Also, regarding the food legislation policy, our programs do not explicitly say what section is considered the food legislation but we did identify that we need to notify SQF and the third party CB within 24 hours for recall and in our crisis management. Is this enough? Do I need a section that specifically says that it is the food legislation policy and compile everything into one section?
Thanks in advance.
When you mentioned food legislation, I immediately jumped to this clause in my mind:
2.4.1.2 The methods and responsibility for ensuring the site is kept informed of changes to relevant legislation, scientific and technical developments, emerging food safety issues, and relevant industry codes of practice shall be documented and implemented.
I typically write a program in my FSQMS that lists out the legislation relative to my company. Mostly FDA under CFR 21 and FSMA, etc. You can find various knowledge bases and update channels that they offer to keep apprised of things like recalls, new laws coming into play, and copy those sources into the program. The program I write usually calls our company culture into play, that QA managers/supervisors are to periodically check for updates to the laws and present their findings via emails and monthly meetings. Having something like this defined and being able to show some of the communications on what we've found over the year typically satisfies the auditors.
For example, that new FDA Traceaiblity rule coming into play this year (enforceable by 2026) is going to create some major changes in my company's record keeping.
