I'm looking at Code 10 for Food Manufacturing specifically: SQFI | View
2.1.1.2 - I really don't like this "food safety culture assessment plan" thing. "Regular measurement and evaluation of food safety-related activities" which, I'm assuming, means developing something beyond your regular monitoring and internal auditing. I know it's been deemed unacceptable by my auditors to point towards a year's worth of good GMP checks to show we have a strong culture.
2.1.2.2 listing out new specifics on what "Site Management" must be updated to at a monthly frequency. Regulatory issues specifically. Man, imagine catching a minor because you failed to tell your boss that an FDA requirement got pushed down the road 30+ months.
2.4.2 - Changing the term to "Good Industry Practices" is stupid, especially when up in 2.2.3.5 we're still required to maintain records of GMP inspections. Imagine catching a minor because you used the wrong phrasing.
2.4.2.1 - Without a guidance document to tell us what they mean by Good Industry Practices, how are we supposed to perform a written risk assessment to justify which practices don't apply to us? They want evidence of why we aren't instituting a certain practice with vague reference to what the total number of practices are...
2.4.3.1 - Food safety plan prepared "in accordance with the twelve steps outlined in the latest version of Codex Alimentarius Commission's General Principals of Food Hygiene." Man, took me a minute to find which version of the Food Hygiene was the latest (2022 btw), and then searching a 38 page document for this twelve step program. What happens when V10 is still in effect but a NEWER version of Codex Food Hygiene comes out to say there are 14 steps? Seems impractical to have such an obtuse reference.
2.4.4.5 - Okay, I actually like this one because their comment is that they removed the requirement to have a contract with your lab. Most labs won't do that, so now we're not required to have them on our approved contract service provider list.
11.3.4.2 - Visitors and GMP: They removed the reference to 11.3.3.8, now it plainly states visitors are required to remove all jewelry and not allowed the plain band or medical exemptions under 11.3.3.8. Good luck telling your auditor to take off their medic alert bracelet.
That's just my cursory first pass. I'm sure I'll have more to gripe about later...
