11 replies to this topic

[Koko LMQ]

Dear Friends,

1.Clause 2.1.5 : Could you please give me the examples of ethical aspects.

2.Clause 2.1.6 : What does the intention related to? Is it the method on how to achieve the quality policy?

3.Clause 3.2.2.7 : Can I use the swab test to check the effectiveness of hygiene procedure? Other methods, please advise.

4.Clause 4.8.1.4 : Does the "Site Security" mean the "Food Security" or "Bioterrorism Security" as the US one?

5.Clause 4.8.4.7.2: Is it necessary to install the light cover in the warehouse which is stored the canned/packed products?

6.Clause 4.10.5 : What is the intension of waste balance?

7.Clause 4.18.6 : How can I keep the perishable raw materials e.g. fresh pineapple till the end of the expiry date of the canned pineapple? Can the term "when appropriate" be applied to and exempt for the perishable ones?

8.Clause 4.19 : I do not know the difference of products consisting of GMOs, containing GMOs or produced from GMOs?

9.Clause 4.19.6 : What is the "identity preserved products"?

10.Clause 5.5.3 : I cannot find the EU quantity control legislation, anyone can give me the copy one?

[yorkshire]

Dear Narongchai,

You raise some interesting points. If I can I will answer the way I see these clauses. If I suddenly stop a post it means I've had to go and do something else. I will go through each point. I will also put down the text of each clause so that those who don't possess the IFS can understand your questions.

1.Clause 2.1.5 : Could you please give me the examples of ethical aspects.

"2.1.5 (Management responsibility) The policy shall include responsibility to environment, hygiene and ethical aspects"

This one puzzles me too as it is new to Version 4. Many companies now are into "Ethical trading policies" and I presume it means this. The policy could be a general statement stating the companies intentions towards its employees and its suppliers employees, e.g. fare wages paid, no corporal punishment, drinking water supplied, no forced labour, etc.....

2.Clause 2.1.6 : What does the intention related to? Is it the method on how to achieve the quality policy?

"2.1.6 Short-term and medium-term intentions shall be defined. The intentions shall be concrete and related to the responsible person. The short-term and medium-term goals shall contain time limits."


Again it is difficult to say. As a management team we have certain quality targets each year - progress is documented and responsibilities assigned. We also have various meetings which relate to food safety, quality and legality - again at each of these meeting responsibilities and timescales are assigned. Does anyone else have other ideas on this clause?

3.Clause 3.2.2.7 : Can I use the swab test to check the effectiveness of hygiene procedure? Other methods, please advise.

"3.2.2.7 The effectiveness of hygiene procedures with regard to hands shall be checked periodically."

This point is a recommendation but I would look at what risk there is to your products. We make low risk products (in fact no risk from the micro side) so the effectiveness of handwashing is not a risk to the product. We have routine visual inspections carried out by the supervisors to see that hands are clean. If you are higher risk it would be worth looking at swabbing.

4.Clause 4.8.1.4 : Does the "Site Security" mean the "Food Security" or "Bioterrorism Security" as the US one?

"4.8.1.4 Measures shall be in place to maintain site security, especially concerning access limitation."

We have 24hr security staff on site, access to site is limited either past our security staff or by keycode / electronic tag doors. Ask yourself if anyone can get into your factory without you knowing about it. If the answer is yes then you may not pass this clause.


To be continued...................

Edited by yorkshire, 04 March 2005 - 12:21 PM.

[yorkshire]

.Clause 4.8.4.7.2: Is it necessary to install the light cover in the warehouse which is stored the canned/packed products?

" 4.8.4.7.2 All bulbs and strip lights, including those on electric fly killer units, where they constitute a risk to product, shall be protected by shatterproof plastic diffusers or sleeve covers. For high temperature lights, where plastic covers are not viable, a fine mesh metal screen shall be fitted. Where full protection cannot be provided, the glass management system shall take this into account."

Firstly you need to look at the risk to product and the risk of a breakage. I believe that if thare is no risk to the product and the risk of breakage is low then you do not need to change your lights. It would be wise to document your risk assessment then you can produce it during the audit. I would also make sure there was a glass breakage procedure in place (and staff are trained in the procedure) to minimise any risk of spread.

[yorkshire]

Clause 4.10.5 : What is the intension of waste balance?

'4.10.5 A waste balance should be established.'

Again I'm not really sure what to say on this. In our factory we note internally how much waste we produce and reconcile it against the weight our contracts say we have produced. The figures never match up but the standard doesn't say that they have to!!!! Peter do you have any ideas?
N.B. this is only a Recommendation.

Clause 4.18.6 : How can I keep the perishable raw materials e.g. fresh pineapple till the end of the expiry date of the canned pineapple? Can the term "when appropriate" be applied to and exempt for the perishable ones?

'4.18.6 From all relevant raw materials, when appropriated, identified samples shall be available and kept stored till the end of the expiry date of the end product.'

I can't see how you can keep these. See other discusion thread.

Edited by yorkshire, 09 March 2005 - 09:18 AM.

[yorkshire]

Clause 4.19 : I do not know the difference of products consisting of GMOs, containing GMOs or produced from GMOs?

'4.19.1 The organisation shall have in place systems and procedures to allow the identification of products consisting of GMOs, containing GMOs or produced from GMOs including food ingredients but also additives and flavouring(s).'

This is how I see it:

Consisting of GMOs - Material which definitely contains GMO material e.g. GMO soya / maize.

Containing GMO - Ingredient is partly made up from GMO material or could be contaminated during the harvesting / manufacturing process.

Produced from GMOs - material which is made from GMO source which may or may not actually contain any GMO material.

Clause 4.19.6 : What is the "identity preserved products"?

'4.19.6 If a customer demand for identity preserved products is specified, this requirement shall be integrated in the quality management and shall be documented.'

Identity preserved product is material which comes from a guaranteed GMO free material. This is usually for products which can often be genetically modified e.g. maize, soya.

Clause 5.5.3 : I cannot find the EU quantity control legislation, anyone can give me the copy one?

'5.3.3 If the Organisation imports pre-pack material intended for sale they shall be able to demonstrate compliance with EU quantity control legislation.'


See Average weights

I'd like to hear other people's comments on these issues too (even if you are not directly involved in the IFS ).

Cheers

Yorkshire

[PSchnittger]

I hope I give some helpful comments too.

"2.1.5 (Management responsibility) The policy shall include responsibility to environment, hygiene and ethical aspects"

This one puzzles me too as it is new to Version 4. Many companies now are into "Ethical trading policies" and I presume it means this. The policy could be a general statement stating the companies intentions towards its employees and its suppliers employees, e.g. fare wages paid, no corporal punishment, drinking water supplied, no forced labour, etc.....

You are right. All auditors I know are checking (more or less) if a company is stating something how the are acting with there employees and others.

"2.1.6 Short-term and medium-term intentions shall be defined. The intentions shall be concrete and related to the responsible person. The short-term and medium-term goals shall contain time limits."
Again it is difficult to say. As a management team we have certain quality targets each year - progress is documented and responsibilities assigned. We also have various meetings which relate to food safety, quality and legality - again at each of these meeting responsibilities and timescales are assigned. Does anyone else have other ideas on this clause?.....

Short-term means round 1 year, medium let's say 2 to 5 years targets. These targets can be related to quality aspects, but also to companies one. They should be measurable and you must show, that you are checking against them.

"3.2.2.7 The effectiveness of hygiene procedures with regard  to hands shall be checked periodically."

This point is a recommendation but I would look at what risk there is to your products. We make low risk products (in fact no risk from the micro side) so the effectiveness of handwashing is not a risk to the product. We have routine visual inspections carried out by the supervisors to see that hands are clean. If you are higher risk it would be worth looking at swabbing......

It means a little bit more. I have a problem, because I don't know the english word for it. In German it is "Abklatschprobe". Something, where you make a sampling on certain places an check it microbiological.

[PSchnittger]

" 4.8.4.7.2 All bulbs and strip lights, including those on electric fly killer units, where they constitute a risk to product, shall be protected by shatterproof plastic diffusers or sleeve covers. For high temperature lights, where plastic covers are not viable, a fine mesh metal screen shall be fitted. Where full protection cannot be provided, the glass management system shall take this into account."

Firstly you need to look at the risk to product and the risk of a breakage. I believe that if thare is no risk to the product and the risk of breakage is low then you do not need to change your lights. It would be wise to document your risk assessment then you can produce it during the audit. I would also make sure there was a glass breakage procedure in place (and staff are trained in the procedure) to minimise any risk of spread.

<{POST_SNAPBACK}>

In some cases the auditor will not be satisfied by stating "for us there is no risk". In the production itself you should ban all glass as far as possible. All other things Yorki stated must also be in place!

[PSchnittger]

'4.10.5 A waste balance should be established.'

Again I'm not really sure what to say on this. In our factory we note internally how much waste we produce and reconcile it against the weight our contracts say we have produced. The figures never match up but the standard doesn't say that they have to!!!! Peter do you have any ideas? 
N.B. this is only a Recommendation.

This is coming from a german administrative order. So I'd recommend to leave it as it is...

'4.18.6 From all relevant raw materials, when appropriated, identified samples shall be available and kept stored till the end of the expiry date of the end product.'

I can't see how you can keep these. See other discusion thread.

It absolutely depends on what you are producing... So best is, to discuss upfront with your auditor.

[PSchnittger]

'4.19.1 The organisation shall have in place systems and procedures to allow the identification of products consisting of GMOs, containing GMOs or produced from GMOs including food ingredients but also additives and flavouring(s).'

This is how I see it:

Consisting of GMOs - Material which definitely contains GMO material e.g. GMO soya / maize.

Containing GMO - Ingredient is partly made up from GMO material or could be contaminated during the harvesting / manufacturing process.

Produced from GMOs - material which is made from GMO source which may or may not  actually contain any GMO material.

Your should check out the EU regulation 1829/2003. There you will find the explanation of GMO. For IFS you shall request a GMO-free conformity from each deliverer.

[Andy]

Hi, I've just some additional comments (to complicate the view a bit):

'4.19.1 The organisation shall ......produced from GMOs including food ingredients but also additives and flavouring(s).'

This is how I see it:

Consisting of GMOs - Material which definitely contains GMO material e.g. GMO soya / maize.

Containing GMO - Ingredient is partly made up from GMO material or could be contaminated during the harvesting / manufacturing process.

Produced from GMOs - material which is made from GMO source which may or may not  actually contain any GMO material.

I think you, yorkshire, are fairly right with your interpretation. The "produced from" clause and the inclusion of additives and flavours is the puzzling part. A lot of the flavouring substances are produced with GMO, i.e. genetically modified bacteria and moulds.
And here an example for this a beer brewn with a GM barley an an normal yeast is a GMO-containing product, whereas ordinary barley fermented with a GM yeast is not.
The next point is the stage of denaturation of the GMO product: corn starch from GM maize is a GMO-product. The glucose-sirup made from it also. But what is the (Non-GM) yeast fed with this sirup? And the ascorbate derived from the glucose using a GM microorganism?
This is not absolutely clear neither from the legislative nor from the IFS point of view.

The main problem with this, especially in the flavourings field is - probably you as a european producer will never know how you flavour was produced, let's say in China.

I am curious about the experiences others made with certificates from flavour producers regarding this topic. Probably every product was stated as "GMO-free".

Please, tell me about!

Cheers

[yorkshire]

ANdy,

We have some ingredients where GM enzymes are used in their production, e.g. glucose syrup and dextros, but are GMO free because they are not in the end ingredient.

We have found that most flavour suppliers will state that there are no GMO ingredients in their products but state that they cannot guarantee that contamination cannot occur.

[ding]

The "ethical aspect"

In my opinion, only 3.3.6 " Suitalbe and sufficiengt rest and catering facilities shall be provided for all staff"

Druing my visits for 40~50 factories, not all have this! This is a kind of ethical aspect responsibilities.