working within set limits, mislabelling, defect metal detectors, cross-contamination, allergens, even food defense since it is actively monitored etc). It covers anything from raw materials to product on the shelves and your ability to get it back in case of a safety problem and it is not defined by any specific situation.

 

Emergency refers to things out of the company's control (fire, flood, tornado!, power outage, pandemic etc). Also, in most cases the product will still be in the facilities. Resulting from the above scenarios your check afterwards determines if everything is in order to keep producing safe products (equipment, facilities, personnel) and if the products you had inside are still safe for consumption. Emergencies in most likely will not result in recalls but you do need at least the internal traceability.



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