Food Safety - CIEH Level 4

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Khurram K Qazi Production Shift Manager Level 4 Award in Food Safety Management for Manufacturing September 3 2010 Staplemead is a Dairy Manufacturing Company located in From, Somerset. The main products include Custards, Sour Cream, and Flavoured milk. Staplmead Ltd. Frome, Somerset BA11 2NQ 01373 457600

Transcript of Food Safety - CIEH Level 4

Khurram K Qazi

Production Shift Manager

Level 4 Award in Food Safety Management for Manufacturing

September 3

2010Staplemead is a Dairy Manufacturing Company located in From, Somerset. The main products include Custards, Sour Cream, and Flavoured milk.

Staplmead Ltd. Frome, Somerset BA11 2NQ 01373 457600

Changes in legislation effective from January 2006 have placed greater accountability on

anyone in the food business with supervisory responsibility. It is therefore vital they are

equipped with both the knowledge and confidence to do their job effectively. This advanced

level course is designed for those working in food businesses at a managerial level and

responsible for the planning and implementation of a cost-effective food hygiene

programme and training. From October, this will be a six day course. The course has been

developed for those who are responsible for the control and promotion of effective food

safety practice in the workplace.

Effective food safety training ensures we know WHY we must do the right things not simply

WHAT we should be doing. When food handlers get it wrong our consumers and our

business suffer.

There are rarely second chances when it comes to food safety and the reputation of our

business. Customer awareness increases daily thanks to the speed and availability of

information. Never before have had our customers had so much choice about what they

buy from where.

The Level 4 Award in Food Safety is the CIEH's higher level accredited course (formally

called "Advanced") and is designed for those whose roles require that extra knowledge

including Food Business Operators, Owners, Technical Managers, Hygiene Managers,

Production Managers and Trainers. These courses are provided to support the specialist in

our business.

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Level ~ Award in Food Safety Management for Manufacturing Candidate assessment record

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feedback report are all

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Title of assignment:

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Candidate's signature: Date:

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I hereby certify that to the best of my knowledge the submitted assignment is the candidate's own work and that he/she has not received unauthorised assistance in completing this assignment.

I Trainer's signature: Date:

Trainer's name (block capitals): Trainer no:

Assignment A - Food safety management procedures (Compulsory)

Your report must contain the following sections:

1 A description of how food safety management procedures ensure effective compliance with current legislation and codes of practice in your catering business. 10 marks

2 An explanation of how you, as a manager in your manufacturing business, can establish, monitor and verify food safety management procedures. 15 marks

3 A critical analysis of an incident when a food safety management procedure failed - including

recommendations of the corrective actions that could be taken and an explanation of how this information could be communicated to staff to ensure food safety in the future. 25 marks

Please note: The food safety management procedure selected for Section 3 ofyour report must not be

the same as the one selected for your elective assignment.

Assignment A:

Food Safety Management Procedures 1. Description of how food safety management procedures ensure

effective compliance with current legislation and codes of practice in

your catering business

1. From 1st January 2006 a number of new food hygiene regulations apply in the UK. The most

important regulations for business are:

- Regulation (EC) No 852/2004

- The Food Hygiene (England) Regulations 2006

Almost all of the requirements in the new laws are the same as the ones they replace. The main new

requirement is that we must be able to show what we do to make or sell food that is safe to eat and

have this written down.

2. The law requires us to have in place procedures to manage food safety ‘hazards’. This is similar to

previous legal requirements, but we must now write our procedures down, keep them up to date and

regularly review them.

3. These procedures can be in proportion to the size of business and the type of work we do.

A few major pieces of food safety legislation now cover all sectors of the food chain ‘from farm to

fork’, consolidating a lot of previous sector-specific and product-specific requirements. The main

legislations are below:

Regulation (EC) No. 178/2002 – this contains many of the definitions and basic principles for most

matters relating to hygiene

Food Safety Act 1990 – this deals mainly with food standards

The Food Hygiene (England) Regulations 2006 and the equivalent legislation for Wales, Scotland and

Northern Ireland – these deal with general food Hygiene requirements in the UK, offences and the

provision of enforcement powers.

Regulation (EC) No. 852/2004 on the hygiene of foodstuffs – this contains the main hygiene

requirements with which all businesses must comply, including a requirement to incorporate HACCP

principles into company procedures.

Regulation (EC) No. 2073/2005 on the microbiological criteria for foodstuffs – a perspective piece of

legislation dealing with microbiological standards in certain foods

General Food Regulations 2004 – deals mainly with legal issues, including offences under Regulation

(EC) No. 178/2002

Food Safety Management Procedures

Risk assessments have been done

to all the departments and lines. All

hazards were taken into account

like Microbiological, Chemical,

Physical and Allergens. From intake

of raw materials to the delivery of

finished goods. Everything has

been recorded for traceability.

How we do it

This piece of legislation is sometimes unofficially referred to as ‘the European food safety Act’ because it

establishes the principles of food law and identifies the legal obligations of business and governments.

It covers all stages of the food chain from

primary production to the sale (‘placing on

the market’) o products and establishes

the rights of consumers to safe food and to

accurate and honest information about it

It includes:

Many of the definitions used in EU food law

The general principles of food law based on risk

management and precautionary principle

Safety requirements for food placed on the market

Procedures for dealing with food safety problems

The principle of traceability

Arrangements for the removal of unsafe food from

the market

Regulation (EC) No. 178/2002

Article 6 Risk

Food law must be based upon

risk analysis, consisting of risk

assessment, risk management

and risk communication. Risk

assessment must be based on

available scientific evidence

Risk based approach required

Article 14

Unsafe food defined as being

injurious to human health or unfit

for human consumption because of

contamination or spoilage

How we do it

There is a HACCP system in place

which makes sure food is safe to

eat.

It is deemed to be unsafe if it is

considered to be:

a) Injurious to health

b) Unfit for human consumption

because of contamination or

spoilage.

If part of a batch is considered

unsafe, then the whole batch is

considered unsafe, unless it can be

demonstrated otherwise.

Food safety requirements

Food law must be based upon risk

analysis, consisting of risk

assessment, risk management

and risk communication. Risk

assessment must be based on

available scientific evidence

Article 16

Packaging etc must not mislead

consumers

How we do it

There is a HACCP system in place

which makes sure food is safe to

eat.

Making sure the correct labels with

ingredients are on package. Also

Use by or BBE dates are to ensure

that food is safe for consumption.

Misrepresentation

The promotion, packaging,

labelling, display setting and so on

must not lead consumers

Article 18

Product tracing systems required

throughout the food chain.

How we do it

At all stages of production,

processing and distribution there is

a system in place, which include

identification of documentation, to

ensure that food placed on the

market can be traced, and the

information can be made available

to the competent authorities when

requested to do so. All suppliers

are approved and identifiable.

There is ‘one up, one down’

traceability on place.

Traceability

All procedures and steps with

materials should be traceable.

Article 19

Systems for withdrawing and

recalling unsafe food.

How we do it

System in place where if a business

believes that food is unsafe,

immediate initiating procedures

kicked up to withdraw food from

the market and, if necessary, can

be recall food that has already

reached the consumer.

Withdrawal or recall

In case of emergency, unsafe food

must be withdraw or recalled

back.

The Food Safety Act 1990, is an Act of Parliament of the Parliament of the United Kingdom. It regulates the statutory obligation to treat food intended for human consumption in a controlled and managed way.

The key requirements of the Act are that food must comply with food safety requirements, must be "of the nature, substance and quality demanded", and must be correctly described (labelled).

Food Safety Act 1990

Section 14

Nature – food different to what

was requested.

Substance – not of the correct

composition or containing physical

contaminants.

Quality – the standard expected.

How we do it

All products have got their Checks

before Production. Aroma, texture,

Nature, pH, Colour, Viscosity, Fat

levels%, Weights, Sizes etc. All

approved by customers and have a

check sheets to make sure all

products meet customer demand.

Consumer Protection

All food sold must be ‘of the

nature or substance or quality

demanded by the purchaser’.

These Regulations, which came into force in January 2006, are:

The Food Hygiene (England) Regulations 2006

The Food Hygiene (Wales) Regulations 2006

The Food Hygiene (Scotland) Regulations 2006

The Food Hygiene (Northern Ireland) Regulations 2006 and subsequent amendments.

The regulation deals largely with the regulation and enforcement of food safety, plus temperature control,

and is the main British route to enforcing the main European Regulations.

Food hygiene Regulations 2006

Regulations 10 & 11

Defence of due diligence. Offence

committed by someone else.

How we do it

To demonstrate that every

possible reasonable step taken to

achieve safe food, we have written

records to support defence. All

documents based on HACCP

Principles like, records of Staff

Training, Temperature

measurements, cleaning

schedules, supplier specifications,

traceability system, remedial

action where food safety problems

have arisen and pest control

measures.

Defences and Offences

Two main defences under these

Regulations, either:

That the offence was the

fault of another person

due diligence

Schedule 4

Detailed temperature control

requirements. Chill and Hot

holding requirements.

How we do it

We have all the temperature

control system and records in

place to support HACCP.

Pasteurization Temp

Holding Tanks Temp

Raw material storage and Temp

Final Product Temp

Cold Store Temp

Despatch Temp

Temperature Control

High-risk foods must be kept or

below 8 °C or at 63 °C above.

The fundamental aim of any hygiene regulation is to create conditions in a food business that will lead to the safe

working production of food. Generally Speaking, this regulation takes a two-prolonged approach.

The management and control of the structure of food premises and the equipment used

The management and control over what happens in food premises

The Regulation seeks to ensure a high level of food hygiene at all stages of the production process (production,

processing and distribution of food). A key point of the legislation is that the main responsibility for food safety

rests with “food business operators”, with a single hygiene policy applicable to all foodstuffs and all operators.

The text defines the obligations of food operators, setting out general and specific hygiene rules and requiring

the establishment, implementation and maintenance of procedures based on HACCP principles.

The regulation foresees that food businesses may use guides to good practices as an aid to comply with their

obligations. Such guides to good practices for hygiene and for the application of HACCP principles can be

developed by each sector at national or Community level.

To facilitate the implementation and interpretation of the Regulation, the European Commission issued the

following guidance documents:

Guidance document on the implementation of certain provisions of Regulation 852/2004/EC on the

hygiene of foodstuffs;

Guidance document on the implementation of procedures based on the HACCP principles, and on the

facilitation

Regulation (EC) No. 852/2004 on the hygiene of foodstuffs

Article 5

Procedures must exist based upon

HACCP principles

How we do it

1: Conduct a hazard analysis.

2: Identify critical control points.

3: Establish critical limits for each critical control point.

4: Establish critical control point monitoring requirements.

5: Establish corrective actions.

6: Establish record keeping procedures.

7: Establish procedures for verifying the HACCP system is working as intended

Hazard analysis and critical

control points

Food business operators must put

in place, implement and maintain

permanent procedures based on

the principles of HACCP.

Article 6

Food business must register

How we do it

Registered with the local council

and competent Authority.

Registration

Food business must register all

premises with the competent

authority.

Main requirements of the regulations

Here is a short summary of the main requirements of Schedule 1 of the regulations.

Schedule 1, Chapter I: General requirements for food premises (other than those specified in Chapter III)

Equipment & facilities Actions

I.1: Food premises Keep clean, and in good repair and condition

I.2: Layout, design, construction and size

Should permit god hygiene practice and be easy to clean and/or disinfect, and should protect food against external sources of contamination such as pests

I.3: Sanitary & hand washing facilities

Adequate facilities must be available, and lavatories must not lead directly into food handling rooms

I.4: Washbasins

Must have hot and cold (or appropriately mixed) running water and materials for cleaning and drying hands. Where necessary there must be separate facilities for washing food and hands

Provide soap and suitable hand-drying facilities

I.5 & I.6: Ventilation

There must be suitable and sufficient means of natural or mechanical ventilation. Ventilation systems must be accessible for cleaning — e.g., give easy access to filters.

I.7: Lighting Food premises must have adequate natural and/or artificial lighting

I.8: Drainage Adequate drainage facilities must be provided

I.9: Changing facilities Adequate changing facilities must be provided where necessary

Schedule 1, Chapter II: Specific requirements in rooms where

foodstuffs are prepared, treated or processed (excluding dining areas and those premises specified in

Chapter III)

Equipment & facilities Actions

II.1: Rooms where food is actually prepared, treated or processed

Floors, walls, ceilings and surfaces (which come into contact with food) must be adequately maintained, easy to clean and, where necessary, disinfect

Keep all surfaces, fixtures and fittings hygienic to prevent contamination of food

II.2: Cleaning and disinfecting of tools, utensils and equipment

Provide adequate facilities, including hot and cold water, for cleaning and, where necessary, disinfecting tools and equipment

Clean and disinfect tools and equipment to ensure food safety

II.3: Washing of food Where appropriate provide adequate facilities for washing food. Supply with hot and/or cold water as required

Wash food properly where necessary

Schedule 1, Chapter III: Requirements for movable and/or

temporary premises (such as marquees, market stalls, mobile

sales vehicles), premises used primarily as a private dwelling, premises used occasionally for catering purposes, and vending

machines

Equipment & facilities Actions

III.1: Requirements for premises and vending machines

The sitting, design and construction must aim to avoid contamination of food and the harbouring of pests

Keep clean and in good repair to avoid food contamination

III.2(a): Working practices for movable or temporary premises

Provide appropriate facilities for personal hygiene

Take all reasonable practical steps to avoid the risk of contamination of food or ingredients

III.2(b): Surfaces Surfaces in contact with food must be easy to clean and, where necessary, disinfect

Take all reasonable practical steps to avoid the risk of contamination of food or ingredients

III.2(c) & (d): Cleaning of utensils and foodstuffs

Adequate provision must be made for cleaning foodstuffs, and for the cleaning and, where necessary, disinfecting of utensils and equipment

Take all reasonable practical steps to avoid the risk of contamination of food or ingredients

III.2(e): Hot and cold water supply An adequate supply of hot and/or cold potable water must be available

Take all reasonable practical steps to avoid the risk of contamination of food or ingredients

III.2(f): Waste storage and disposal Adequate arrangements must be made for the storage and disposal of waste

Take all reasonable practical steps to avoid the risk of contamination of food or ingredients

Schedule 1, Chapter IV: Transport Equipment & facilities Actions

IV.1: Containers and vehicles used for the transport of food

Where necessary their design must allow them to be adequately cleaned and disinfected

Keep clean and in good order to prevent contamination

IV.2: Dedicated containers and vehicles used for bulk transport of food in liquid, granular or powder form

Containers or vehicles used must be reserved for food only and marked as such, when there is a risk of contamination

Do not use the containers or vehicles to transport anything other than food if this may result in contamination

IV.3: Containers or vehicles used for different foods or for both food and non-food products

Where necessary separate different products effectively to protect against the risk of contamination

IV.4: Where different products have been carried in the same containers

Effectively clean them between loads to avoid the risk of contamination

IV.5: Minimising the risk of contamination

Foodstuffs in conveyances or containers must be placed so as to minimise the risk of contamination

Schedule 1, Chapter V: Equipment requirements

Equipment & facilities Actions

V.1: Equipment requirements

Articles, fittings and equipment that can come into contact with food shall be made of such materials and maintained so that they, and the surrounding areas, can be kept clean and, where necessary, disinfected.

All equipment and surfaces that come into contact with food must be kept clean. On the line automatic cleaning system is installed and with Caustic in the middle to make sure it is cleaned and disinfected later

Schedule 1, Chapter VI: Food waste Equipment & facilities Actions

VI.1: Food and other waste

Do not allow food and other waste to gather in food rooms, unless this is unavoidable for the proper functioning of your food business

VI.2: Containers for food and other waste

Containers must be able to be closed unless the environmental health services are satisfied that this is not appropriate. They must be kept in good condition and, where necessary, be easy to clean and disinfect

VI.3: Arrangements for the storage and removal of refuse

Refuse stores to be designed and constructed to be easily cleaned and to prevent pests gaining access

Arrange for the proper periodic removal of the refuse and keep the area clean; protect against pests and contamination generally

Schedule 1, Chapter VII: Water supply Equipment & facilities Actions

VII.1: Water supply There must be an adequate supply of potable (drinking) water

Where necessary for food safety use potable water to prevent contamination

VII.2: Ice

Where appropriate, ice must be made from potable water to prevent contamination. Ice should be stored and handled carefully to protect it from contamination

Schedule 1, Chapter VIII: Personal hygiene Equipment & facilities Actions

VIII.1: Personal hygiene Food handlers must wear suitable clean and, where appropriate, protective clothing

Everyone in a food handling area must maintain a high level of personal cleanliness

VIII.2: Infected food handlers

No-one who is suffering from (or a carrier of) a disease which could be transmitted through food should work in a food handling area

Schedule 1, Chapter IX: Provisions applicable to foodstuffs

Equipment & facilities Actions

IX.1: Raw materials

No raw materials or ingredients should be accepted if known or suspected of being contaminated and which would still be unfit after normal sorting or processing

IX.2: Protection of raw materials from contamination

At any stage of the business operation food must be protected from contamination likely to render it unfit for human consumption

Schedule 1, Chapter X: Training Equipment & facilities Actions

X.1: Training

All food handlers must be supervised and instructed and/or trained in food hygiene matters to a level appropriate to their job

Assignment A:

Food Safety Management Systems

2. An explanation of how you, as a manager in your manufacturing business, can

establish, monitor and verify food safety management procedures

Assignment A:

Food Safety Management System

PRE REQUISITES:

Training

Waste disposal

Training

It is recommended that food handlers receive

refresher training

How we do it

To ensure that all personnel performing work that

affects product safety, legality and quality are

demonstrably competent to carry out their activity

through training, work experience or qualification.

All relevant personnel including temporary staff

and contractors are appropriately trained prior

to commencing work and adequately

supervised throughout the working period. This

is in the form of an induction either carried out

by the agency or on site. All staff should have

completed induction training prior to the end of

their probationary period. An induction

checklist should be signed off as confirmation

this has been carried out. All new staff to the

factory should sign off first day induction

training to confirm they are aware of the points

documented. A copy should be kept by

employee and held on file.

All personnel engaged in activities relating to

critical control points should have relevant

training and documented evidence will be a

record made on the persons training records

covering off the CCP.

Personnel hold each persons training records to

provide evidence what training is required to

carry out the role and signed off documentation

on the status of the training carried out.

Internal audits and monitoring of Quality Defect

Alerts are used as a method of reviewing the

implementation and effectiveness of training

and competency of trainer.

All staff complete a 13 week probationary

period which is monitored by departmental

heads and personnel department.

How we do it

All training records have:

a. Name of employee

b. A sign off following any attendance of any course

c. Date and if necessary duration of training

d. Title of course or time being trained

e. Training provider

f. A copy of the contents of the course should be held

with training/personnel department.

A yearly review of the competencies of staff is carried

out and where necessary relevant training is carried out

as deemed necessary by the departmental head. The

review will take into consideration any finding following

internal audits, quality defect alerts or changes that

have arisen within the department. The review should

be documented by the departmental head and signed

off on the training log. Relevant training can be either

by formal training, on the job experience or refresher

training.

Food Safety refresher training should be carried out on

average every 3 – 4 years.

Documentation Held In

First Day Induction Personnel

Induction Check List Personnel

Personal Hygiene How we do it

Personal Hygiene ensures that personal hygiene

standards are documented and are adopted by all

personnel, including contractors and visitors to the

production facility.

1. The site has in place “site hygiene rules” which cover

off the following:

a. Jewellery

b. Hand washing

c. Fingernails

d. Perfume

e. Smoking

f. Cuts and grazes

This is communicated to staff either via an induction or

by individual letters; it is then regularly checked during

the departmental hygiene audit in addition to random

checks by team leaders and managers.

2. Only approved plasters are allowed in production

areas, these are blue metal detectable plasters, they are

controlled, by first aiders who issue and document the

issue number and person issued to. A sign off at end of

shift by the person who has received the plaster is

carried out to reconcile issue and no loss. The plasters

are also checked to ensure that they are rejected by the

metal detector as each new supply is received on to

site. This is documented. The plaster issue log states

what action must be taken in the event of a plaster that

is lost.

3. It is Staplemead’s policy that no medication is stored

in first aid rooms. The only items that can be stored are

plasters, bandages, eyewash etc. Should personnel need

medication during their working period the following

procedures must be observed:

• No medication in any form – liquid, powder, tablets or

pastels are allowed in production areas at any time.

• Certain exceptions will have to be made in the case of

medication that must remain on the person at all times

e.g. inhalers. In these situations (unless situation is life

threatening) then the operators must remove

themselves from the immediate production area prior

to administrating the said medication.

• Any medication brought on site must be stored safely

and locked in personnel lockers.

Documentation Held In

Site Hygiene rules, PR-042 Technical

Plaster metal detection log. Log-009 Technical

Plaster Issue Log, Log-044 Technical

Lost Plaster Investigation Form, Log-045 Technical

Good Hygiene Practices

Examples include:

How we do it

ALL Personnel entering production areas must wash

their hands on entering. The alcohol gel is to be used

after drying hands in order to sanitise the hands. There

is the provision for the use of barrier cream which is to

be used after washing hands for engineers due to the

nature or their work. In addition hands should be

washed after eating, smoking, coughing/sneezing into

hands, touching face/nose, touching floor, tying laces or

handling unsuitable containers/materials, using the

toilet before leaving the toilet block.

a) Wet hands

b) Apply soap

c) Rub palms and back of hands thumbs, backs of and

between fingers and repeat 5 times

d) Rinse with water

e) Dry hands

f) Apply and rub in sanitizer

Regular thorough hand washing

Documented cleaning instructions are in place and

maintained for buildings, services and equipment. All

cleaning instructions state who is responsible, what

item needs to be cleaned, frequency of cleaning,

method of cleaning, cleaning materials to be used. Sign

off is recorded and team leaders/coordinator sign off as

verification.

CIP facilities are monitored and maintained to ensure

effective operation. Frequency is recorded on logs or by

PC, cycle times and temperature is either recorded on

logs or by PC. Chemical concentration is checked by

conductivity checks carried out by operators. Spray ball

location and coverage is checked either weekly or

monthly depending on the department. CIP has

adequate separation from active product lines.

Effective Cleaning

All products packed within Staplemead Ltd are kept

<8°C, Target <7°C, unless the products are hot filled.

If there is a break down during production that is longer

than 2 hours or where the product is >8°C the packed

product is placed in the cold store until breakdown has

be actioned. All product left in hoppers >10°C to be

purged to waste prior to start up.

All products after filling are stored in a cold store which

is between 0°C – 5°C within 1 hour, unless the product is

a hot filled product.

All products are <5°C on despatch.

Where product is know to be warm, it is passed down

the wind tunnel to accelerate cooling to <5°C within 4

hours.

Temperature controlled storage areas must be

controlled within the set limits found on the monitoring

systems within each department, e.g. main Cold Store

log CSL- In the event that when a check is carried out

and found to be out of the defined limits the following

action must take place.

a. Team leader must be informed immediately together

with engineering department and technical department.

b. In conjunction all three areas of responsibility must

carry out a risk assessment to establish what course of

action is required and issued with a unique number,

CSL-59.

c. Team leader to ensure action required is carried out.

Construction, design and maintenance of premises

How we do it

There are separate hand basins just to wash hands.

There is a hand washing policy where washing hands

with anti-bacterial soap with running hot water. After

washing drying with disposable paper towels and after

drying sanitising hands with a sanitizer.

The site is located in a rural area that is free from any

adverse impact from the environment. Measures such

as pest proofing production areas, lying bait boxes on

the perimeter of the site the production areas are taken

to prevent product contamination and filtration of air

entering high risk production areas.

The boundaries of the site are defined by the River

Frome the stream and ditches.

2. The external areas are maintained and managed by

the Site Services Manager. Grassed areas are tended

and maintained by a gardening contractor.

A clean and unobstructed area is provided along

external walls of buildings used for production and

storage. In areas where there are adjoining walls

inspection and cleaning procedures are in place to

ensure that the product is protected and food hygiene

standards are maintained.

3. Drains are situated to ensure that rain water and

spillages are directed away from production and storage

areas.

4. External traffic routes are suitably surfaced and are

maintained in good repair to avoid contamination of

product.

5. Building fabric maintenance is ongoing to minimise

potential for product contamination by pest entry,

ingress of water or other contaminants.

Documentation Held In

Site perimeter audits Technical Proofing audits Technical Pest Control company audits/action Technical

Pest Control How we do it

1. Pest Control is undertaken by a Pest Control

Contractor. The overall responsibility for Pest

Control on site is that of the Technical Manager or

Technical Support Manager.

2. The service contract is defined and reflects the

activities on site, a copy of the contract is held with

the pest control manual.

3. An up to date, signed and authorised plan is in place

identifying numbered pest control device locations.

4. Bait boxes are robust, of tamper resistant

construction, secured in place and are appropriately

located to prevent contamination risk to product.

5. Electric fly killers are site at key production areas as

detailed in the site plan held in the pest control

manual.

6. In the event of infestation immediate action will be

taken to eliminate the hazard. Action shall be taken

to identify, evaluate and authorise the release of

any product potentially affected.

7. Detailed records of pest control inspections,

recommendations and actions taken are monitored.

Completion of corrective action is demonstrated by

documented evidence.

8. Results of pest control inspections are assessed and

analysed for trends on a yearly basis or after any

infestation.

Documentation Held In

Pest Control Manual Technical Corrective Action Log Technical

Developing a HACCP Plan

HACCP is a system of extensive evaluation and control over an entire food production process for the sole

purpose of reducing potential food-related health risks to consumers. A HACCP program maintains safety and

wholesomeness of food products because potential hazards that may occur during processing are anticipated,

evaluated, controlled and prevented. A hazard is defined as any biological, physical or chemical property that

could cause a product to be unsafe for consumption. Processing plants are required to have a HACCP plan for

each product. The general steps for developing a HACCP plan are briefly described below.

Support of Management

The success of HACCP depends upon the behaviour and commitment of all plant employees to food safety.

Management must provide financial and philosophical support to HACCP because it demonstrates an awareness

of the benefits of the program. Employees will not take HACCP seriously if it does not receive visible support from

their supervisors and upper management.

Establish a HACCP Team

HACCP is a program for the entire company; therefore, a team of individuals from different areas of production

and processing should be involved in developing the HACCP plan. The team must include individuals with specific

expertise, such as production, processing, quality control, sanitation, microbiology, plant engineering, and

research and development. This should make it easier to identify the hazards associated with each product. A

HACCP coordinator should be chosen to work with the HACCP team and company management to develop,

implement and manage the HACCP plan.

Product Description

Plants are required to have a HACCP plan for each product they make. With each HACCP plan, a complete

description of the product and the raw ingredients that go into the product are required. Some of the product

description information that should

be listed for each product includes:

Product's common name

How the product will be used

Type of packaging material

Length of product's shelf-life, and at what temperature

Where product will be sold

Product's labelling instructions

Any special instructions for the product

Writing a HACCP PLAN

Employee Training

All employees should be given HACCP training, but at levels relating to their responsibilities within the HACCP

plan. Extensive training of line workers is critical because these are the individuals responsible for the product.

Everyone at the facility in contact with the products should receive an overview of HACCP, as well as information

regarding the company’s HACCP policies and procedures.

Principles of HACCP and Implementation of a HACCP Plan

Once the HACCP team has been identified, the team should use the basic principles of HACCP to design a plan.

The basic principles of HACCP are listed in Table 1 and are briefly described below.

Principle HACCP Steps

1 Conduct an analysis of the hazards in your plant. Make a list of all processing steps where a hazard might occur.

2 Identify all critical control points (CCP's) in the process. CCP's are critical to the safety of the product.

3 Establish a critical limit for each of the identified CCP's.

4 Establish CCP monitoring requirements.

5 Establish corrective action to be taken if the CCP deviates from the critical limit.

6 Establish effective record-keeping procedures to document the HACCP program.

7 Establish a procedure to verify that your HACCP program is working.

Principle 1: Hazard Analysis.

The first step in designing a HACCP plan is to conduct an analysis of hazards associated with each product. During

hazard analysis, the HACCP team evaluates all of the procedures concerned with production, distribution, and

the use of raw materials for potential problems that could occur. The HACCP team should list the type of problem

(biological, chemical or physical), and the appropriate preventive action necessary to keep the problem from

occurring. It may be useful to draw a flow diagram detailing production steps from receiving to the consumer and

to present the hazard analyses in a table format (an example is shown in Table 2). Figure 1 shows an example of a

typical flow diagram for dairy business; however, diagrams should be developed to fit the unique conditions that

exist in each plant. Once a flow diagram has been developed, it is important to check it to make sure that it is

correct, and that steps have not been omitted.

Table 1: Principles of HACCP

Principle 2: Identify CCP's

The next and most important step is to determine the critical control points (CCP's) in the process, or the points

at which a loss of control could result in a biological, chemical or physical health hazard. CCP's vary for different

products, particularly if your facility processes raw and finished product. In some cases, it may be difficult to

decide if a processing step is a CCP. As a result, many companies will establish too many CCP's. A CCP decision

tree, such as the one shown in Figure 2, can be used to identify CCP's. CCP's should be noted on the flow diagram

as part of the HACCP documentation. An example of a CCP for a fully cooked product is the cooking process

because proper cooking eliminates pathogenic bacteria; however, after cooking, care should be taken to keep

the product from being contaminated again. While proper cooking may be addressed in the plants standard

operating procedures (SOP's), it is also a CCP and should be listed as such. In raw products, pathogenic bacteria

may be reduced and their growth controlled using a well-designed HACCP plan, but elimination requires

additional measures.

Principle 3: Establish critical limits

Once the CCP's have been determined, a critical limit or the amount of acceptable deviation has to be established

for each CCP. Critical limits are set for product safety and not product quality. For example, the critical limit for

frozen raw poultry storage and shipping would require the product be held below 5 degrees C, which does not

constitute frozen but prevents bacterial growth. In a cooked product, an example of a critical limit would be that

an internal temperature of the product reaches at least 71 degrees C.

Principle 4: Monitoring critical limits

All CCP's must be monitored to insure that the process remains within critical limits. The HACCP team needs to

establish methods not only for monitoring each CCP, but also for determining the frequency of CCP evaluation.

Monitoring methods should be appropriate for on-line use and should provide a simple but rapid assessment. For

example, visual observations, aroma, and measurements of temperature, pH, moisture, fat, etc. are commonly

used to monitor poultry processing CCP's. Traditionally, microbiological testing has not been used to monitor

CCP's because procedures are time consuming; however, with the advent of new rapid methods, microbiological

testing could provide valuable information within minutes.

Principle 5: Corrective action

In addition to monitoring CCP's, procedures should be developed to describe what steps will be taken if the

process goes out of control. The corrective action plan must include:

1) Who is responsible for regaining control of the process?

2) How to regain control,

3) What to do with the product that was produced during the loss of control, and

4) How to handle a product recall.

Principle 6: Record keeping

Documentation of a formal HACCP plan for all products is required. Detailed records must be kept of data

recorded at CCP's. Effective record keeping includes:

• List of HACCP team members and their responsibilities

• All records should be dated. All products and their intended use should be identified

• HACCP flow diagrams with all CCP's

• List of all critical limits and preventive measures

• Monitoring and verification plans

• Course of action when a critical limit deviation occurs, and person(s) responsible for corrective actions

• Procedures for product handling when deviation from critical limit occurs

• Appropriate product packaging information and expected product shelf-life

• HACCP check off sheets for each shift which must be signed upon completion of a step

• HACCP plan reviews, date of reviews, and reviewer's initials

• Records of all deviations

Principle 7: HACCP Verification

Once established, each HACCP plan will change as the company adds new products, updates old products, installs

new equipment, or changes product-handling procedures. It is important to periodically verify that the HACCP

plan is working.

Verification procedures may include:

• Routine check of all HACCP plans and records.

• Routine check of monitoring procedures and equipment.

• Random microbiological sampling of all product contact surfaces, as well as a portion of the product.

• Official evaluation of product.

• Review of all critical limit deviations and product handling.

Conclusion

HACCP was designed to prevent hazardous products from leaving the manufacturing or processing facility.

However, the key to the success of HACCP is employee training, behaviour and attitude. Some companies are

under the misconception that they already have a HACCP plan because they are adequately controlling all areas

where safety could be compromised. The difference is that rather than monitoring isolated processing steps, a

HACCP approach controls the entire production process as an integrated system. Although HACCP provides

insurance that product is safe, there is no way to completely eliminate all hazards. HACCP is most effective when

used with other control systems. Total Quality Management programs or ISO 9000 and Standard Operating

Procedures should be used along with HACCP to improve product safety, product quality, and plant productivity

by providing intimate knowledge of the production process, production environment and processing equipment.

Figure 1: Flow Diagram

Table 2: CCP Chart

`

We produce different kind of flavoured milks. These are of different sizes from 1 litre size to 330 mil size. The

bottles came to Factory as in Pallets and covered in Plastic Bag. These are then taken inside the factory where

they are de-stacked and send to Production Line. On Production line they are then taken out from plastic bag

and put on the line. Then they go under the filler line to be filled and then caps goes on top. Labelled and then

goes in to boxes to get stacked on Pallet. From there they goes to Cold store from where they are despatched to

the Customers.

Introduction

A piece of Plastic bag (Swarf) was found inside the 1 litre bottle before going to be filled.

What went wrong?

Start of Production, when the bottles were on conveyor and before being filled with milk.

When it went wrong?

After De-canting the bottles Area and before going to the filler.

Where it went wrong?

Found by operator who was looking after the bottles and also keep a visual check for any non-conformance

with the bottles.

How and who found it?

Food Safety Management Procedures 3 A critical analysis of an incident when a food safety management procedure failed –

including recommendations of the corrective actions that could be taken and an

explanation how information could be communicated to staff to ensure food safety in

future

Assignment A:

QDA

The Quality defect Alert was raised. As it was a non-conformance and a possible food hazard with Physical

contamination it was necessary to understand the problem and find the right solution. The system was failed to

stop this kind of contamination inside the bottle and it could gone to customer.

INVESTIGATION

The investigation was done to understand and find the root cause of the problem. First of all we checked all the

following point:

The piece which was found to be in the bottle was identified. It was come from the bag inside which

bottles were packed and supplied to us. There is a safe policy and method of debagging the bottles from

the plastic bag so no swarf contaminates bottles.

To cut the bags we use Fish knives which are specifically made for industrial use and are very safe to

cut. Risk assessments have been carried out previously and it’s a safe practice to use them in

production. Before coming to production the bottles are sealed in plastic blue bags which mean no

physical contamination occurs. So how did it happen?

Staff: The person who was de-bagging the bottles was well trained and is a senior operator. He uses the fish

knife to cut the bag He did not notice anything as he was rushing the job and trying to cope with the line

speed. Everything was done according to policy and we couldn’t find any fault apart from that a swarf

might gone to a bottle after de-canting (de-bagging) of bottles.

HACCP REVIEW MEETING:

We had a HACCP review meeting with all the HACCP team which includes the Technical Manager, QA, Engineers

and staff from Production and Planning. With HACCP Review Meeting we reviewed the whole process again.

Corrective Actions and Recommendations

The problem arises before filling and after de-canting.

All staff on the line is trained on De-canting of bottles and physical contamination hazards.

It was the first case in years and we never had this kind of contamination happened before.

There is a need of a process which eliminates this risk before filling line.

Process Flow

Filling Bottle De-canted Primary Packaging

Risk Assessment

From risk assessments now it was evident that we do need more robust system in place to ensure the food

safety. As the line runs with 200 bottles per minute, it is impossible with a naked eye to control this risk.

#therefore there is a need of some automated process to eliminate this risk.

Few recommendations were put forward to make sure it won’t happen again:

1) Bottle Inverter : To make sure the bottles were emptied before filling

2) Staff Training : More staff training to make sure that staff understands the importance of controlling

hazards and are more vigilant

3) X-ray or Any other form of detector : To detect and foreign body inside the bottles

4) Vacuum sucked: Vacuum chamber where bottles were vacuumed making sure nothing inside the bottles.

5) Extra staff : To inspect each and every bottle

First and second option was more suitable and can be implemented in a short term. Rest of them are really costly

and long term solutions. We were sure that first 2 will almost eliminate the risk of hazard.

Recommendations

BOTTLE INVERTER:

After HACCP meeting it was decided that there is a need of Bottle Inverter to make sure that no bottle goes to

filler with physical contamination. This machine works as turning bottles upside down to make sure whatever is

inside the bottles drop down.

After De-Bagging all the bottles goes through conveyor to Bottle inverter where they turn upside down and then

after passing this inverter goes to filler machine.

Corrective and preventive measures

Bottle Inverter

Process Flow

Inverter Bottle De-canted Primary Packaging

Filling

Risk Assessment

1. All relevant personnel including temporary staff and contractors are appropriately trained prior to commencing

work and adequately supervised throughout the working period. This is in the form of an induction either carried

out by the agency or on site. All staff should have completed induction training prior to the end of their

probationary period. An induction checklist should be signed off as confirmation this has been carried out. All new

staff to the factory should sign off first day induction training to confirm they are aware of the points documented.

A copy should be kept by employee and held on file.

2. All personnel engaged in activities relating to critical control points should have relevant training and

documented evidence will be a record made on the persons training records covering off the CCP.

3. Personnel holds each person’s training records to provide evidence what training is required to carry out the

role and signed off documentation on the status of the training carried out. Internal audits and monitoring of

Quality Defect Alerts are used as a method of reviewing the implementation and effectiveness of training and

competency of trainer. All staff complete a 13 week probationary period which is monitored by departmental

heads and personnel department.

4. All training records should have:

a. Name of employee

b. A sign off following any attendance of any course

c. Date and if necessary duration of training

d. Title of course or time being trained

e. Training provider

f. A copy of the contents of the course should be held with training/personnel department

5. A yearly review of the competencies of staff is carried out and where necessary relevant training is carried out

as deemed necessary by the departmental head. The review will take into consideration any finding following

internal audits, quality defect alerts or changes that have arisen within the department. The review should be

documented by the departmental head and signed off on the training log. Relevant training can be either by

formal training, on the job experience or refresher training.

Food Safety refresher training should be carried out on average every 3 – 4 years.

Training

Objective to ensure that the hazards identified in the study are complete and correct and that the

selected controls for these Hazards are suitable.

o Packaging specifications and supplier approval

Specifications and migration certificates are on file to provide evidence that the product packaging is suitable for use. Production trails must have been completed and signed off for approval

o Migration certificates for packaging

All the certificates are held in Technical Department.

o Inverter operating parameters

Checks for start-up, Glass and Perspex Checks, Safety Stop Checks, Hygiene Swabs Test,

Verification

The following Verification procedures are undertaken:

Audits of the HACCP system

Internal: Carried out by the Quality Department, example to make sure all the Pre-

Requisites are followed properly

External: Review of Suppliers as part of Approved Supplier procedures

Finished product and interim product testing.

Investigate and trend:

Operator Checks; Pre-Start up checks, Nut and bolts checks, Hygiene Swabs

Customer complaints,

Monitoring Results

Corrective Actions

Process Deviations

Product Disposals

Validation

~)".:fj

~ Chartered ~'W Institute of \ Environmental Health

Level '-I Award in Food Safety Management for Manufacturing Candidate assessment record

Candidate's name (in full and block capitals):

w r<. AAtvt I<./-IM-JD ().A?;1

E>RI, I Centre number:

Final result

D Trainer's mark

D Moderator's mark

This result is only valid if

the marking grid and trainer Duration of cou~e{-start date and last date of course attendance): feedback report are all

5 :y. l-Y '2010 q 3UL-Y 2.010 complete.

Title of assignment:

MSSir4.N (III€N T 8 - Al..LE:f<.f;,eN GJN m-n~'NI'I710N I hereby certify that the submitted assignment is my own work, I have not received unauthorised assistance in completing this aSSignment and understand that it has been produced for assessment purposes only.

Candidate's signature: I1d~W­ Date:

., I ::.:-::-­ 3/ q /2-010 I hereby certify that to the best of my knowledge the submitted aSSignment is the candidate's own work and that he/she has not received unauthorised assistance in completing this assignment.

I Trainer's signature: Date:

Trainer's name (block capitals): Trainer no:

Assignment B - Allergen contamination

Your report must contain the following sections:

1 A description of how allergen contamination controls, including compliance with current legislation and codes of practice, contribute to food safety in your manufacturing business. 10 marks

2 An explanation of how you, as a manager in your manufacturing business, can establish, monitor and verify allergen contamination controls. 15 marks

3 A critical analysis of the corrective actions you could take in the event of a failure of an allergen

contamination control, with your recommendations of the most appropriate corrective actions, and an explanation of how you would communicate this information to staff to ensure food safety

in the future. 25 marks

Allergen Contamination 1. Description of how allergen contamination controls, including with

current legislation and codes of practice, contributes to food safety in

your manufacturing business.

There are both criminal and civil legal regimes relevant to the sale of foods containing allergens and the

provision of ‘allergen-free’ lists. It is essential that these are given careful consideration. The following is a

brief outline of the main provisions to assist manufacturers in identifying their legal obligations and the

appropriate courses of action in respect of Good Manufacturing Practice and the provision of information to,

or for communication to, consumers. Also with respect to those regulations I will point out how we abide

those regulations at our work place to make food safe and better.

This piece of legislation is sometimes unofficially referred to as ‘the European food Safety Act’ because it

establishes the principles of food law and identifies the legal obligation of food business and governments.

Allergen Controls

It covers all stages of the food chain from

primary production to the sale (‘placing on

the market’) o products and establishes the

rights of consumers to safe food and to

accurate and honest information about it

It includes:

Many of the definitions used in EU food law

The general principles of food law based on risk

management and precautionary principle

Safety requirements for food placed on the market

Procedures for dealing with food safety problems

The principle of traceability

Arrangements for the removal of unsafe food from

the market

Regulation (EC) No. 178/2002

Assignment B:

Article 6

Risk based approach required Risk assessments have been done

to all the departments and lines. All

hazards were taken into account

like Microbiological, Chemical,

Physical and Allergens. From in-

take of raw materials to the

delivery of finished goods.

Everything has been recorded for

traceability.

How we do it Risk

Food law must be based upon

risk analysis, consisting of risk

assessment, risk management

and risk communication. Risk

assessment must be based on

available scientific evidence

Article 14

Unsafe food defined as being

injurious to human health or unfit

for human consumption because

of contamination or spoilage

There is a HACCP system in place

which makes sure food is safe to

eat.

It is deemed to be unsafe if it is

considered to be:

a) Injurious to health

b) Unfit for human consumption

because of contamination or

spoilage.

If part of a batch is considered

unsafe, then the whole batch is

considered unsafe, unless it can be

demonstrated otherwise.

Food law must be based upon

risk analysis, consisting of risk

assessment, risk management

and risk communication. Risk

assessment must be based on

available scientific evidence

Food safety requirements How we do it

Article 16

Packaging etc. must not mislead

consumers

There is a HACCP system in place

which makes sure food is safe to

eat.

Making sure the correct labels with

ingredients are on package. Also

Use by or BBE dates are to ensure

that food is safe for consumption.

If there is al allergen, it should be

declared on the label.

The promotion, packaging,

labelling, display setting and so

on must not lead consumers

How we do it Misrepresentation

The Food Safety Act 1990 is an Act of Parliament of the Parliament of the United Kingdom. It regulates the statutory obligation to treat food intended for human consumption in a controlled and managed way.

The key requirements of the Act are that food must comply with food safety requirements, must be "of the nature, substance and quality demanded", and must be correctly described (labelled).

Food Safety Act 1990

Section 7

Offence to sell food for human

consumption if it is injurious to

health.

Every step of the process makes

sure that food is safe to consume.

Everything is declared on

ingredients information on

packaging so consumer can easily

see what product is constituted of.

It is an offence for a food business

to sell food for human

consumption if it has been made

injurious to health by:

Adding any article or

substance to a food that

renders it injurious to

health

Using any article or

substance as an

ingredient that renders it

injurious to health

Abstracting any

constituent from the food

that renders it injurious

to health

Subjecting the food to

any other process or

treatment that renders it

injurious to health.

How we do it Food Injurious to health

Section 14

Nature – food different to what

was requested.

Substance – not of the correct

composition or containing physical

contaminants.

Quality – the standard expected.

All products have got their Checks

before Production. Aroma, texture,

Nature, pH, Colour, Viscosity, Fat

levels%, Weights, Sizes etc. All

approved by customers and have a

check sheets to make sure all

products meet customer demand.

If there is any trace of Allergen or,

if a product got allergens in it ,

they are declared to make sure

consumer is aware of it before use.

All food sold must be ‘of the

nature or substance or quality

demanded by the purchaser’.

How we do it Consumer Protection

These Regulations, which came into force in January 2006, are:

The Food Hygiene (England) Regulations 2006

The Food Hygiene (Wales) Regulations 2006

The Food Hygiene (Scotland) Regulations 2006

The Food Hygiene (Northern Ireland) Regulations 2006 and subsequent amendments.

The regulation deals largely with the regulation and enforcement of food safety, plus temperature control,

and is the main British route to enforcing the main European Regulations.

Food hygiene Regulations 2006

Regulations 10 & 11

Defence of due diligence. Offence

committed by someone else. To demonstrate that every

possible reasonable step taken to

achieve safe food, we have written

records to support defence. All

documents based on HACCP

Principles like, records of Staff

Training, Temperature

measurements, cleaning

schedules, supplier specifications,

traceability system, remedial

action where food safety problems

have arisen and pest control

measures.

Two main defences under these

Regulations, either:

That the offence was the

fault of another person

due diligence

How we do it Defence and offences

The fundamental aim of any hygiene regulation is to create conditions in a food business that will lead to the safe

working production of food. Generally Speaking, this regulation takes a two-prolonged approach.

The management and control of the structure of food premises and the equipment used

The management and control over what happens in food premises

The Regulation seeks to ensure a high level of food hygiene at all stages of the production process (production,

processing and distribution of food). A key point of the legislation is that the main responsibility for food safety

rests with “food business operators”, with a single hygiene policy applicable to all foodstuffs and all operators.

The text defines the obligations of food operators, setting out general and specific hygiene rules and requiring

the establishment, implementation and maintenance of procedures based on HACCP principles.

The regulation foresees that food businesses may use guides to good practices as an aid to comply with their

obligations. Such guides to good practices for hygiene and for the application of HACCP principles can be

developed by each sector at national or Community level.

To facilitate the implementation and interpretation of the Regulation, the European Commission issued the

following guidance documents:

Guidance document on the implementation of certain provisions of Regulation 852/2004/EC on the

hygiene of foodstuffs;

Guidance document on the implementation of procedures based on the HACCP principles, and on the

facilitation

Regulation (EC) No. 852/2004 on the hygiene of foodstuffs

Article 5

Procedures must exist based upon

HACCP principles

1: Conduct a hazard analysis.

2: Identify critical control points.

3: Establish critical limits for each critical control point.

4: Establish critical control point monitoring requirements.

5: Establish corrective actions.

6: Establish record keeping procedures.

7: Establish procedures for verifying the HACCP system is working as intended

Food business operators must put

in place, implement and maintain

permanent procedures based on

the principles of Hazard Analysis

of Critical Control Points.

How we do it HACCP

Allergen Contamination

2. An explanation of how you, as a manager in your manufacturing

business, can establish, monitor and verify allergen contamination

controls.

Assignment B:

In order to avoid the unintentional presence of allergenic foods in products it is necessary to evaluate the

likelihood of unintentional allergen cross-contamination across the supply chain, from raw materials through to

the finished product. Following completion of such a risk analysis, manufacturers can then determine whether

or not allergen advisory labelling is appropriate on the finished product as sold to consumers.

Risk analysis is made up of four stages:

1. Risk assessment– what is the risk?

2. Risk management – can the risk be managed?

3. Risk communication – how should the risk be communicated?

4. Risk review – has the risk changed?

Figure 1 set out as a flow chart, the steps involved in this risk analysis.

Figure 4 shows the steps in the decision tree for managing allergens.

Allergen Risk Assessment,Management and Communication

S t e p 1 – A s s e s s r i s k f r o m i n t e n t i o n a l p r e s e n c e

Is the food manufactured from any of the allergenic foods specified in the current UK legislations or their derivatives?

YES NO

(Label as necessary, go to step 7) Go to Step 2

S t e p 2 – A s s e s s r i s k f r o m u n i n t e n t i o n a l p r e s e n c e

What is the likelihood, under normal operating conditions, of cross-contamination of the food by specified allergens?

PROBABLE REMOTE

(Go to step 2a) (No action – Go to step 7)

S t e p 2 a – C h e c k a g a i n s t i n g r e d i e n t l a b e l l i n g

Is the potential cross-contaminating allergen already declared on the label as an ingredient?

YES NO

(No action – Go to step 7) (Go to step 3)

S t e p 3 – C h e c k a g a i n s t e x e m p t i o n s l i s t

Is the potential cross-contaminating material exempt from mandatory labelling?

YES NO

(No action – Go to step 7) (Go to step 4)

S t e p 4 – H a z a r d c h a r a c t e r i s a t i o n

Identify the physical form and the characteristics of the potential cross-contaminating allergenic material

YES NO

( Go to step 7) (Go to step 6)

S t e p 5 – R i s k m a n a g e m e n t o f u n i n t e n t i o n a l p r e s e n c e

Can the identified risk of cross-contamination be managed?

S t e p 6

S t e p 7 – C h e c k o t h e r r e l e v a n t a l l e r g e n s

Risk Communication – Include warning on label (Go to Step 7)

YES NO

( No Action) (Go to step 1)

Have all relevant allergens been considered?

Figure 1: Allergen advisory labelling decision tree

Processing

Aid Raw

Material

Handling

Storage Transport

Air Particles in

Supply Chain

Area

Packaging

Supply Chain

Cross-

Contamination

Shared

Equipment

People

Cleaning

Re-work Other?

The second step in the risk assessment process will identify the probability of unintentional presence of

allergens, by thinking about how cross-contamination could happen and how likely it is to happen (see figure 2).

The outcome of the initial risk assessment will be either:

Probable: A likely chance of risks occurring.

Remote: Risks are unlikely to arise but are still possible. Low probability risks should not be ignored and

should be managed and eliminated where appropriate.

Figure 2: Potential Sources of Cross-Contamination

Allergen Risk Management

Where a risk has been identified (as either probable or remote), attempts has been made to reduce the

unintentional presence of allergens in the product as far as possible.

Whether manufacturing individual ingredients or complex food products, consistency in risk assessment and

application of risk management measures is always done.

The ‘visually and physically clean’ standard can in principle be applied to each stage in the supply chain.

Allergens should be managed to avoid their unintentional presence in products wherever possible. This

management involves evaluation of the likelihood of allergen cross-contamination associated with every step of

the food production process, from sourcing raw materials through to marketing of a finished product.

Our business already has Good Manufacturing Practice (GMP) in place. These require a commitment and

discipline to ensure products meet food safety, quality and legal requirements, using appropriate

manufacturing operations, including effective food safety systems (using hazard analysis principles) and quality

assurance systems. Existing GMP controls will assist with allergen management, for example avoiding cross-

contamination by segregation, cleaning, using separate utensils etc. However, it should be noted that unlike

microbiological risks, heating does not necessarily destroy food allergens and may actually increase their

potency, for example roasting peanuts.

The introduction of allergen management into a food business can be seen as an extension of existing food

safety management rather than a completely new system.

General Pronciples

The key aspects of our businesses to be considered in the management of allergens are illustrated in figure 3,

which are then discussed in more detail in the following sections.

Manufacturing

Figure 3: Key areas for consideration

All staff (including temporary staff and contractors) involved in handling ingredients, equipment, utensils,

packaging and products are all aware of food allergens and the consequences of their ingestion by sensitive

individuals. They are trained in avoiding cross-contamination of foods by the major food allergens. Appropriate

procedures on the management of allergens have also be available and/or posted wherever they need to be

observed in pursuit of the company’s management policy. Additionally, it is important to ensure awareness of

these procedures on the part of both workers and visitors by posting in the reception and production areas at

least a summary of the critical aspects. Training and awareness procedures include:

• Recognising which ingredients are the allergens of concern and why.

• Identifying potential allergen cross-contamination situations.

• Hand washing.

• Clothing requirements including laundering.

• Re-work procedures.

• Waste management procedures.

• Cleaning procedures.

• Dedicated equipment if available.

• People movement around the site, for example, people changing production line or site, trips to the canteen

and visitors.

• Equipment movement around the site, for example, maintenance tools, food trays, etc.

People

There is an appropriate and proportionate policy for assessing the allergen status of ingredients for use within

our own manufacturing processes and premises, and if appropriate, by their suppliers or co-packers. Any

change in supplier must be accompanied by the appropriate checks.

We are all aware of the presence of the major allergens in all raw materials, particularly the potential for

allergen cross contamination from manufacturing and handling activities on the raw material suppliers’ sites, as

well as earlier in the food chain during harvesting and transport. This is done through audits or from asking

suppliers to provide the required information. We ensure that materials are ordered against a clear

specification and that we ask appropriate questions of our suppliers.

Ingredients are fully described in specifications.

Steps have been taken to ensure that non-allergenic ingredients do not come into contact with allergens in

subsequent handling and storage. Allergenic raw materials should be stored in clearly identified areas where

possible, for example, using colour-coded boxes or demarcation of storage areas using painted lines on the

floor.

Raw Materials and Supply Chain

Where allergenic raw materials are de-bagged or de-boxed, they are placed in dedicated lidded and labelled

containers and made easily identifiable. Such containers are only used for storage of other raw materials after

appropriate cleaning.

If allergenic ingredients are sieved, then the sieving unit is either:

(i) Dedicated or

(ii) Thoroughly cleaned after sieving allergenic ingredients.

In summary, practices ensures that the allergen status of all ingredients (including flavourings, additives,

carriers and processing aids), as well as other materials that might come into contact with the food such as

baking release agents, are known:

Check the allergen status of all ingredients with suppliers and review regularly.

Ask suppliers to notify changes in the allergen status of the materials they supply.

Clearly identify allergenic raw materials and segregate where possible.

Ensure the handling of allergenic ingredients does not cause contamination of other ingredients.

Check implications of any change of ingredient supplier.

Manufacturing Premises, Equipment and Processes

Whilst the ideal approach to avoiding cross-contamination with allergens is to dedicate production facilities to

specific allergenic products, it is recognised that food manufacturing premises and product ranges vary greatly

and that this is not always an option particularly in small and micro businesses. Where dedicated production

facilities are not possible, there are a number of ways of separating the production of allergen containing

products from those that do not contain the allergen. These can include separation:

• In different parts of the production area.

• By using physical barriers between the production lines.

• By use of dedicated equipment.

• By minimising unnecessary movement of materials.

• By appropriate scheduling of production runs, including appropriate cleaning of equipment between

production runs.

• By managing re-work, ensuring that residual material containing an allergen is not re-worked into a product

not containing the allergen.

• By separating the air supply, where this is practical.

Shared Equipment

Consideration has been given to the dedication of equipment within production facilities.

For example, weighing equipment, scoops and utensils are dedicated and the weighed product placed in

dedicated, lidded and labelled containers.

Consideration also been given to colour coding equipment.

Physical Separation

Physical separation has been considered for ‘high risk’ ingredients and the implications of changes to the layout

of the food production area have been assessed. Consideration has also been given to the ease of cleaning of

equipment. Avoiding the crossover of production lines and allowing adequate space for effective cleaning has

helped minimise the risk of allergen cross-contamination.

Storage

Consideration has been given to the temporary labelling of work in progress. This is, for instance, a half-finished

product that is held-over. Care should be taken that the product is not mistaken for another product with a

different set of allergens. Similarly, care should be taken to label and store packaging materials that are unused

at the end of a production run. Co-products are misshapes and broken products, which for quality reasons are

not acceptable as finished product but could still be consumed by employees or sold through factory shops.

Such products should be subject to the normal allergen labelling controls.

Re-work

Re-work that contains allergenic ingredients should be re-worked only into products that contain that allergen,

for example chocolate that contains nuts or nut fillings should only be re-worked into other nut containing

chocolates. Re-work should be clearly identified in order that it may be tracked in the manufacturing process.

Oils used for cooking allergenic foods (for example, shellfish, fish and breaded or battered products) should not

be used subsequently for cooking products not containing that allergen.

In summary

Is it possible to have dedicated production lines or areas?

Is it possible to erect physical barriers between production lines or areas?

Is it possible to dedicate utensils and equipment?

Is it possible to clean between production runs?

Is it possible to schedule production runs to minimise possible cross-contamination?

Is re-work managed?

Is it possible to manage airflow?

Are held-over products suitably labelled?

Is there a procedure for removing packaging and labelling it before returning it to the stores?

Very small amounts of some allergens, such as nuts, can cause adverse reactions, including potentially fatal

anaphylactic shock. Therefore, thorough cleaning that is effective in reducing the risks of allergen cross

contamination should be used where appropriate. A ‘visually and physically clean’ standard is not just a casual

visual inspection of the production line or area, it also requires that all of the trouble spots are sought out and

inspected. Cleaning practices that are satisfactory for hygiene purposes may not be adequate for removing

some allergens and their validity for such a purpose should be assessed, for example, via residue/environmental

swab testing. Equipment may need to be dismantled and manually cleaned to ensure hard to clean areas are

free from allergen residues. Particular food materials (for example, powders, seeds, pastes and particulates)

present significant cleaning problems and any relevant industry guidance, where this has been developed,

should be followed. Adequate procedures should be in place for cleaning both production and packaging

machinery. Where adequate cleaning is not possible, then the risk of allergen cross-contamination should be

assessed and advisory labelling used, if appropriate.

Care is needed in cleaning to ensure that the cleaning of one line does not contaminate another (for example,

by use of compressed air cleaning), or an area which has already been cleaned (for example, clean dry mix areas

from the top down).

Any spillage that occurs during production, storage and transportation should be cleaned up immediately to

ensure that there is no subsequent allergen cross-contamination. Where known allergen contamination has

occurred, the contaminated material should be labelled and physically moved away from the non-contaminated

ingredients and work-in-progress.

Consideration should be given to maintenance activities, such as the use of dedicated tools or adequate

cleaning procedures where tools are not dedicated.

Where adherence to a cleaning regime is part of a separation system, it should be validated as ‘fit for purpose’

and compliance should be monitored.

Investment in developing and following appropriate cleaning regimes will help to minimise food allergen cross-

contamination and can reduce the likelihood of needing costly product recalls. Ensure that cleaning equipment

itself is cleaned after use to minimise the risk that it may carry and transfer allergen traces.

Establish appropriate cleaning regime including laundering of protective clothing.

Validate cleaning regimes.

Monitor that cleaning is being done properly.

Keep records of cleaning.

Cleaning

Incorrect packaging and/or labelling is a major cause of allergen related product recalls. Procedures for checking

that the correct labels are applied to products should be implemented and audited regularly, so that accurate

information is provided to allergic consumers. Checks should be in place between processing and packing to

ensure the correct packaging is used, for example the use of automated label verification systems.

It is important that, following recipe changes or the introduction of a new allergen cross-contamination risk etc,

the old packaging is not only withdrawn from use but is physically destroyed, so that it cannot be used in error.

There are systems to ensure packaging is removed at the end of a run, including any packaging that may be

within the wrapping machine. This will help to avoid packaging mix-ups when the product to be packed is

changed and, therefore, reduce the number of instances in which misleading information is passed to the

consumer.

It is important to ensure that the correct outer packaging is used for multi-pack products and that allergen

information appears on, or is visible through, both the inner and outer wrappers.

Packaging

Product Formulation

Whenever possible, it is good practice not to include an allergenic ingredient in a product unless necessary. For

example, manufacturers could consider using corn (maize) flour instead of wheat flour or using vegetable oil,

for example sunflower oil, instead of butter. By using allergenic ingredients only when they are essential

components of a food product, one element of the risk from unintentional allergenic cross contamination will

be minimised.

Reformulating Products

Reformulation of a product with the introduction of a new allergenic ingredient may lead to accidental

contamination of other lines produced in the same premises, for which advisory labelling might then become

appropriate. Businesses can benefit from simplification programmes and these might provide opportunities to

discontinue minor lines that bring allergen complexity in manufacturing, as well as reformulating products to

avoid allergenic ingredients.

Extending Brands

If it is decided to extend a brand name into a different product sector (for example, an established

confectionery product giving its name to a dessert product or ice cream), care should be taken that the

presence of any allergen not associated with the original product is clearly indicated. The approach to allergen

labelling across a brand should be as consistent as possible.

New Product Development and Reformulation

Factory Trials and Consumer Testing

If conducting factory trials of allergen-containing products, measures should be taken to avoid allergen cross-

contamination with existing products. Information on the presence, or potential presence, of allergens should

be made available to those involved in factory trials and in taste testing and that information should be clearly

conveyed with products presented for wider test and marketing purposes.

However clearly they are labelled, care should be taken if sample products containing the major food allergens

are distributed or offered where they can be taken by unsupervised children (for example through letterboxes,

in stores or other public places).

Managing Changes

Any changes to one production process within the food production area or the introduction of a new product

line can affect the risks of allergen cross-contamination of other products. Moving production of a product to

another site may also result in a different allergenic risk that needs to be relayed to the consumer. Following

any such changes, it will be necessary to conduct a new assessment of the risks of allergen cross contamination

of a product, including an evaluation of any advisory labelling that might be necessary.

Consumers may unknowingly consume allergen-containing products where changes have been made to the

recipe of a familiar product and allergenic ingredients have been introduced. Any changes to the allergen status

of a product (for example, recipe changes) need to be made obvious to the consumer, for example, by using

prominent labelling flashes, preferably on the front of the pack, in addition to the amended ingredients list.

Suitable warnings might be, for example, ‘New Recipe’ and ‘Now Contains’. It may also be possible to use other

methods such as websites to inform consumers of recipe changes. This is important, as allergic consumers, who

may have been consuming the product for some time, need to be informed of a new potential hazard. In

addition, food manufacturers and retailers are strongly advised to provide updated information to consumer

support organisations such as the Anaphylaxis Campaign and Coeliac UK as they have systems in place for

informing their members about changes.

Allergen Management Systems should be monitored and reviewed to provide assurance that they are working

correctly. The most effective way of doing this is by carrying out routine checks on manufacturing operations

including an audit or ‘health check’ of the system. An overall ‘health check’ can find any weaknesses in the

system and then corrective actions can be taken. A key benefit of auditing the system is to provide evidence of

due diligence in managing allergens.

The ‘health check’ should as a minimum encompass compliance with GMP requirements, including:

Review and verification of the hazard analysis and hazard management system.

Product and ingredient specifications.

Operating procedures.

Cleaning procedures.

Training records – demonstration of competence.

Analysis of customer complaints.

Internal Audits and External Audits to make sure everything is verified and in place

Customer complaints should be investigated and changes made where necessary.

The frequency of review will depend on the risk level of the operation. An annual review is likely to be

reasonable in most circumstances. However, any of the following may trigger the need to conduct a review:

Introduction of new ingredients, new recipes or new processes,

Changes in scheduling, equipment, site, source of raw material, product storage, handling or

manufacture,

EFSA will be reviewing the list of allergens for mandatory ingredients listing, so new allergens may

emerge that will need to be managed, or

Any other changes which introduce significant risks.

For example, any changes to one process within a food production area, or introduction of a new product, can

affect the risks of allergen cross contamination of other products manufactured at the same site. Moving

production of a product to another site may also result in a different allergenic risk, which needs to be relayed

to the consumer.

Following any such changes, it will be necessary to conduct a new assessment of the risks of allergen cross-

contamination of a product, including an evaluation of any advisory labelling that might be necessary.

Allergen Risk Review

Allergen Contamination 3 A critical analysis of the corrective actions you could take in the event of a

failure of an allergen contamination control, with your recommendations of

the most appropriate corrective actions, and an explanation of how you

would communicate this information to staff to ensure food safety in the

future.

Assignment B:

In our company we produce two kinds of Custards. One is normal custard without Allergens and one with

Allergens with eggs in it. To make sure we do have control we have policies defined in our HACCP Plan how to

make sure that cross contamination does not occur.

As we have same line running both products, there is a Cleaning Procedure between Non Allergen Products and

Allergen Products. The line is clean with Caustic and then later disinfects it. This is to make sure there are no

remains of Allergens left on the line and it is safe to run non Allergen Product. There is a physical clean and also

visual check to make sure that cleaning happens.

Introduction

After running an Allergen Product, the line was not cleaned and we packed non Allergen Product afterwards.

What went wrong?

In the early morning when we had a plan to run a new fresh non Allergen Product. It was a normal day with no

Issues or break downs on the line.

When it went wrong?

On the Custard line where we produce fresh custards (free from allergens) and Luxury Custard (with Allergens).

Where it went wrong?

While going through traceability paperwork, QA found out that the line was not cleaned after running last

Allergen Product. As normal routine of doing traceability, QA found out at the end of run that the product might

be contaminated with Allergens as the line was not cleaned.

How and who found it?

PRODUCT ON HOLD

The entire product which was made last hour was put on hold. Line was put on clean and the samples were

taken to send external Laboratory

INVESTIGATION

When the Allergen Product ran last time, as it was the last run of production the line was not cleaned

thoroughly instantaneously. It was cleaned by Operator with normal cleaning but as with Allergen it should have

cleaned with Caustic called as CIP. As the day gone by, the operator on the cleaning department forgot to clean

the line as he was busy cleaning other lines. The next day Operator checks visually and found nothing dirty on

top and started the run. There was no check for operator to make sure that line was really cleaned and free of

Allergens.

There was a need of HACCP Review as the system failed and it did not guarantee our Food Safety system.

HACCP REVIEW MEETING:

We had a HACCP review meeting with all the HACCP team which includes the Technical Manager, QA, Engineers

and staff from Production and Planning.

RECOMMENDATIONS:

Allergens runs should be run at the end of Production.

The cleaning Procedure was fine, but there was no check for operator to make sure the line is clean,

safe and ready to start production.

To make it Robust and fool proof we need Operator to check it.

Protein Swab Checks need to be implemented which can detect trace of Allergens

This needs training of staff and communication to all Levels.

The lab result came back with some traces of Allergens and we have to destroy the entire product.

Corrective Actions and Recommendations

Hazards (Cross contamination to final packed product) Control Document reference

Sev

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risk

Spillage during transfer/ storage Spillage kit GEN-033 Sugared egg yolk spillage 3 1 3

Wrongly labelled, used in wrong product Agreed packaging format with supplier and to be clearly identified as egg.

R-004 Handling of sugared egg yolk and custard containing egg 3 1 3

Transfer/ Storage to processing dept Spillage during transfer/ storage Spillage kit GEN-033 Sugared egg yolk spillage 3 1 3

Cross contamination with non egg custard through mix loop, via valve leaking.

Egg custard to always be mixed and processed last followed by a full CIP. Egg

pallecon to be only connected up to mix loop post all non egg custard mixing.

R-004 Handling of sugared egg yolk and custard containing egg 3 2 6

Cross contamination in mix loop by mixing non egg after a egg custard

Egg custard to be clearly identified and non egg custard to always be processed post full

CIP of mix loop

R-004 Handling of sugared egg yolk and custard containing egg/ Mixing matrix 3 2 6

Cross contamination with non egg custard through mix loop, via incidental leakage from

flexi/ purges

Egg custard to always be mixed and processed last followed by a full CIP. Egg to be only connected up to mix loop post all non

egg custard mixing.

R-004 Handling of sugared egg yolk and custard containing egg 3 1 3

No further production to go ahead until minimum requirements of mix loop CIP are

met

R-004 Handling of sugared egg yolk and custard containing egg

CIP effectiveness in eradicating egg allergen verified minimum annually or after any changes

to plant or process

Ref CIP verification results kept on file held in Technical

Leakage/ spillage of product Spillage kit/ red designated trays for open end of flexi to be stored over.

GEN-033 Sugared egg yolk spillage/ R-004 Handling of sugared egg yolk and custard

containing egg3 1 3

Cross contamination via cleaning equipment Designated red cleaning equipment R-004 Handling of sugared egg yolk and custard containing egg 3 1 3

Cross contamination via operator overalls Red over sleeves and apron to be worn when mixing egg mixes

R-004 Handling of sugared egg yolk and custard containing egg 3 1 3

Cross contamination via cleaning equipment Designated re cleaning equipment R-004 Handling of sugared egg yolk and custard containing egg 3 1 3

Direct purge of product to floor where line primes itself

Egg custard to be processed last and all purges to be completely cleaned up using

designated red cleaning equipment

R-004 Handling of sugared egg yolk and custard containing egg 3 1 3

Direct purge of product to floor where line purges last 250L of skim to mix tank

Procedure for deep cleaning mix room post egg mixes

R-004 Handling of sugared egg yolk and custard containing egg 3 1 3

Cross contamination via cleaning equipment Designated red cleaning equipment R-004 Handling of sugared egg yolk and custard containing egg 3 1 3

No further production to go ahead until minimum requirements of mix loop CIP are

met

R-004 Handling of sugared egg yolk and custard containing egg

CIP effectiveness in eradicating egg allergen verified minimum annually or after any changes

to plant or process

Ref CIP verification results kept on file held in Technical

Cross contamination in mix loop by mixing non egg after a egg custard

Egg custard to be clearly identified and non egg custard to always be processed post full

CIP of mix tank

R-004 Handling of sugared egg yolk and custard containing egg/ Mixing matrix 3 2 6

No further production to go ahead until minimum requirements of mix loop CIP are

met

R-004 Handling of sugared egg yolk and custard containing egg

CIP effectiveness in eradicating egg allergen verified minimum annually or after any changes

to plant or process

Ref CIP verification results kept on file held in Technical

Cross contamination in plate pack by processing non egg after a egg custard

Egg custard to be clearly identified and non egg custard to always be processed post full

CIP of plate pack

R-004 Handling of sugared egg yolk and custard containing egg/ Processing matrix 3 2 6

Purge of egg custard at start up or after a divert to drain

Egg custard to be processed last and all purges to be completely cleaned up using

designated red cleaning equipment

R-004 Handling of sugared egg yolk and custard containing egg 3 1 3

No further production to go ahead until minimum requirements of mix loop CIP are

met

R-004 Handling of sugared egg yolk and custard containing egg

CIP effectiveness in eradicating egg allergen verified minimum annually or after any changes

to plant or process

Ref CIP verification results kept on file held in Technical

Overflow purge Egg custard to be processed last and all

purges to be completely cleaned up using designated red cleaning equipment

R-004 Handling of sugared egg yolk and custard containing egg 3 1 3

No further production to go ahead until minimum requirements of mix loop CIP are

met

R-004 Handling of sugared egg yolk and custard containing egg

CIP effectiveness in eradicating egg allergen verified minimum annually or after any changes

to plant or process

Ref CIP verification results kept on file held in Technical

Cross contamination by filling non egg custard after an egg custard

Egg custard to be clearly identified and non egg custard to always be filled post full CIP

and sterilise of fillef

R-004 Handling of sugared egg yolk and custard containing egg/ filling matrix 3 2 6

JVC-011 Cleaning of custard Gasti

Verification by co-ordinator manuall cleaning via protein swabs

Cross contamination via cleaning equipment Designated red cleaning equipment R-004 Handling of sugared egg yolk and custard containing egg 3 1 3

Cross contamination via operator overalls Red over sleeves and apron to be worn when filling custard egg custard

R-004 Handling of sugared egg yolk and custard containing egg 3 1 3

Cross contamination via cleaning equipment Designated red cleaning equipment R-004 Handling of sugared egg yolk and custard containing egg 3 1 3

Cross contamination via operator overalls Red over sleeves and apron to be worn when filling custard egg custard

R-004 Handling of sugared egg yolk and custard containing egg 3 1 3

Cross contamination via cleaning equipment when cleaning up egg custard spillage Designated red cleaning equipment R-004 Handling of sugared egg yolk and

custard containing egg 3 0 0

Cross contamination via operator overalls Red over sleeves and apron to be worn when filling custard egg custard

R-004 Handling of sugared egg yolk and custard containing egg 3 0 0

Transferred to cold store/ stored prior to being picked and despatched (all product is sealed at

this point)

Risk assessment for cross contamination of non egg containing products with sugared egg yolk ingredient and custard containing egg

1 - 3 = Low risk 4-6= Medium risk 7-9= High risk

Date prepared: 04/11/08 Revision: 2 Prepared by: S. Hudd

Cross contamination of non egg custard through failure of manual cleaning of filler

Cross contamination non egg custard through failure of CIP

Failure of a CIP post egg custard, pre non egg custard.

3

(Any step scoring 7 or above is considered a significant risk and control measure or step needs to be revised accordingly to reduce risk to an acceptable level)

Packing - Product is shrink wrapped, outer case bar code applied and palletised (All

product is sealed at this point)

2

Holding tank (Tanks are CIPed after each batch)

Procedure in place for manual cleaning

3 2

2

2

6

Mix tank

3 2 6

6

Failure of a CIP post egg custard, pre non egg custard.

Failure of a CIP post egg custard, pre non egg custard. 3

3

63

62

6

Prime the egg dosing line and purge egg to floor

Failure of a CIP post egg custard, pre non egg custard.

Step

Connecting up to egg dosing station on mix loop/ mix tank

Filling - Product is filled into pots, heat sealed, coded then placed into a collation tray

Pasteurisation/ homogenisation/ cooling

Receipt of incoming egg to cold store, put into storage

End of mix purges to floor

RA Egg allergen Page 1 of 1

Introduction of Protein Swab

To make sure we don’t produce any more contaminated product, there was a check included in start-up checks

for an operator to check before Start. To verify that manual cleaning of the filler has been sufficient in removing

traces of egg protein the filler must be swabbed with protein swabs and pass, post CIP prior to being disinfected.

THIS IS A CCP.

Work Instruction

Work Instruction was created to make sure that it is communicated to all the staff properly and they are properly

trained on it.

Preventive Actions

EXAMPLE OF PROTEIN SWAB WORK INSTRUCTION

To verify that manual cleaning of the filler has been sufficient in removing traces of egg protein the filler must be

swabbed with protein swabs and pass, post CIP prior to being disinfected. THIS IS A CCP.

(NB: It is critical swabs are done post CIP and prior to chemical disinfection as the chemicals used in disinfection

step interfere with the swab reagents).

1. Take a sample by swabbing a 10cm square area. For uneven surfaces try to swab the equivalent size surface area.

2. Put swab back into tube.

3. Activate by bending bulb until ‘snap valve’ breaks. Squeeze bulb twice to expel liquid reagent down swab shaft.

4. Gently shake swab in an upright position (Swab tip facing down) for 5 seconds.

5. Compare colour of reagent against the Pro-clean colour swab label.

Interpreting results – (NB: Colour chart is also shown on side of swab stick for easy reference)

6. PASS - Go ahead and put filler on for a chemical disinfection. (The swab must be retained and checked after 10

minutes in order for the swab to have time to pick up any faint traces of protein. If this is the case then the machine

must go back through a manual clean)

FAIL – Where a swab has failed, manually re-clean filler and then re-swab. If the re-swab passes you can then

continue with putting filler on for a chemical disinfection.

7. It is critical that all swabs results and any re-swabs are recorded on log sheet (RL-016 or RL-017) along with any

action taken i.e. re-cleans etc.

START UP CHECK:

There is a check included in Operator Start-up check sheet. This sheet is confirmed and sign by Team Leader or

Manager.

Protein Swab was included in the checks to make sure that there is no trace of any Allergens left on the line.

Process Flow

Holding Tank Filler Pots

Start-up Checks:

1) Hygiene Swabs

2) Nut & Bolts

Checks

3) Visual Cleaning

Checks

4) Protein Swab

There was staff brief at that time which made sure that all the staff now aware of new process and systems.

Why we introduce the Protein Swabs and what is the Importance of the Protein Swabs.

1. All relevant personnel including temporary staff and contractors are appropriately trained prior to

commencing work and adequately supervised throughout the working period. This is in the form of an

induction either carried out by the agency or on site. All staff should have completed induction training

prior to the end of their probationary period. An induction checklist should be signed off as

confirmation this has been carried out. All new staff to the factory should sign off first day induction

training to confirm they are aware of the points documented. A copy should be kept by employee and

held on file.

2. All personnel engaged in activities relating to critical control points should have relevant training and

documented evidence will be a record made on the persons training records covering off the CCP.

3. Personnel holds each person’s training records to provide evidence what training is required to carry

out the role and signed off documentation on the status of the training carried out. Internal audits and

monitoring of Quality Defect Alerts are used as a method of reviewing the implementation and

effectiveness of training and competency of trainer. All staff complete a 13 week probationary period

which is monitored by departmental heads and personnel department.

4. All training records should have:

a. Name of employee

b. A sign off following any attendance of any course

c. Date and if necessary duration of training

d. Title of course or time being trained

e. Training provider

f. A copy of the contents of the course should be held with training/personnel department

5. A yearly review of the competencies of staff is carried out and where necessary relevant training is carried

out as deemed necessary by the departmental head. The review will take into consideration any finding

following internal audits, quality defect alerts or changes that have arisen within the department. The

review should be documented by the departmental head and signed off on the training log. Relevant

training can be either by formal training, on the job experience or refresher training.

Food Safety refresher training should be carried out on average every 3 – 4 years.

Training

Objective to ensure that the hazards identified in the study are complete and correct and that the

selected controls for these Hazards are suitable.

o Packaging specifications and supplier approval

Specifications and migration certificates are on file to provide evidence that the product packaging is suitable for use. Production trails must have been completed and signed off for approval

o Migration certificates for packaging

All the certificates are held in Technical Department.

o Laminar operating parameters

Checks for start-up, Glass and Perspex Checks, Safety Stop Checks, Hygiene Swabs Test and

PROTEIN SWABS

Verification

The following Verification procedures are undertaken:

Audits of the HACCP system

Internal: Carried out by the Quality Department, example to make sure all the Pre-

Requisites are followed properly

External: Review of Suppliers as part of Approved Supplier procedures

Finished product and interim product testing.

Investigate and trend:

Operator Checks; Pre-Start up checks, Nut and bolts checks, Hygiene Swabs

Customer complaints,

Monitoring Results

Corrective Actions

Process Deviations

Product Disposals

Validation

As I am a Production Manager who is looking after the Production all the time, it was so

beneficial for me to understand all the food safety rules and regulations in more detail. Now

I am confident that I would be able to work towards safer food more confidently. Also I

would be able to

• Guide and advice on the management of food safety in a manufacturing business • contribute to the management of food safety in a manufacturing business • identify further technical knowledge necessary in food safety management procedures • determine further training requirements • identify areas for legal compliance • determine good practice • design an improvement plan • outline a HACCP-type plan • promote and encourage good standards of food safety • liaise with enforcement officers • deliver level 1 and 2 food safety training (with appropriate training skills).

Some useful sites and publications I referred to:

British Retail Consortium www.brc.org.uk Coeliac UK www.coeliac.org.uk Food and Drink Federation www.fdf.org.uk Food Standards Agency www.food.gov.uk Institute of Food Science and Technology www.ifst.org LACoRS www.lacors.gov.uk

http://www.cip.ukcentre.com/food1x.htm

http://books.google.co.uk/books?id=GLu142ovTu4C&lpg=PR20&ots=qDgASt49

Xk&dq=how%20to%20establish%2C%20monitor%20and%20verify%20the%20f

ood%20safety%20management%20system&pg=PP1#v=onepage&q&f=true