2.4.3.1 Food Safety Plan
Implementing GFSI Schemes Ann-Marie Beall, Manager, GFSI Training and Calibration, AIB International Certification Services
Key Outcomes • GFSI Overview • Scheme Statistics • Top 5 Focus
Rules for Today
What is it? • The GFSI benchmarking document
• defines requirements for benchmarking process • defines qualifications for accreditation of audit company • defines qualifications for certification of auditors
• Defines the key audit elements that must be met identified within the Standard document
GFSI Organization • The Global Food Safety Initiative – GFSI GFSI Standard Owner Accreditation Body Certification Body
GFSI Benchmarked Audits • There are 11 primary manufacturing Standards that are currently fully benchmarked against the GFSI standard. 4 are most prominent: • • • •
BRC Global Standard (British Retail Consortium) SQF (Safe Quality Food) IFS (International Food Standard) FSSC 22000 - F22K
Scheme Statistics • FSSC – 12,391 certified sites, none FSC J • SQF – 635 certified sites in FSC 25 and 26 • 197 Added in 2016
• IFS – 16,800 certified sites • BRC – 1,307 S&D certified sites
• Approximately 875 between UK and USA
Scheme Statistics • FSSC – 12,391 certified sites, none FSC J • SQF – 635 certified sites in FSC 25 and 26 • 197 Added in 2016
• IFS – 16,800 certified sites • BRC – 1,307 S&D certified sites
SQF Nonconformities • Top Critical NC
• 2.4.1.1 Food Legislation
• Top Major NCs • • • • •
2.4.3.1 Food Safety Plan 2.8.2.1 Allergen Management 2.5.2.1 Validation and Effectiveness 2.5.7.1 Internal Audits 2.4.5.1 Incoming Goods and Services
SQF Nonconformities • Top Minor NCs
• 2.4.3.1 Food Safety Plan • 2.2.2.2 Records • 2.5.7.1 Internal Audits
Correlation:
• Top Major NCs
• 2.4.3.1 Food Safety Plan • 2.5.7.1 Internal Audits
BRC Nonconformities • Top NCs • • • • • • • • •
4.4.10 Pest Proofing 3.1.2.1 Document Authorization 2.6 Defining Scope of HARA 6.4.2 Cleaning Practices 1.1.4 Management Review 4.4.1 Facility Condition 2.11 CCPs 2.7 Hazard Identification 1.2.3 Job Descriptions
BRC Nonconformities • Top NCs • • • • • • • • •
4.4.10 Pest Proofing 3.1.2.1 Document Authorization 2.6 Defining Scope of HARA 6.4.2 Cleaning Practices 1.1.4 Management Review 4.4.1 Facility Condition 2.11 CCPs 2.7 Hazard Identification 1.2.3 Job Descriptions
Top 5 Focus • Management Commitment • Food Safety Plan • Internal Audits • Records • Verification and Validation
Management Commitment
Management Commitment • Scheme-specific requirements:
• Company’s Senior Management shall ensure clear objectives are defined (BRC) • Company’s senior management shall provide human and financial resources (BRC) • Senior Management shall prepare and implement a Policy Statement (SQF) • Senior Management shall ensure adequate resources are available (SQF) • Senior Management shall be responsible for reviewing the SQF System and documenting the review.
Management Commitment Senior Management does not: Attend opening or closing audit meetings Ensure a review process is followed Participate in review process Ensure all programs are implemented Have specific role in Food Defense Have specific role in Product Recall Does not hold personnel accountable for corrective actions !!
Management Commitment • Negative connotation • Say what you do, do what you say • Management review is NOT an internal audit • Follow-through is key
Hold People Accountable
Food Safety Plan • HACCP method
• Codex Alimentarius
• FSMA requirements
• HARPC • Sec 111 – Sanitary Transport of Food • Sec 303/304 – Import of Food
• Documented evidence
• Likelihood / Severity matrix • Scientific articles
Internal Audit • All audits require:
• Ethical conduct • Truthful reporting
• Ties to record keeping
• Due diligence
• Must be thorough
• Competence
• Training to ISO 19011
• Independence
• Do not audit own work
• Evidence based results
Internal Audit • Audit Activities • Opening meeting • Communication & information sharing • Define roles / responsibilities • Collecting and verifying information • Writing audit findings – positive & negative • Audit conclusion / consensus • Closing meeting
Internal Audit • Are personnel working in accordance with procedures and work instructions / best practices? • Are existing procedures, work instructions and personnel skills adequate to ensure effective quality and food safety controls? • Are all activities adequate to meet company requirements for employee health, safety, food safety, environmental security and other programs affecting internal and external stakeholders? • Are company objectives being met for all company policies and customer requirements? Note: Audits are a sampling, not a 100% review
Records – Accuracy is Key!
Records • Legible, genuine • Retained at appropriate frequency • Correct revision • Verification
Verification and Validation • Each scheme defines verification and validation slightly differently….. • Yet each essentially means the same thing! • Verification – are we doing what we say we’re doing? • Validation – is what we’re doing effective?
Verification and Validation • One more question to ask: • What hazard is this program designed to control? • This question leads to the appropriate verification and validation activity
• Verification and validation may be the same information • Water quality testing
Verification and Validation SQF Verification and Validation Worksheet (SAMPLE) Program
Verification Activities What Self-Inspections - Employees complying with company policies
do?)
(Are we doing what we said we would Validation
Who
Self-Inspection Team
When
Weekly
Personnel Practices
Personnel Processing Practices
Self-Inspections - Employees complying with company processing practices
Internal Audit - Ensure documented training is on file for each task each employee carries out.
Training of Personnel
Self-Inspection Team
Internal Audit Team
Weekly
Annually
Activities
getting our desired results?)
What
Who
(Are we When
Micro swabbing of hands after hand washing
QA Manager
Quarterly
Review of Complaints related to Personnel Practices
QA Manager
Monthly
Review of Holds related to Personnel Practices
QA Manager
Monthly
Review of Complaints related to Personnel Processing Practices
QA Manager
Monthly
Review of Holds related to Personnel Processing Practices
QA Manager
Monthly
Internal Audit - Employee interviews
Internal Audit Team
Annually
Performance Reviews - Observe employees completing tasks
Department/Sh ift Supervisors Annually
Review of Complaints related to lack of effective training QA Manager
Monthly
Review of Holds related to lack of effective training
Monthly
QA Manager
Sometimes, It Feels Like….
Implementation Really Is….
Thank You! • Any other questions?
Key Outcomes • GFSI Overview • Scheme Statistics • Top 5 Focus
Rules for Today
What is it? • The GFSI benchmarking document
• defines requirements for benchmarking process • defines qualifications for accreditation of audit company • defines qualifications for certification of auditors
• Defines the key audit elements that must be met identified within the Standard document
GFSI Organization • The Global Food Safety Initiative – GFSI GFSI Standard Owner Accreditation Body Certification Body
GFSI Benchmarked Audits • There are 11 primary manufacturing Standards that are currently fully benchmarked against the GFSI standard. 4 are most prominent: • • • •
BRC Global Standard (British Retail Consortium) SQF (Safe Quality Food) IFS (International Food Standard) FSSC 22000 - F22K
Scheme Statistics • FSSC – 12,391 certified sites, none FSC J • SQF – 635 certified sites in FSC 25 and 26 • 197 Added in 2016
• IFS – 16,800 certified sites • BRC – 1,307 S&D certified sites
• Approximately 875 between UK and USA
Scheme Statistics • FSSC – 12,391 certified sites, none FSC J • SQF – 635 certified sites in FSC 25 and 26 • 197 Added in 2016
• IFS – 16,800 certified sites • BRC – 1,307 S&D certified sites
SQF Nonconformities • Top Critical NC
• 2.4.1.1 Food Legislation
• Top Major NCs • • • • •
2.4.3.1 Food Safety Plan 2.8.2.1 Allergen Management 2.5.2.1 Validation and Effectiveness 2.5.7.1 Internal Audits 2.4.5.1 Incoming Goods and Services
SQF Nonconformities • Top Minor NCs
• 2.4.3.1 Food Safety Plan • 2.2.2.2 Records • 2.5.7.1 Internal Audits
Correlation:
• Top Major NCs
• 2.4.3.1 Food Safety Plan • 2.5.7.1 Internal Audits
BRC Nonconformities • Top NCs • • • • • • • • •
4.4.10 Pest Proofing 3.1.2.1 Document Authorization 2.6 Defining Scope of HARA 6.4.2 Cleaning Practices 1.1.4 Management Review 4.4.1 Facility Condition 2.11 CCPs 2.7 Hazard Identification 1.2.3 Job Descriptions
BRC Nonconformities • Top NCs • • • • • • • • •
4.4.10 Pest Proofing 3.1.2.1 Document Authorization 2.6 Defining Scope of HARA 6.4.2 Cleaning Practices 1.1.4 Management Review 4.4.1 Facility Condition 2.11 CCPs 2.7 Hazard Identification 1.2.3 Job Descriptions
Top 5 Focus • Management Commitment • Food Safety Plan • Internal Audits • Records • Verification and Validation
Management Commitment
Management Commitment • Scheme-specific requirements:
• Company’s Senior Management shall ensure clear objectives are defined (BRC) • Company’s senior management shall provide human and financial resources (BRC) • Senior Management shall prepare and implement a Policy Statement (SQF) • Senior Management shall ensure adequate resources are available (SQF) • Senior Management shall be responsible for reviewing the SQF System and documenting the review.
Management Commitment Senior Management does not: Attend opening or closing audit meetings Ensure a review process is followed Participate in review process Ensure all programs are implemented Have specific role in Food Defense Have specific role in Product Recall Does not hold personnel accountable for corrective actions !!
Management Commitment • Negative connotation • Say what you do, do what you say • Management review is NOT an internal audit • Follow-through is key
Hold People Accountable
Food Safety Plan • HACCP method
• Codex Alimentarius
• FSMA requirements
• HARPC • Sec 111 – Sanitary Transport of Food • Sec 303/304 – Import of Food
• Documented evidence
• Likelihood / Severity matrix • Scientific articles
Internal Audit • All audits require:
• Ethical conduct • Truthful reporting
• Ties to record keeping
• Due diligence
• Must be thorough
• Competence
• Training to ISO 19011
• Independence
• Do not audit own work
• Evidence based results
Internal Audit • Audit Activities • Opening meeting • Communication & information sharing • Define roles / responsibilities • Collecting and verifying information • Writing audit findings – positive & negative • Audit conclusion / consensus • Closing meeting
Internal Audit • Are personnel working in accordance with procedures and work instructions / best practices? • Are existing procedures, work instructions and personnel skills adequate to ensure effective quality and food safety controls? • Are all activities adequate to meet company requirements for employee health, safety, food safety, environmental security and other programs affecting internal and external stakeholders? • Are company objectives being met for all company policies and customer requirements? Note: Audits are a sampling, not a 100% review
Records – Accuracy is Key!
Records • Legible, genuine • Retained at appropriate frequency • Correct revision • Verification
Verification and Validation • Each scheme defines verification and validation slightly differently….. • Yet each essentially means the same thing! • Verification – are we doing what we say we’re doing? • Validation – is what we’re doing effective?
Verification and Validation • One more question to ask: • What hazard is this program designed to control? • This question leads to the appropriate verification and validation activity
• Verification and validation may be the same information • Water quality testing
Verification and Validation SQF Verification and Validation Worksheet (SAMPLE) Program
Verification Activities What Self-Inspections - Employees complying with company policies
do?)
(Are we doing what we said we would Validation
Who
Self-Inspection Team
When
Weekly
Personnel Practices
Personnel Processing Practices
Self-Inspections - Employees complying with company processing practices
Internal Audit - Ensure documented training is on file for each task each employee carries out.
Training of Personnel
Self-Inspection Team
Internal Audit Team
Weekly
Annually
Activities
getting our desired results?)
What
Who
(Are we When
Micro swabbing of hands after hand washing
QA Manager
Quarterly
Review of Complaints related to Personnel Practices
QA Manager
Monthly
Review of Holds related to Personnel Practices
QA Manager
Monthly
Review of Complaints related to Personnel Processing Practices
QA Manager
Monthly
Review of Holds related to Personnel Processing Practices
QA Manager
Monthly
Internal Audit - Employee interviews
Internal Audit Team
Annually
Performance Reviews - Observe employees completing tasks
Department/Sh ift Supervisors Annually
Review of Complaints related to lack of effective training QA Manager
Monthly
Review of Holds related to lack of effective training
Monthly
QA Manager
Sometimes, It Feels Like….
Implementation Really Is….
Thank You! • Any other questions?
