Does a Change in the Flow Diagram Require EMP Review?

If the plant change the process of the flow diagram or add new equipment in production.  Do you need to review the EMP.

Hi Touchdown,

Changes to the process or new equipment should result in a review and update of any relevant site procedures that are affected such as:

Operating procedures

Maintenance

Cleaning

Environmental monitoring

Internal Audits/Inspections

Training

Kind regards,

Tony

You have to check everything in the new process flow. Even if there is no change, you must review and confirm it.

It looks like this is the type of thing that will fall under the new section in SQF 10 - Change Management Program.

I used to have an agenda which we'd use for our HACCP review but also for any HACCP meeting which was out of cycle (just to make sure everything was covered).  I can't remember the exact wording but I think I had a question on there to prompt review of verification activities after any change.  So that then became an agenda discussion point and I could record it had been discussed and the outcome of that discussion.  It helped with audit compliance but also helped make sure we were considering it.

In reality it depends a lot on what the change is.  For example, a move to an automated palletiser in a low risk area will change your flow but it will be unlikely to change your EMP programme.  A movement of one chiller into another meaning your movements of ingredients changes strangely might not change your process flow but probably would change your EMP if the different ingredients have different intrinsic microbiological risk (e.g. fresh washed leaf vs. fully cooked pasta).

Ultimately ANY change in HACCP should at least prompt a review of your verification activities (not just environmental monitoring) and that could include process flow diagram changes but also changes too subtle to make a difference to your process flow.