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Food Safety Management System vs Food Safety Plan... Food Safety Policy?

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NorCalNate

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Posted 13 June 2023 - 08:44 PM

I'm creating our Food Safety Management System document for SQF and am pretty confused on the following requirements under 2.2.1.1. For reference, we are a Winery who produces and bottles our own wine:

 

i. A summary of the organization's food safety policies and methods it will apply to meet requirements of this standard

ii. The food safety policy statement...

vi. Food Safety procedures, prerequisite programs, food safety plans

vii. Process controls that impact product safety

 

Here are my questions:

 

1. What Policies fall under the definition of "Food Safety Policy"? GMPs? Glass and Brittle Plastics? Foreign Material Control? Is there a list?

 

2. What is a "Food Safety Policy Statement"? We have a Management Commitment Policy which contains a statement from Management, not sure if that suffices? 

 

3. What specifically is considered a "Food Safety Policy"? Currently we have a HACCP Plan, though I'm not sure if this would be considered our Food Safety Policy?

 

4. What are considered "Food Safety Procedures"? There are obviously procedures like Glass or Brittle Plastic Breakage, but since there's not a definition I don't know where to start!

 

5. For "Process Controls that impact product safety", I was thinking things like filtration and sparging bottles prior to filling but I wasn't sure if incoming material inspections or trailer inspections also met this criteria? Again, any help defining this would help me out.

 

6. I've looked everywhere for an example of a Food Safety Management System, but haven't had any luck. Would greatly appreciate if someone could send me one!



Scotty_SQF

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Posted 14 June 2023 - 11:06 AM

I like to think of the Food Safety Management System as the company's SQF program itself.  Basically it is the programs and policies you have in place for food safety.  For example: how you are minimizing, how you are controlling, how you are preventing, how you are greatly reducing food safety risks.  It should include your HACCP program, yes, but it also goes a bit beyond just your HACCP program.  The programs and policies of your Food Safety Management system should include all the mandatory programs required by SQF.

 

All policies that are are mandatory elements per SQF and any other policies you have in place that your company utilizes for food safety should be included.  I actually think the SQF code is clear on what you need to have for the Food Safety policy: Section 2.1.1.1  (same as the policy statement management is to put together).  Food Safety Policy is how your site is committed to manufacturing, supplying, etc. safe food through following legislation and such.  I could go on and on, but do not have enough room and I'm sure others will comment to help out as well.  Our food safety management system is basically like an overview of the policies and programs we have in place to support food safety, kind of like how we have our quality management system.   Then at the end we have the SQF register that goes through each section of the code and then lists which of our SOPs, policies and programs we have that support that portion of the code.

 

Hope this helps somewhat and makes some sense.



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Sayed M Naim Khalid

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Posted 14 June 2023 - 12:38 PM

Hello, 

Food safety policy a brief - mostly 1 pager document that declares to the employees the commitment of the leadership to food safety. It is aligned with the business goals and it is VERY high level. 

Here is an example of "Food Safety Policy Statement": 
________________________________________________________________________________________________________________________

Food Safety Policy Statement

The management of [food company name] is committed to providing safe and wholesome food to our customers. We will achieve this by:

  • Following all applicable food safety laws and regulations.
  • Implementing and maintaining a comprehensive food safety program.
  • Training all employees on food safety procedures.
  • Maintaining a clean and sanitary environment.
  • Using only safe and wholesome ingredients.
  • Properly handling, storing, and cooking food.
  • Monitoring food safety conditions on a regular basis.

We are committed to providing our customers with a safe and enjoyable dining experience. We believe that food safety is an essential part of providing quality service.

Name and Signature of TOP level person in the company

_______________________________________________________________________________________________________________

Question 4: food safety procedure: a procedure is a step by step document that tells the employees how to make sure that a product is made, produced, manufactured, stored, transported, thawed, chilled... safely. When speaking about safety of product, you make sure that your product is not causing biological, physical or chemical hazard to your customers.

you can make several procedures part of GMP and HACCP. A combination of all these procedures, HACCP plan, and the records generated by these procedures, are collectively called food safety plan.

 

Here is a sample food safety procedure:
_________________________________________________________________________________________________

Glass Control Procedure

Purpose: To prevent glass from contaminating food and to ensure the safety of food handlers and customers.

Scope: This procedure applies to all glass used in the food service operation, including glassware, windows, and doors.

Key Words: Glass, contamination, food safety, hazard, risk

Instructions:

  1. All glass must be clean and free of debris before it is used.
  2. Glassware must be washed and sanitized after each use.
  3. Windows and doors must be kept clean and free of cracks or chips.
  4. Broken glass must be removed immediately and disposed of properly.
  5. Employees must be trained on the proper handling of glass.
  6. A system must be in place to monitor the implementation of this procedure.

Training: All employees who handle glass must be trained on the proper procedures for handling and cleaning glass. This training must include the following:

  • The importance of keeping glass clean and free of debris.
  • The proper way to wash and sanitize glassware.
  • The importance of reporting broken glass immediately.
  • The proper way to dispose of broken glass.

Monitoring: The manager or designated food safety officer must monitor the implementation of this procedure. This monitoring should include the following:

  • Inspections of glassware and other glass surfaces to ensure that they are clean and free of debris.
  • Inspections of windows and doors to ensure that they are free of cracks or chips.
  • Investigation of any incidents of broken glass.

Records: The manager or designated food safety officer must maintain records of glass control training and monitoring. These records should include the following:

  • The dates of training sessions.
  • The names of employees who attended training sessions.
  • The results of inspections.
  • The results of investigations into incidents of broken glass.


_________________________________________________________________________________________________

 

Question 6: Food Safety Management System is coming from two sources: 1) laws applied to your facility , 2) a food safety standard your follow. 
Let's say you operate in the US, you need to follow the federal food safety requirements, state and city requirements for food safety. In order to follow them, you may need to the following: 

  1. Have food safety operations in written format (written procedures, documented corrective actions, documented recalls, documented inventory, temperature control records, training records.... 
  2. Train your employees
  3. Keep records of receiving, shipment, cooking, cleaning, Transporation, recalls, ...
  4. Conduct regular reviews/monitoring and inspections and take actions for any shortcomings for example if a mouse was found in your facility, what did you do? what actions did you take? Did you find the root cause? Is the issue resolved? If not, what is going to happen? 

 

A sum of all the above is a brief food safety management system

If your company is rich, then you can work on a GFSI standard like FSSC 22000, BRC, SQF, IFS... to certify and when you follow their procedures. You gonna make few bundles of binders, books, procedures... which will be called a food safety management system. DO THIS ONLY IF YOU ARE RICH or JUST WANT TO SHOW OFF. 

_________________________________________________________________________________________________

Hope the above information helps.

Thanks,

Sayed M Naim Khalid
FSQA Professional


Edited by Sayed M Naim Khalid, 14 June 2023 - 12:47 PM.


G M

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Posted 14 June 2023 - 01:49 PM

I'm creating our Food Safety Management System document for SQF and am pretty confused on the following requirements under 2.2.1.1. For reference, we are a Winery who produces and bottles our own wine:

 

i. A summary of the organization's food safety policies and methods it will apply to meet requirements of this standard

ii. The food safety policy statement...

vi. Food Safety procedures, prerequisite programs, food safety plans

vii. Process controls that impact product safety

 

Here are my questions:

 

1. What Policies fall under the definition of "Food Safety Policy"? GMPs? Glass and Brittle Plastics? Foreign Material Control? Is there a list?

 

2. What is a "Food Safety Policy Statement"? We have a Management Commitment Policy which contains a statement from Management, not sure if that suffices? 

 

3. What specifically is considered a "Food Safety Policy"? Currently we have a HACCP Plan, though I'm not sure if this would be considered our Food Safety Policy?

 

4. What are considered "Food Safety Procedures"? There are obviously procedures like Glass or Brittle Plastic Breakage, but since there's not a definition I don't know where to start!

 

5. For "Process Controls that impact product safety", I was thinking things like filtration and sparging bottles prior to filling but I wasn't sure if incoming material inspections or trailer inspections also met this criteria? Again, any help defining this would help me out.

 

6. I've looked everywhere for an example of a Food Safety Management System, but haven't had any luck. Would greatly appreciate if someone could send me one!

 

There is a lot of overlap here, they're not exclusive terms.  

 

1&3. All your examples are potentially Food Safety Policies -- does it address food safety, and declare or explain why something is being done, and maybe also who is responsible for it, and is probably designed for the infrequent person reading it to understand your process at a 'high' or 'broad stokes' level, then it's probably a food safety policy.  It may even explicitly claim something along the lines of "we stay in compliance with XXX regulation by following YYY procedures."

 

2. Food Safety Policy Statement -  do you post it for the team members to see, or share it with your suppliers or customers to make it clear to them what your intentions and expectations are for food safety, then its probably a food safety policy statement.

 

4. Food Safety Procedures - does it explain how something is done related to food safety, perhaps in some detail, and is probably designed for an employee to use when performing some routine task, then its probably a food safety procedure.

 

5. Process controls that impact food safety - is relatively self explanatory.  Something that is done to make product, because that is how the product is made either as part of its standard of identity or just because that's how you chose to make it your way -- and it has some impact on food safety.

 

6. Food Safety Management System -- primarily needs to contain your policies, but it can also contain procedures and forms if you feel like organizing it that way to avoid redundancy etc.  (If an auditor came in and asked to see our "food safety management systems" I would hand them the all of the Prerequisite Programs, HACCP Plan, and SQF Program documents.)



NorCalNate

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Posted 14 June 2023 - 02:47 PM

I like to think of the Food Safety Management System as the company's SQF program itself.  Basically it is the programs and policies you have in place for food safety.  For example: how you are minimizing, how you are controlling, how you are preventing, how you are greatly reducing food safety risks.  It should include your HACCP program, yes, but it also goes a bit beyond just your HACCP program.  The programs and policies of your Food Safety Management system should include all the mandatory programs required by SQF.

 

All policies that are are mandatory elements per SQF and any other policies you have in place that your company utilizes for food safety should be included.  I actually think the SQF code is clear on what you need to have for the Food Safety policy: Section 2.1.1.1  (same as the policy statement management is to put together).  Food Safety Policy is how your site is committed to manufacturing, supplying, etc. safe food through following legislation and such.  I could go on and on, but do not have enough room and I'm sure others will comment to help out as well.  Our food safety management system is basically like an overview of the policies and programs we have in place to support food safety, kind of like how we have our quality management system.   Then at the end we have the SQF register that goes through each section of the code and then lists which of our SOPs, policies and programs we have that support that portion of the code.

 

Hope this helps somewhat and makes some sense.

Thanks for the response. I'm guessing I'll probably need to go through our last internal audit where we note what procedures/policies are in place in order to satisfy specific subsections of SQF code 9.0 and just note which ones correspond to food safety. 



NorCalNate

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Posted 15 June 2023 - 04:40 PM

Thank you all for the suggestions, they really helped I think I'm grasping the topics/requirements much better now. 

 

Another question: our consultant told us our FSMS document should be 2-3 pages. In order to keep it that small, instead of specifically answering each topic I will need to identify the document where the information is located. Is this acceptable? It seems much more logical to reference the applicable document so we don't have to update the FSMS whenever a change is made to a referenced Procedure/Policy/Plan. Thoughts?



kingstudruler1

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Posted 15 June 2023 - 05:33 PM

This clause refers to your entire program.   You can think of it as your entire food safety "manual".   An organized collection of everything you use to meet the SQF standard.  There are no requirements in this clause are not met by other clauses.  

 

The only exceptions to the is "A summary of the organization’s food safety policies and the methods it will apply to meet the requirements of this standard" This can be whatever you want.  a summary of all of your programs, etc.   This might be the 2 -3 page document your consultant suggested.   The org chart is also only in this clause.  

 

The policy statement is the same one you have for 2.1.1.   

 

 

The guidance document for VERSION 8.1 may help.   Yes, i know this is the old standard but it gives you a better idea of the purpose of this clause. 

 

https://www.sqfi.com...and-checklists/


Edited by kingstudruler1, 15 June 2023 - 05:39 PM.

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