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4.1.2.3.food.safety.quality.diagram.training

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A Power Point training aid to educate plant personnel of Food Safety, Food Quality, SQF, Food Safety Fundementals (HACCP) and use this information to actually build a pyramid of Total Quality. To get …

A Power Point training aid to educate plant personnel of Food Safety, Food Quality, SQF, Food Safety Fundementals (HACCP) and use this information to actually build a pyramid of Total Quality. To get a functioning copy with the animation email ed.ayers315@hotmail.com

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  • 1. ?Who How What Whom
  • 2. LOSURDO FOODS, INCTRAINING: SQF 2000 SYSTEM (SAFE QUALITY FOOD) What is SQF; Western Australia late 1990‟s Why do retailers turn to a System like SQF Why are some retailers not requiring SQF Certification (YET) Why us How much do we risk if we don‟t? SQF is as easy as 2 phrases;  Say what “you” do  Do what “you” say  OR  The methods to ensure our products are safe quality foods are: ___________________ ReceivingStartup Ball Line Inline and the responsibilities belongreceivers TankLine ______________ and SHALL be documented and Ball to: Filters Check implemented on :___________________________, and verified by:____________ 4.1.1.ii.1.Milk.Receiving.Log 4.1.1.ii.1.Packing.Line.Check Lead Jeff DeFrance . Jeff DeFrance
  • 3. HOW TO INTERPRET SQF REQUIREMENTS What must happen How do we make it happen & How do we prove it happened; what documentation is required to instruct how and what is needed to document and prove it! Who is required to make it happen Whom needs to know these things!
  • 4.  4.1.1 Management Policy  The owner or most senior person shall define the Supplier‟s commitment to food safety, quality and continuous improvement as well as make resources available to achieve these objectives in a Policy Statement; which is relevant to the Supplier‟s goals and customer requirements. The owner or most senior person must sign the policy statement, have it documented in the Policy Manual, and ensure it is communicated to all employees and staff.
  • 5. GLOBAL FOOD SAFETY INITIATIVE (GFSI) Welcome to the Global Food Safety Initiative  The Global Food Safety Initiative (GFSI) is a collaboration between some of the worlds leading food safety experts from retailer, manufacturer and food service companies, as well as service providers associated with the food supply chain. It is coordinated by The Consumer Goods Forum, the only independent global network for consumer goods retailers and manufacturers worldwide. It serves the CEOs and senior management of nearly 400 members, in over 150 countries.
  • 6. GLOBAL FOOD SAFETY INITIATIVE (GFSI) Why did the Global Food Safety Initiative begin?  In May 2000, following a number of food safety scares, a group of international retailer CEOs identified the need to enhance food safety, ensure consumer protection and to strengthen consumer confidence. They launched the Global Food Safety Initiative which sets requirements for food safety schemes through a benchmarking process in order to improve cost efficiency throughout the food supply chain.  Members include 70% of the World‟s food retail revenue and has 9000 companies SQF certified worldwide
  • 7. CONSULTING MAJOR US FIRMS ADOPTING SQFAlready requiring SQFCertificationWalMart Under review and consideration•US Foodservice at many other firms:•Stop & Shop –Kroger•Giant –Wegman‟s•Price Chopper –Harris Teeter•Lund‟s & Byerly‟s –Costco•HEB –Sysco•Food Lion –Yum Brands•Hannaford Bros. –McDonalds
  • 8. THREE LEVELS OF IMPLEMENTATION INTERGRATED QUALITY LEVEL 3 FOOD QUALITY PLAN MANAGEMENT HACCP & FOOD SAFETY FOOD SAFETY MANAGEMENT LEVEL 2 PLANS FOOD SAFETY FUNDEMENTALS LEVEL 1 PREREQUISITE PROGRAMS
  • 9.  What does SQF mean by “you”; you might ask yourself, why is this all on me / us?  Remember Say what “you” do; of the three statements below, who would be the “you”  Losurdo Foods, Inc will provide annual GMP refresher training.  Losurdo Foods, Inc will maintain needed inventories of cleaning utensils needed to maintain the facility is a constant state of sanitation to avoid product contamination.  Losurdo Foods, Inc will provide PPE and maintain inventories needed to provide employees, contractors, and visitors the ability to protect themselves from hazards encountered at its facilities.  You = Losurdo Foods, Inc
  • 10. FOREIGN MATERIAL CONTROL: METAL DETECTOR SOP Purpose: What  To minimize the possibility of metal from processing equipment getting into consumer product. This operation is done through the use of metal detection devices used in the product packaging lines. The procedure covers the analyzing of our products for foreign material prior to shipment. Method: How  Performance of the metal detectors are determined by the size of the machine itself and its set up, as well as size, shape, density, temperature and the composition of the product. To ensure that the metal detectors are in proper working condition they are to be calibrated for each product. The product format is entered into the machine and checked throughout that product run. The test calibration pieces ensure that calibration has been retained. Responsibilities: Who
  • 11. FOREIGN MATERIAL CONTROL: METAL DETECTOR SOP Responsibilities: Who  Itis the responsibility of the packing personnel to test the performance of the metal detectors as identified in the above the procedures. They are to notify Management in the event that the detector is not performing the way it should. It is the responsibility of packing personnel to perform the Daily Preventive maintenance on the metal detectors. Responsibilities: Whom  What facility personnel must be trained and follow this SOP?
  • 12. JUST HACCP VERSES JUST PRE-REQUISITE PROGRAMS Why do we need both? In its 1997 document titled "Hazard Analysis and Critical Control Point Principles and Application," the National Advisory Committee on Microbiological Criteria for Foods (NACMCF) states, "The production of safe food products requires that the HACCP system be built upon a solid foundation of prerequisite programs...Prerequisite programs provide the basic environment and operating conditions that are necessary for the production of safe, wholesome food.“
  • 13. JUST HACCP VERSES JUST PRE-REQUISITE PROGRAMS The success of the HACCP system depends on prerequisite programs that are both active and effective. Many potential hazards can be eliminated or reduced to a "non-hazardous" state through well- defined and effective prerequisite programs.
  • 14. JUST HACCP VERSES JUST PRE-REQUISITE PROGRAMS CONT. NO EASY WAY OUT So, why bother with the prerequisite program if HACCP can do the same thing? Creating critical control points (CCPs) and managing them through the HACCP plan is not always a viable option. CCPs have significant requirements. introducing a CCP places demands on the system, which may not always be practical. Deviation is critical and must be addressed, documented and supported by records to demonstrate actions taken. A pre-determined corrective action must define an immediate action to divert the product and to ensure that violated product is not released for consumption.
  • 15. JUST HACCP VERSES JUST PRE-REQUISITE PROGRAMS CONT.  Whenever possible, the best solution is to define and manage as many potential hazards as possible in a prerequisite program. The focus of prerequisite programs do differ from the overall HACCP focus. Generally, a prerequisite program applies across product lines that are managed system or process wide. The HACCP plan focus is product specific. Every deviation in a prerequisite programs requirement will not necessarily result in a food safety hazard, yet the effectiveness of the overall program may affect the HACCP system (product safety).
  • 16. SQF 2000 SYSTEM Section 4 –SQF System Requirements Section 5 –Food Safety Fundamentals –Building and Equipment Design and Construction Section 6 –Food Safety Fundamentals –Pre- requisite Programs
  • 17. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.1 of SQF –Commitment 4.1.1 Management Policy  Policy statement with commitment to quality and safety must be written and signed by Senior management; must be displayed for all employees 4.1.2 Management Responsibility  Organizationalstructure in place with designated responsibility for food safety (resources, training, job descriptions
  • 18. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.1 of SQF –Commitment 4.1.3 Food Safety and Quality Management System  Policy manual, food safety manual, and quality manual in place 4.1.4 Management Review A system is in place for management to review SQF system annually
  • 19. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.1 of SQF –Commitment 4.1.5 Compliant Management A system for recording, reviewing, and responding to customer complaints 4.1.6 Business Continuity Planning A crisis management plan is in place
  • 20. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.2 of SQF –Document Control and Records 4.2.1 Document Control  Documents are maintained, accessible, and current. Maintained by designated person. 4.2.2 Records  Recordsare securely maintained. Procedures detail person responsible for completion and person for verification as well as how to be completed.
  • 21. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.3 of SQF –Specifications and Product Development 4.3.1 Product Development and Realization  Procedures for conducting R&D, approving, and validating. 4.3.2 and 4.3.3 Raw Materials and Packaging  Specificationsfor raw materials and packaging with list of suppliers, supplier approval, and procedures for receipt of materials verifying that they are from approved supplier.
  • 22. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.3 of SQF –Specifications and Product Development 4.3.4 Contract Services  Procedures and documentation for any contract services 4.3.5 Contract Manufacturers  Willinclude suppliers of Product contact, raw materials, processing aids, and / or ingredients to your facility. Procedures for approval and evaluating supplier.
  • 23. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.3 of SQF –Specifications and Product Development 4.3.6 Finished Product  Finishedproduct specifications with review. Product labels established. All comply with government regulations and customer requirements.
  • 24. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.4 of SQF –Attaining Food Safety 4.4.1 Food Legislation  Aware of applicable food regulations and that facility complies with federal state and local regulations including having appropriate licenses 4.4.2 Food Safety Fundamentals  Policies address practices to address facilities, equipment, and prerequisite programs
  • 25. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.4 of SQF –Attaining Food Safety 4.4.3 Food Safety Plan  HACCP in place, maintained, and validated 4.4.4 Incoming Goods and Services  Approved supplier, raw material inspection, and monitoring or raw material suppliers. Also, emergency receipt of materials
  • 26. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.4 of SQF –Attaining Food Safety 4.4.6 Corrective and Preventive Action  Proceduresfor corrective action with record keeping and preventive measures taken 4.4.7 Non-Conforming Product or Equipment  Who is responsible for non-conforming product and how is it controlled
  • 27. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.4 of SQF –Attaining Food Safety 4.4.8 Product Rework  Who is responsible for reworking product and how is it controlled 4.4.9 Product Release  Who is responsible for releasing product and how is it controlled 4.4.10 Stock Rotation A Stock rotation procedure is in place
  • 28. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.5 of SQF –Verification 4.5.1 Verification  Verificationof pre-requisite programs, control steps with established limits, and monitoring 4.5.2 Validation  Do programs ensure process meets intended limits
  • 29. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.5 of SQF –Verification 4.5.3 Verification of Monitoring Activities  Documentation of methods, responsibilities, and criteria for verifying effectiveness of pre-requisite programs and HACCP 4.5.4 Product Sampling, Inspection, and Analysis  Procedures for testing and sampling written, responsibility assigned, and records maintained
  • 30. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.5 of SQF –Verification 4.5.5 Internal Audit  Procedures and responsibility for internal audits 4.5.6 SQF Verification Schedule  Procedures, frequency, and responsibility for checking the effectiveness of the SQF system
  • 31. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.6 of SQF –Product Identification 4.6.1 Product Identification  Methods and responsibilities for identifying product during all stages of production 4.6.2 Product Trace  System to complete „one forward, one back‟ traceability
  • 32. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.6 of SQF –Product Identification 4.6.3 Product Withdrawal and Recall  Procedures for recall including methods, responsibilities and management procedures, must conduct mock recalls
  • 33. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.7 of SQF –Food Defense (US Army) 4.7.1 Food Defense  Food defense protocol that outlines the methods, responsibilities, and criteria for preventing intentional contamination (Prerequisite Program #14)
  • 34. SQF 2000 SECTION 4 –SYSTEM REQUIREMENTS Section 4.6 of SQF –Identify Preserved Foods 4.8.1 General requirements  Methods for maintaining special attributes of the food and their raw materials  Allergens, organic, GMO, kosher
  • 35. SQF 2000 SECTION 5 –FOOD SAFETY FUNDAMENTALS Section 5.0 of SQF 5.1 Site Requirements and Approvals 5.2 Food Handling Areas 5.3 Water and Ice Supply 5.4 Storage Facilities 5.5 Separation of Functions (prevent cross contamination) SEPARATING FUNCTIONS 5.6 On-Site Laboratories
  • 36. SQF 2000 SECTION 5 –FOOD SAFETY FUNDAMENTALS 5.7 Staff Amenities (Restrooms, break rooms, etc) 5.8 First Aid Facilities 5.9 Waste Disposal 5.10 Exterior
  • 37. SQF 2000 SECTION 6 –PREREQUISITE PROGRAMS O B Section 6.0 of SQF S E R 6.1 Personnel Practices V A T 6.2 Personnel Processing Practices PERFORMANCE I REVIEW JOB INTERVIEW O 6.3 Training of Personnel ASSIGNMENTS PROCESS N S RECORD KEEPING 6.4 Calibration of Equipment 6.5 Pest Control 6.6 Maintenance of Equipment
  • 38. SQF 2000 SECTION 6 –PREREQUISITE PROGRAMS Section 6.0 of SQF 6.7 Cleaning and Sanitizing 6.8 Monitoring Water Micro and Quality 6.9 Control of Physical Contaminants 6.10 Supplier Approval 6.11 Receiving, Storage, Transport and Delivery (ours) 6.12 Waste Management 6.13 Allergen Control
  • 39. SQF 2000 SECTION 6 –PREREQUISITE PROGRAMS Section 6.0 of SQF: LFI additions 6.14 Food Defense (LFI Addition) 6.15 Customer Complaints (LFI Addition) D 6.16 Traceability, Recall & Withdrawal (LFI Addition)
  • 40. 7 S Q AFE TY UALI F OODS 2 S HACCP PRINCIPLES 1.FD & HAZARD ANALYSES 2.CRITICAL CONTROL INTERACTIVE 000 ystem POINTS 3.OP LIMITS & CRITICAL LIMITS PRE-EMPTIVE 4.MONITORING 5.CORRECTIVE ACTIONS QUALITY 6.VALIDATING VERIFING SYSTEM VERIFICATION 7.RECORD KEEPING EMPLOYEE ORGANIZATIONAL ENVOLVMEN COMMITMENT T SANITATION TEAMS SELF STANDARD INSPECTIONS OPERATING & SELF CONTROL PROCEDURES REGULATORY COMPAN STANDARD INSPECTIONS OPERATING AUDITS & 3RD MECHANISM Y PROCEDUR PARTY S POLICIE ES AUDITS PERSONN WATER CRITICAL S EL QUALITY EQUIPMENT PRACTICE PROGRA CALIBRATION S PERSONNE PREMISES S M TRAININGPROGRAM L EQUIPMENT PROGRAMCLEANING EDUCATION PROCESSIN MAINTENAN SANITATION VALIDATION AL G CE PROGRAM PROGRAM CUSTOMER PRACTICES RECEIVING PROGRAM PHYSICAL WASTE STANDAR PROGRAM COMPLAINT STORAGE CONTAMINAT CONTROL DS, S TRANSPO ES PROGRA PROGRAM RT CONTROL M SAFETY, &TRACEABILI APPROVE PROGRAM ALLERG PROGRAM PEST FOOD STABILITY TY D EN MANAGEMEN DEFENS RECALL SUPPLIER CONTRO T EPROGRAM PROGRA L PROGRAM PROGRA 16 – PREREQUISITE PROGRAMS M PROGRA M M
  • 41. 7 S Q AFE TY UALI F OODS 2 S HACCP PRINCIPLES 1.FD & HAZARD ANALYSES 2.CRITICAL CONTROL INTERACTIVE 000 ystem POINTS 3.OP LIMITS & CRITICAL LIMITS PRE-EMPTIVE 4.MONITORING 5.CORRECTIVE ACTIONS QUALITY 6.VALIDATING VERIFING SYSTEM VERIFICATION 7.RECORD KEEPING EMPLOYEE ORGANIZATIONAL ENVOLVMEN COMMITMENT T SANITATION TEAMS SELF STANDARD INSPECTIONS OPERATING & SELF CONTROL PROCEDURES REGULATORY COMPAN STANDARD INSPECTIONS OPERATING AUDITS & 3RD MECHANISM Y PROCEDUR PARTY S POLICIE ES AUDITS PRESONN WATER CRITICAL S EL QUALITY EQUIPMENT PRACTICE PROGRA CALIBRATION S PERSONNE PREMISES S M TRAININGPROGRAM L EQUIPMENT PROGRAMCLEANING EDUCATION PROCESSIN MAINTENAN SANITATION VALIDATION AL G CE PROGRAM PROGRAM CUSTOMER PRACTICES RECEIVING PROGRAM PHYSICAL WASTE STANDAR PROGRAM COMPLAINT STORAGE CONTAMINAT CONTROL DS, SAFET S TRANSPO ES PROGRA PROGRAM RT CONTROL M Y, &TRACEABILI APPROVE PROGRAM ALLERG PROGRAM PEST FOOD STABILITY TY D EN MANAGEMEN DEFENS RECALL SUPPLIER CONTRO T EPROGRAM PROGRA L PROGRAM PROGRA 16 – PREREQUISITE PROGRAMS M PROGRA M M
  • 42. STANDARDS, SAFETY, & STABILITY Product Identification, Traceability and Recall Programs The ability to identify and trace raw materials through finished product is essential. The product recall program should include mock recalls performed at a defined frequency (i.e., semi-annually) and records confirming acceptable results. Do not wait for a real situation to learn the program is not effective. Labeling (Application and Control) Product must be labeledTRACEABIL appropriately; labels must clearly identify the product and its ITY RECALL ingredients. Labels must be evaluated to ensure that they contain allPROGRAM required information and meet legal requirements for product TRACEABILITY,should be performed to ensure identification and content. Evaluation REC proper labels are ALL, WITHDRAWAL applied to corresponding products. An ineffective PROGRAM label-management program could result in a serious food safety issue. .....A_EDAA_SQF6. SQF REQUIREMENTS FOR PRE- REQUISITES6.16.TRACEABILITY.RECALL.PREREQUISITE.PROGRAM0_6.16.RECALL.WITHDRAWAL.PRO CEDURE.OUTLINE.docx
  • 43. STANDARDS, SAFETY, & STABILITY CONTINUED Introduction and aim of procedure has product safety, product quality, quality, and service as its products and services. It aims to be fair and transparent in its operations, in particular in the process of managing complaints, CUSTOMER about a corrective action and in order to bring mutually agreeable solution for all parties.CUSTOMERCOMPLAIN COMPLAINTS Complaints may be made by any external person or organization and TSPROGRAM can be received by any PROGRAM member of Losurdo Foods‟ staff. The aim of this procedure is to describe the process of receipt (who, what, where, and why), logging (full description of the complaint detail specifically product “Best By Code”, size, and product the type), and (corrective actions) and resolution of all complaints received.....A_EDAA_SQF6. SQF REQUIREMENTS FOR PRE- REQUISITES6.15.CUSTOMER.COMPLAINTS.PREREQUISITE.PROGRAM6.15.CUSTOMER.COMPLAINTS.LOG.HEUVELTON.xlsx
  • 44. STANDARDS, SAFETY, & STABILITY CONTINUED Supplier Certification and On-going Evaluation Programs Supplier assurance that specific criteria are met should be an essential part of the HACCP plan. Many potential hazards related to the raw ingredient supply may be controlled through an effective supplier assurance program. Supplier programs should include requirements for identifying and qualifying suppliers, the means to monitor existingAPPROVE suppliers at defined frequencies, and handling any negative DSUPPLIER supplier issues. Keep in mind that if an assurance is madePROGRAM APPROVED based on a COA (certificate of approval) or a COC SUPPLIER process should also (certificate of compliance) then the PROGRAM identify a means to spot check incoming items (testing, etc.) at a defined frequency to verify the accuracy of the suppliers results. .....A_EDAA_SQF-AMSTERDAM6. SQF REQUIREMENTS FOR PRE- REQUISITES6.10.SUPPLIER.APPROVAL.PREREQUISITE.PROGRAMMIZKAM WHITE VINEGAR 6.10.2.1.i.SUPPLIER.SPECIFICATION.docx
  • 45. STANDARDS, SAFETY, & STABILITY CONTINUED Receiving, Storing and Controlling Raw Ingredients and Materials Inspections performed on raw ingredients and materials must ensure RECEIVING that all defined requirements are in compliance for the specific itemRECEIVING STORAGE before its receipt and are especially critical for requirements related to STORAGETRANSPORT PROGRAM TRANSPORT food safety hazard. Procedure requirements should be well defined; inspection and verification activities should be documented and PROGRAM maintained. Receiving inspection may link closely with supplier approval and evaluation requirements. All items must be stored in a manner that assures quality and protects their safety.
  • 46. CONTINUED STANDARDS, SAFETY, & STABILITY Storage Practices: To establish the protocols for receiving, rotating, and CONTINUED storage of raw materials and managing first-in/first-out inventory of all ingredients, packaging materials and finished products. Set standards to which loads must arrive in order to accept the contents. No load can be received without first inspecting the trailer, the BOL, and RECEIVING the contents and document the inspection on the inspection report. If STORAGE there are any signs of rodent or insect activity the Losurdo Foods employee must contact the manager on duty. Once the manager inspects RECEIVING STORAGE TRANSPORT the load, he or she must report their findings to the Plant/General TRANSPOR T PROGRAM PROGRAM Manager and the QA Manager. If a trailer is dirty or the products for delivery are dirty, you must inform the manager on duty. Temperature Sensitive Materials: If the load is temperature sensitive a temperature must be documented on the inspection report and be less than 41 degrees at arrival. If there are signs the trailer did not transport the product below the maximum temperature of 45 degrees, you must report these findings to the manager on duty. When you open the doors, if product has visible signs of condensation, you must run a core temperature on the must center pallet of that load. This must also be enforced for all refrigerated liquids received at the facility.
  • 47. CONTINUED STANDARDS, SAFETY, & STABILITY CONTINUED Containers and Utensils: Containers (bags, cups, trays, tubs, pails, lids, seals, and film) may only be used for their intended purpose. This is a RECEIVING serious violation of company GMP and Written Company Policy‟s. Do not RECEIVING STORAGE use product containers for but not limited to the following: storage of TRANSPOR T PROGRAM STORAGE tools, parts, chemical, drinking water, solvents, or writing instruments. TRANSPORT Rejection of Shipments: Losurdo foods will maintain records of all temperature sensitive products received or rejected. These records are PROGRAM recorded on “OPS.MATERIAL.HANDLING.INCOMING.INSPECTION.FORM”
  • 48. STANDARDS, SAFETY, & STABILITY CONTINUED Allergen Control Depending on product, allergen control may be identified as a potential hazard. It is imperative that possible allergensALLERGEN and required controls specific to each manufactured product areCONTROLPROGRAM identified. As appropriate, requirements to ensure that products are allergen free must be defined clearly with records maintained to confirm compliance. ALLERGEN CONTROL PROGRAM
  • 49. STANDARDS, SAFETY, & STABILITY CONTINUED Foreign Material Control Foreign material may be controlled by filters, strainers, socks or sifters. Magnets are also considered a form of foreign material control. The prerequisite program determines placement and monitoring activities. In some operations, a unit PHYSICAL strategically placed in the process may be identified as a CCP.CONTAMINATE S CONTROL CONTROLLING Whether a CCP or managed as a prerequisite, monitoring requirements should bePHYSICAL PROGRAM defined and records demonstrating compliance maintained.CONTAMINATES PROGRAM ....A_EDAA_SQF6. SQF REQUIREMENTS FOR PRE- REQUISITES6.9.CONTROL.OF.PHYSICAL.CONTAMINATION.PREREQUISITE.PROGRAM6.9.FOREIGN.MATERIAL.DETECTION.CAL.CHECKS(B K).xlsx
  • 50. STANDARDS, SAFETY, & STABILITY CONTINUED Pest Control Pest management may be included in the GMP program or exist as a stand-alone program. This depends on how responsibilities within the operation are assigned. If an external supplier provides these services, ensure that requirements are clearly PESTMANAGEMEN communicated to the supplier and that records are maintained to T PROGRAM confirm not only that activities are being performed as defined, but also that any identified pest control concerns are addressed in a timely and effective manner. PEST MANAGEMENT PROGRAM
  • 51. STANDARDS, SAFETY, & STABILITY CONTINUED Drainage and sewage systems are equipped with appropriate traps and vents. Establishments are designed and constructed to prevent cross-connection between the effluent of human wastes and any other WASTE No drainage pipes pass directly over or wastes in the establishment. CONTROL WASTECONTROLPROGRAM PROGRAM through production areas, unless they are controlled to prevent contamination. Facilities are provided for the storage of waste and inedible material prior to their removal from the establishment. These facilities are designed to prevent contamination. Containers used for waste are clearly identified and are leak proof.
  • 52. STANDARDS, SAFETY, & STABILITY CONTINUED What is Food Defense? Food defense is not the same as Food Safety. Food defense focuses on protecting the food supply from intentional contamination, with a variety of chemicals, biological agents or other harmful substances by FOODDEFENSE people who want to do us harm. These agents could include materialsPROGRA M that are not naturally-occurring or are not routinely tested for. An attacker‟s goal might be to kill people or disrupt our economy. Intentional acts are generally not reasonable and are hard to predict. FOOD DEFENSE PROGRAM
  • 53. CONTINUED STANDARDS, SAFETY, & STABILITY CONTINUED What is Food Defense? Food Safety addresses the accidental contamination of food products during processing or storage by biological, chemical or physical hazards. The main types of food safety hazards are microbes, chemicals and foreign objects. This unintentional contamination of FOOD DEFENSE food products can be reasonably anticipated based on the type of PROGRA processing. This principle is the foundation of the Hazard Analysis M Critical Control Point (HACCP) process used to ensure Food Safety Plan and Food Quality Plans are successful but separate from Our Food Defense Plan. ....A_EDAA_SQF6. SQF REQUIREMENTS FOR PRE- FOOD DEFENSE REQUISITES6.14.FOOD.DEFENSE.PLAN.PREREQUISITE.PROGRAM6.14.FOOD.DEFENSE.PLAN.VALIDATION.CHECKLI ST.docx PROGRAM Also see the added articles of food related contamination paragraph 17 of “FORMING YOUR HACCP TEAM”
  • 54. Training STANDARDS, SAFETY, requirementCONTINUED is an essential HACCP & STABILITYmentioned by the Codex Alimentarius Commission2 that is not specifically stated as one of the seven principles. Codex states, "Training of personnel...in HACCP principles and applications, and increasing awareness of consumers are essential elements for the effective implementation of HACCP." It is imperative that associates are trained in their TRAINING responsibilities. Qualification and competency requirementsEDUCATIONAL PROGRAM for specific responsibilities, including those related to the HACCP plan, must be defined with records maintained to confirm that requirements have & TRAINING been met. This must include personnel on temporary assignment, individuals filling in EDUCATION during breaks, vacations or sick leave, even those hired PROGRAM through a temporary agency. Well-defined and effective training cannot be stressed enough.
  • 55. CONTINUED Prerequisite programs can include& STABILITY chemical STANDARDS, SAFETY, hazardous and CONTINUED material control, sensory testing and training, control of nonconforming product, customer complaints and internal auditing. Any discussion related to HACCP must emphasize management commitment. Though management commitment is not one of HACCPs seven principles, the Codex document states, "Management commitment is necessary for TRAINING EDUCATIONAL implementation of an effective HACCP system" and emphasizes PROGRAM that "the successful application of HACCP requires the full commitment and involvement of management and the work force." Management must convey &positive message of TRAINING a commitment throughEDUCATION operation in both words all levels of the and actions. Management should conduct formalized meetings- PROGRAM perhaps quarterly-to evaluate the suitability and effectiveness of all HACCP-related activities. Any concerns or weaknesses in these should be addressed to ensure product safety.
  • 56. STANDARDS, SAFETY, & STABILITY CONTINUED Personnel suffering from infectious diseases or are carriers of any infectious disease shall not engage in product handling or processing operation. This is covered in our GMP policy and PERSONNEL communicated annually at our GMP training. In PRACTICES addition, personnel with exposed cuts, sores or lesions shall not be engaged in handling or processing product. Minor cuts or PROGRAM abrasions on exposed parts of the body shall be covered with aPRESONNE colored band-aid. LPRACTICE S Outlined in the GMP policy is the prohibition of smoking,PROGRAM chewing, eating, drinking or spitting in any food processing or food handling areas. Clean hands are required by all of our employees. They shall be washed by all personnel upon entering any food handling or processing areas; after each visit to a toilet; after using a handkerchief; after handling wash down hoses or contaminated material; and after smoking, eating or drinking.
  • 57. CONTINUED STANDARDS, SAFETY, & STABILITY CONTINUED Whenever gloves are used, personnel are required to follow the hand washing requirements listed above. The clothing worn by employees is maintained, stored and PERSONNEL PRESONNE laundered by an outside contractor. It is to be worn so as PRACTICES L PRACTICE not to present a contamination risk to product. Employees S PROGRAM PROGRAM are to wear a clean set of uniforms each day. At the end of the day, the soiled uniforms are not to be stored in their locker, instead, they are to be placed in the used laundry bins.
  • 58. Personnel entry into processing& STABILITY STANDARDS, SAFETY, and packaging areas is CONTINUED through the designated doors only. Doors throughout the plant are on automatic closing systems and are to be kept closed at all times. Exterior doors are kept closed and are secured by a key fob system throughout the plant. All personnel are required to wash their hands upon entry into any processing or packaging area.PERSONNE L Per the GMP policy, the wearing of false fingernails andPROCESSI NGPRACTICES fingernail polish is not allowed when handling foodPROGRAM products. Packaging material, product and ingredients are to be PERSONNEL stored off the floor in all areas. Wood pallets are not to be PROCESSING used to store material in the packaging / processing areas PRACTICES use of plastic pallets is for more than an 8 hour shift. The PROGRAM required if material is to stay in the room for an extended period of time.
  • 59. CONTINUED Waste isSTANDARDS, SAFETY, & STABILITY collected in the labeled trash cans CONTINUED and emptied daily by the custodial staff. Waste at the packaging machine machines is collected and discarded by the operations staff throughout the day. Evaluating products in the food handling contact zone is not permitted. All product that is being evaluated by staff is to be done at the designated product evaluation area. The PERSONNE L PROCESSI area is to be maintained in a sanitary manner and NG PRACTICES equipment used is sanitized, maintained and stored PROGRAM separate from processing equipment. PERSONNEL All wash down hoses are stored on provided hose racks after use and not left on the floor. Nozzles are not permitted PROCESSING to touch the floor while in use or storage. PRACTICES PROGRAM
  • 60. Water Quality and Water Treatment ProgramsSTABILITY STANDARDS, SAFETY, & The internal CONTINUED for requirements ensuring the safety of the water supply will depend on its source. An effective UV process supported by records confirming acceptable water potability would be necessary for well water used in production whereas a certificate of compliance combined with periodic (i.e., quarterly, semi-annual) lab testing may WATER QUALITY be sufficient for city water. Keep in mind that ensuring the safety of the water supply may also include attention to boiler additives, ice production, and other PROGRAM water quality/treatment activities. WATER Quality Control and Microbiological Testing Depending on the operation, QUALITYPROGRAM various quality control/quality assurance programs (i.e., microbiological testing, temperature monitoring, pH testing) may be included in prerequisite programs. In most instances, these programs verify and validate the HACCP plan. However incorporated into the plan, specific tests, frequencies and acceptable parameters must be identified and records maintained. All water used meets the requirements of the Pasteurized Milk Ordinance and the federal requirements for potable water. The water used to flush out products meets the requirement per the PMO of pasteurized water or its equivalent. We have completed all sampling and testing of flush points as required by the PMO and submitted results to New
  • 61. STANDARDS, SAFETY, & STABILITY CONTINUED Preventive Maintenance Successful operations perform preventive maintenance (PM) to ensure uninterrupted process; however, many do this informally. A better approach is to formalize the procedures: Identify equipment, required maintenance, frequencies, etc., then PREMISES document performance. Prioritize to identify critical equipment that EQUIPMENTMAINTENANCE must be maintained in a timely fashion, the neglect of which could PROGRAM jeopardize product safety, quality or overall production. A small company may use a structured inventory system instead of a formal PM program to ensure that there are always spare parts for the critical equipment. The system that works best is well defined. PREMISES & EQUIPMENT MAINTENANCE PROGRAM
  • 62. Calibration Any equipmentSAFETY, & STABILITY STANDARDS, used to demonstrate compliance to a CONTINUED specified requirement must be calibrated. Calibration confirms the accuracy of the equipment and should be measured against a known standard. A master list of equipment requiring calibration, CRITICAL frequencies, methods, tolerances, responsibilities, etc., should be CRITICALEQUIPMENT EQUIPMENT maintained along with the required action if an instrument testsCALIBRATIO NS PROGRAM CALIBRATIONS outside acceptable tolerances during routine calibration. Product tested (dating back to the last acceptable calibration check) with out- PROGRAM of-compliance equipment must be evaluated to ensure that it was indeed acceptable. If calibration is an element of the HACCP plan, prove that no food safety hazard was created. Deviations are addressed through programs that control nonconforming product or product recall.
  • 63. STANDARDS, SAFETY, & STABILITY This facility has a Quality Assurance Preventative Maintenance CONTINUED Program detailing the equipment and areas to be cleaned, along with the frequency of cleaning. This program covers the gasket change program, valve inspections, pump inspections, press inspections, and many more PM programs. In addition, there is a Master Sanitation Schedule for each room of the plant detailing the daily cleaning of the areas and the frequency of the cleaning. SSOP‟s are available that have been developed by ourCLEANINGSANITATIO N contracted cleaning company – Basic Chemical Solutions (BCS).PROGRAM These detail the procedures showing how to clean the equipment including the required chemicals to be used. After cleaning of the equipment, the & CLEANING operator is responsible for SANITIZING inspecting the equipment for cleanliness. In our packaging and processing areas, an equipment inspection is conducted prior to PROGRAM start up by the foreman or supervisor on duty. Spot checks are done on the packaging equipment with an ATP swab at the end of cleanup and spot checked prior to startup.
  • 64. CONTINUED We haveSTANDARDS, SAFETY, & STABILITY CONTINUED a detailed equipment inspection form for each of our processing and packaging areas. As the operator cleans an item, they document this on the form. When complete, the on duty supervisor or leadperson do an inspection of the equipment and sign off on the inspection form that the work was satisfactory. If the equipment is not CLEANING SANITATIO clean, it will be noted on the sheet and the equipment will N PROGRAM be re-cleaned until it passes inspection. In addition, a spot check of equipment is conducted using area Swabs, sending out to a 3rd party lab. CIP charts are reviewed and verified each day by the quality & CLEANING assurance department. Our intent is to buy an SANITIZING an ATP analyzer for our agreement for processing facilities.PROGRAM
  • 65. CONTROL MECHANISMS Losurdo Foods, Inc. is America‟s leading Italian style cheese manufacturing specialist. Losurdo Foods, Inc is supplying a variety of Italian style cheeses to the food service and manufacturing industry. Over the last fifty years Losurdo Foods, Inc. has built a reputation for honesty, quality, and superior customer service. It is through the determination in producing only the highest quality product that Losurdo Foods, Inc. has become one of the premier Italian foodsCOMPAN specialists of the industry. YPOLICIE S Losurdo Foods, Inc has fully committed to and execute the principles, practices, and initiatives set forth by Global Food Safety Initiative (GFSI), a non-for profitPOLICIES Safe Quality Foods COMPANY organization. Institute (SQF) has SQF 2000 System which is collaborative and structured guidelines to Safe Quality Foods as part of the Global Safe Food Initiative in conjunction with principles of HACCP (Hazard Analysis Critical Control Points).
  • 66. CONTINUED CONTROL MECHANISMS CONTINUED This initiative will enhance and strengthens our current HACCP Plan and is the foundation of the Losurdo Foods, Inc Food Safety Program. The Code is a HACCP quality management system that utilizes NACMCF (National Advisory Committee on Microbiological Criteria for Foods) and CODEX HACCP Principles and Guidelines, proven methods used by the food industry professionals to reduce the incidence of unsafe food COMPAN Y reaching the marketplace. POLICIE S The main objective of the company and organization is to invest needed resources to fully and continually meet and COMPANY POLICIES improve the safety, quality and consistency of our product line by the implementation of the SQF System 2000 Guidelines. ....A_EDAA_SQF-AMSTERDAM4. SQF 2000 REQUIREMENTS4.1.1.ii.1 METHODS4.1.1.1.SQF.POLICY.REQUIREMENTS.MANUAL.docx
  • 67. CONTROL MECHANISMSCONTINUED Sanitation Programs These define requirements for cleaning and sanitizing activities. In some industries, such as juice processes, documenting these requirements in sanitation standard operating procedures (SSOPs) is required. Obligation or not, SANITATION requirements for performing sanitation activities should be clearly defined in written procedures. Training must be performed in an effective manner that ensures STANDARD responsible associates understand and perform all assigned tasks competently. OPERATING 21 CFR part 178.1010. It is considered one of the prerequisite programs of HACCP.SANITATION PROCEDURES For more information on the reason for SSOP history go to HACCP 1996.ForSTANDARDOPERATING regulations and inspections go to FSIS.PROCEDUR ES SSOP‟s are generally documented steps that must be followed to ensure adequate cleaning of product contact and non-product surfaces. These cleaning procedures must be detailed enough to make certain that adulteration of product will not occur. All HACCP plans require SSOP‟s to be documented and reviewed periodically to incorporate changes to the physical plant. This reviewing procedure can take on many forms, from annual formal reviews to random reviews, but any review should be done by “responsible educated management”. As these procedures can make their way into the public record if there are serious failures, they might be looked at as public documents because they are required by the government.
  • 68. CONTINUED CONTROL MECHANISMS SSOP‟s in conjunction with the Master Sanitation Schedule and Pre- Operational Inspection Program, form the entire Sanitation operational SANITATION guidelines for food related processing and one of the primary backbones of all food industry HACCP plans. STANDARD SSOP‟s can be very simple to extremely intricate depending on the SANITATION STANDARD OPERATING focus. Food industry equipment should be constructed of sanitary OPERATING PROCEDUR ES PROCEDURES design; however some automated processing equipment by necessity is difficult to clean. An individual SSOP should include: •The equipment or affected area to be cleaned, identified by common name, •The tools necessary to prepare the equipment or area to be cleaned •How to disassemble the area or equipment •The method of cleaning and sanitizing
  • 69. CONTROL MECHANISMS CONTINUED 2.1 Definition An important aspect of a quality system is to work according to unambiguous Standard Operating Procedures (SOPs). In fact the whole process from sampling to the filing of the analytical result should be described by a continuous series of SOPs. A SOP for a laboratory can be defined as follows: "A Standard Operating Procedure is a document which describes theSTANDARD regularly recurring operations relevant to the quality of the investigation.OPERATINGPROCEDUR The purpose of a SOP is to carry out the operations correctly and always in ES the same manner. A SOP should be available at the place where the work is done". STANDARDS A SOP is a compulsory instruction. If deviations from this instruction are allowed, the conditions for these should be documented including who can OPERATING give permission for this and what exactly the complete procedure will be. PROCEDURES The original should rest at a secure place while working copies should be authenticated with stamps and/or signatures of authorized persons.
  • 70. CONTINUED CONTROL MECHANISMS CONTINUED Several categories and types of SOPs can be distinguished. The name "SOP" may not always be appropriate, e.g., the description of situations or other matters may better designated protocols, instructions or simply registration forms. Also worksheets belonging to an analytical procedure have to be standardized (to avoid jotting down readings and calculations on odd pieces of paper). A number of important SOP types are: - Fundamental SOPs. These give instructions how to make SOPs of the other categories. STANDARD - Methodic SOPs. These describe a complete testing system or method of OPERATING PROCEDUR investigation. ES - SOPs for safety precautions. STANDARDS - Standard procedures for operating instruments, apparatus and other equipment. OPERATING - SOPs for analytical methods. PROCEDURES - SOPs for the preparation of reagents. - SOPs for receiving and registration of samples. - SOPs for Quality Assurance. - SOPs for archiving and how to deal with complaints.
  • 71. CONTROL MECHANISMS CONTINUED PURPOSE Losurdo Foods audits processes and procedures to determine the effectiveness of the Food Safety Program and to provide objective evidence SELF INSPECTIONS concerning the need for reduction, elimination and prevention of nonconformities. SeniorREGULATORY the results of these audits to & management reviews ensure suitability and adequacy and to continuously improve the documented Food Safety Program. INSPECTIONS SELFINSPECTIONS & RESPONSIBILITYREGULATORYINSPECTIONS Internal Audit Coordinator is responsible for creating and controlling this procedure. Internal auditors are responsible for planning and conducting audits and developing records as defined in this procedure. REQUIREMENTS Internal audits are periodically performed to determine if the Food Safety Program: •Planned and scheduled by the Internal Audit Coordinator •Audits conducted on Plant departments and their associated activities:
  • 72. CONTINUED CONTROL MECHANISMS CONTINUED Scope: Wet receiving To set up guidelines for interaction with and reporting to different agencies and/or third party audits. Dry receiving •NYS Ag & Markets: The General/Plant manager or the QA Lab SELF INSPECTIONS be kept inThe records “NYSthese Markets inspections. or Director will assist the representative/s during their visits inspections. will the Binder from Ag & visits or inspections Maintenance & REGULATORY These records will be kept in the main office. •The USPH (United States Public Health) representatives Ball production and packaging will be assisted by either the General/Plant Manager or the INSPECTIONS QA Directormain office. the facility. USPH records will be Loaf production and Packaging kept in the while visiting SELF •USDA (United States Department of Agriculture) INSPECTIONS & Log Production and Packaging representatives will be assisted by either the General/Plant REGULATORY Manager or the QA Director while visiting the facility. USDA INSPECTIONS Marinade production and packaging records will be kept in the main office. •FDA (Food & Drug Administration) representatives will be Ricotta production and packaging assisted by either the General/Plant Manager or the QA Director while visiting the facility. FDA records will be kept Ricottone production and packaging in the main office. •US Army representatives (Veterinary service) will be Cheddar production and packaging assisted by either the General/Plant Manager or the QA Director while visiting the facility. US Army records will be Cold Storage kept in the main office. •AIB (American Institute of Baking) third party auditor; Shipping representatives will be assisted by either the General/Plant Manager or the QA Director while visiting the facility. AIB records will be kept in the main office. •OSHA (Occupational Safety and Health Administration) representatives will be assisted by either the General/Plant Manager or the QA Director while visiting the facility. OSHA records will be kept in the main office.
  • 73. ....A_EDAA_SQF4. SQF 2000 REQUIREMENTS4.4.4.FOOD.QUALITY.PLAN.CHECKLIST4.4.4.CQP.CHECKLIST.docx ....A_EDAA_SQF4. SQF 2000 REQUIREMENTS4.4.3.FOOD.SAFETY.PLAN4.4.3.FOOD.SAFETY.PLAN.CHECKLIST4.4.3. FOOD.SAFETY.CHECKLIST.docm SELF AUDITS & 3RD PARTY ....A_EDAA_SQF4. SQF 2000 AUDITS REQUIREMENTS4.5.VERIFICATION.SOP.SQF4.5.5.INTERNAL.AUDIT.GUIDE.docx ....A_EDAA_SQF4. SQF 2000 REQUIREMENTS4.5.VERIFICATION.SOP.SQF4.5.5.INTERNAL.AUDITS4.5.5.INTERNAL.A UDIT.SCHEDULE.docx ....A_EDAA_SQF4. SQF 2000 REQUIREMENTS4.1.1.MANAGEMENT.POLICIES4.1.COMMITMENT.STATEMENT.docxORGANIZATIO ....A_EDAA_SQF4. SQF 2000 NALCOMMITTMENT REQUIREMENTS4.1.1.MANAGEMENT.POLICIES4.1.COMMITMENT.STATEMENT (SPANISH).doc ....A_EDAA_SQF9. SQF PRINCIPLES & APPLICATION OF HACCP9.HACCP.TEAM.xlsx
  • 74. QUALITY IMPROVEMENT SYSTEMS Introduction: We can think of the „formation of the HACCP team‟ not only from the perspective of dairy manufacturing and distribution organization that wants to improve its HACCP program but also from the perspective of other organizations – governmental and non-governmental - that wish to develop generic HACCP models or hygiene codes that are consistent EMPLOYEEENVOLVMEN T with HACCP principles for our sub-sectors. One of the main focuses of the global project on „Improving TEAMS EMPLOYEE food safety and quality through the prevention of un- intended results‟ has been the training of a core group of ENVOLVMENT staff within the organization of general principles of food TEAMS hygiene and in HACCP programs. This group has a two-fold core responsibility:
  • 75. CONTINUED QUALITY IMPROVEMENT SYSTEMS CONTINUED • To design and implement further training on food hygiene and HACCP to selected target groups; • To participate in teams to work on the development / refinement of HACCP models and hygiene codes for our sub- categories of food production (this work clearly feeds EMPLOYEE ENVOLVMEN T back in to the training programs that we design and TEAMS implement). ....A_EDAA_SQF9. SQF PRINCIPLES & APPLICATION OF EMPLOYEE HACCPFORMING YOUR HACCP TEAM.docx ENVOLVMENT TEAMS
  • 76. 7 HACCP PRINCIPLES 1.FD & HAZARD ANALYSES 7 HACCP PRINCIPLES 2.CRITICAL CONTROL 1.FD & HAZARD ANALYSES 2.CRITICAL CONTROL POINTS POINTS 3.OPERATING LIMITS CRITICAL LIMITS 3.OPERATING LIMITS 4.MONITORING5.CORRECTIVE ACTIONS6.VALIDATING/VERIFING CRITICAL LIMITS 7.RECORD KEEPING 4.MONITORING 5.CORRECTIVE ACTIONS 6.VALIDATING/VERIFING 7.RECORD KEEPING
  • 77. 7 S Q AFE TY UALI F OODS 2 S HACCP PRINCIPLES 1.FD & HAZARD ANALYSES 2.CRITICAL CONTROL INTERACTIVE 000 ystem POINTS 3.OP LIMITS & CRITICAL LIMITS PRE-EMPTIVE 4.MONITORING 5.CORRECTIVE ACTIONS 6.VALIDATING QUALITY VERIFING 7.RECORD SYSTEM VERIFICATION KEEPING EMPLOYEE ORGANIZATIONAL ENVOLVMEN COMMITMENT T SANITATION TEAMS SELF STANDARD INSPECTIONS OPERATING & SELF CONTROL PROCEDURES REGULATORY COMPAN STANDARD INSPECTIONS OPERATING AUDITS & 3RD MECHANISM Y PROCEDUR PARTY S POLICIE ES AUDITS PRESONN WATER CRITICAL S EL QUALITY EQUIPMENT PRACTIC PROGRA CALIBRATION ES PERSONNE PREMISES S M TRAINING PROGRA L EQUIPMENT PROGRAMCLEANING EDUCATION M PROCESSIN MAINTENAN SANITATION VALIDATION AL G CE PROGRAM PROGRAM CUSTOME PRACTICES RECEIVING PROGRAM PHYSICAL WASTE STANDAR PROGRAM R STORAGE CONTAMINAT CONTROL DS, SAFET COMPLAIN TRANSPO ES PROGRA TS RT CONTROL M Y, & PROGRAMAPPROVE PROGRAM ALLERG PROGRAM PESTTRACEABILI FOOD STABILITY TY D EN MANAGEMEN DEFENS RECALL SUPPLIER CONTRO T EPROGRAM PROGRA L PROGRAM PROGRA 16 – PREREQUISITE PROGRAMS M PROGRA M M
  • 78. Record Control HACCPs Principle Seven (see boxbelow) requires an "effective record keeping systemthat documents the HACCP plan." Readily accessiblerecords must provide evidence that CCPs have beenestablished according to required procedures, andprerequisite programs are maintained in an effectivemanner. Without the proof (record), the activity is nottechnically complete. There can be no assumptions normust any activity be left to interpretation. Theserecord-control programs should include theidentification of the records, retentiontimes, responsibilities, requirements forcompletion, etc. These records should be completed inpermanent ink; all changes to the document must beinitialed. A strong argument can be made supporting a
  • 79. Document Control An effective document controlprocess will include defined requirements forpreparing procedures, work instructions, forms, andother instructional documents. It should also definerequirements for revising and distributing documents.A master list of all documents that includes the currentrevision status of each document and its distributionmust be maintained. This ensures all obsoletedocuments are retrieved and replaced with currentversions. Distribution may include hard-copy versions(maintained in binders or posted in high-traffic areas)or accessibility through computer terminals. Havingcurrent requirements accessible where needed willprevent needless problems.