AWARENESS TRAINING PROGRAMME Technical Standard and Protocol for Companies Supplying Retailer Branded Food Products

1
AWARENESS TRAINING PROGRAMMETechnical Standard
and Protocol for Companies Supplying Retailer
Branded Food Products

• presented by
• David Burns

2
Who Were Involved ?

• Inspection
• Bodies
• EFSIS
• TLC
• Law Labs
• RSSL
• National Britannia

• Trade
• Associations
• FDF
• BACFID
• Accreditation
• Body
• UKAS

• Retailers
• Safeway
• Tesco
• Asda
• Sainsbury
• Iceland
• Somerfield
• CWS
• Boots
• Waitrose

3
Consistency of Inspection
HIGHER LEVEL Additional Beneficial Practices
BEST PRACTICE RECOMMENDATIONS
UKAS EN 45004 NEW EN 45011
4
Benefits of the Standard

• Accepted Standard based on best practice
• Inspection bodies accredited to EN45004 to
  achieve maximum consistency in application and
  interpretation (this is changing to EN 45011,
  refer to Protocol section)
• Open and transparent
• Encourages continuous improvement
• Cost effective, removes need for multiple
  inspections

5
UKAS Accreditation (Mark)
6
Benefits for the Retailer

• Removes burden of routine visits
• Focus on HACCP development
• Focus on quality
• Focus on complaint issues
• Focus on hot issues e.g GMO,allergen

7
Benefits for the Manufacturer

• Resource benefit as due diligence visits
• are reduced
• Focus on factory issues
• Focus on development
• Focus on specific Retailer requirements
• Cost effective, independent and professional
  audit

8
CERTIFICATION

• Accredited Certification (UKAS)
• Quality Management
• Product Certification

9
TYPES OF STANDARDS

• Food Standards in Europe
• Voluntary Codes
• EU Legislated

10
TYPES OF STANDARDS

• Voluntary Codes (for example)
• Animal Feeds
• Cereals
• Horticultural Produce
• Dairy Produce
• Beef, Lamb, Pork

11
TYPES OF STANDARDS

• EU Legislated (for example)
• Food Labelling
• Beef Labelling
• Organic Food Production
• Egg Production
• Animal Welfare
• Environment

12
HACCP

• Majority of Food Chain Standards incorporate
• Hazard Analysis Critical Control Point (HACCP)

13
BRC - STANDARD CONTENTS

• 1. HACCP System
• 2. Quality Management System
• 3. Factory Environment Standards
• 4. Product Control
• 5. Process Control
• 6. Personnel

14
BRC - TECHNICAL STANDARD

• The BRC Standard is divided into two levels, as
  follows
• Foundation Level
• Higher Level

15
BRC HACCP

• Useful reference documentation as suggested by
  the BRC Working Group
• Title
• Hazard Analysis Critical Control Points (HACCP)
  system Guidelines for its Application
• Published in
• Codex Alimentarius Food Hygiene Texts
• Ref. Number
• ISBN 92-5-104021-4

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THE STANDARD REQUIREMENTS

• 1. HACCP
• HACCP - Principles
• Conduct hazard analysis
• Determine critical control points
• Establish critical limits programme
• Monitor against programme
• Establish corrective action
• Verification and validation records
• Establish documentation

17
THE STANDARD REQUIREMENTS

• HACCP - Risk
• Assessment of the identified risk
• Reference to appropriate technical documentation
• Prioritisation of monitoring programme
• Monitor recurring trends
• Underpinned by technical personnel

18
THE STANDARD REQUIREMENTS

• HACCP - Management
• HACCP led by Senior Management commitment
• Reference to product legal and safety obligations
• Technically competent HACCP team
• Plotting the CCP through the production process
• Identification with reference to technical
  working instructions / methods for CCP
• Proof of training / awareness for HACCP at all
  appropriate levels

19
THE STANDARD REQUIREMENTS

• 2. QUALITY MANAGEMENT SYSTEM
• 2.1 Quality Management System (QMS)
• General Requirements
• Identify the processes needed for the QMS
  application
• Sequence and interaction of processes
• Determine criteria and methods to ensure
  operational control(s)
• Resources management
• Monitor, measurement and analysis
• Implementation, planning and improvement

20
THE STANDARD REQUIREMENTS

• 2. QUALITY MANAGEMENT SYSTEM
• 2.2 Quality Policy Statement
• Published statement by the Top Management
• Commitment to the Standard requirements
• Appropriate to the purpose of the company
• Commitment to continuous improvement
• Establishing and reviewing quality objectives
• Communicated and understood
• Reviewed for continuing suitability
• Authorised and approved by Top Management

21
THE STANDARD REQUIREMENTS

• 2.3 Quality Manual
• Development and maintenance of a formal
  documented management system
• The manual should be fully implemented and
  supported by documented evidence (internal
  systems auditing)
• Procedures, and where applicable, referring to
  specification and methods

22
THE STANDARD REQUIREMENTS

• 2.4 Organisational Structure, Responsibility and
  Management Authority
• Authority and communication at appropriate levels
• Responsibility of the management
• Including clear responsibility of safety, legal,
  environmental and quality matters
• Technical responsibility of product compliance to
  specification
• Details of deputy personnel

23
THE STANDARD REQUIREMENTS

• 2.5 Management Commitment
• Top management commitment to the QMS
• Importance of meeting customer, statutory and
  regulatory requirements
• establishing the quality policy
• Ensuring quality and business objectives are
  established
• Conducting management reviews
• Ensuring the availability of resources

24
THE STANDARD REQUIREMENTS

• 2.6 Customer Focus
• Top management shall ensure that the customer
  requirements (and expectations) are determined
  and are met with the aim of enhancing customer
  satisfaction
• Customers may include
• The immediate retailer
• The transporter
• The wider community, and consumer

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THE STANDARD REQUIREMENTS

• 2.7 Management Review
• Top management shall ensure that the QMS is
  reviewed at regular intervals, consistent with
  the management objectives.
• Agenda (may include)
• Internal audit
• Customer complaints
• Production issues
• Supplier evaluation of performance

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THE STANDARD REQUIREMENTS

• 2.8 Resource Management
• The company shall determine and provide the
  resources needed
• To implement and maintain the QMS and continually
  improve its effectiveness, and
• to enhance customer satisfaction by meeting
  customer requirements
• To provide financial resources required for HACCP
  study and implementation

27
THE STANDARD REQUIREMENTS

• 2.9 Internal Auditing
• Programme of audits in consideration of risk
• Senior management approval
• Technical personnel
• Documented results of audit
• Review of audit results
• Corrective and preventive actions

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THE STANDARD REQUIREMENTS

• 2.10 Purchasing
• Purchasing information shall describe the product
  to be purchased, including requirements
• For approval of product, procedures, processing
  and equipment
• For qualification of personnel, and
• Quality management system

29
THE STANDARD REQUIREMENTS

• 2.10.1 Supplier Performance Monitoring
• The evaluation and selection of suppliers
• Formal evaluation and selection
• Approved supplier list (product impact)
• Product receipt inspection
• Performance monitoring

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THE STANDARD REQUIREMENTS

• 2.10.1 Supplier Performance Monitoring
• Supplier conformance with HACCP
• Traceability of product supplied
• Verification of supplier claims / approvals
• Method and frequency of assessment in
  consideration of risk
• Supplier audits (programme)

31
THE STANDARD REQUIREMENTS

• 2.11 General Documentation Requirements
• 2.11.1 Document Control
• 2.11.2 Specifications
• 2.11.3 Procedures
• 2.11.4 Record Keeping

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THE STANDARD REQUIREMENTS

• 2.11.1 Document Control
• Policy statement
• Quality manual
• Technical procedures and methods
• Administration procedures
• Supporting records and archives
• Reference standards appropriate to the scope

33
THE STANDARD REQUIREMENTS

• 2.11.2 Specifications
• Product specification
• Product name
• Customer supplied specifications
• Unique reference / issue number
• Authorisation
• Availability at point of use

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THE STANDARD REQUIREMENTS

• 2.11.2 Specifications
• The company shall ensure that appropriate
  specifications exist for
• Raw materials (including packaging)
• Completed products (including packaging)
• In-process / part completed (where applicable)

35
THE STANDARD REQUIREMENTS

• 2.11.3 Procedures
• Production and administration control
• Procedure / process name
• Customer supplied procedures (and methods)
• Unique reference / issue number
• Authorisation
• Availability at point of use

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THE STANDARD REQUIREMENTS

• 2.11.3 Procedures
• Production and administration control
• Process and performance driven
• Clear, unambiguous and legible
• Issued to appropriate personnel
• Readily accessible at all times

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THE STANDARD REQUIREMENTS

• 2.11.4 Record Keeping
• Information and data generated from the QMS
• Name of record(s)
• Location of record(s) and traceability
• Unique reference / issue number
• Retention period (legal and/or contract
  obligation)
• Disposal of archive records

38
THE STANDARD REQUIREMENTS

• 2.11.4 Record Keeping
• (continued summary)
• In line with procedures
• Records must be legible and genuine
• Safe storage, traceable and retrievable
• Contain appropriate information safety, testing,
  legality and product quality
• Computer back-up (as applicable)

39
THE STANDARD REQUIREMENTS

• 2.11 General Documentation Requirements
• (continued summary)
• Reference standards appropriate to the scope, may
  include
• Food Safety
• Compositional standards
• Metrology
• Additives
• Lot identification and traceability
• Labelling and packaging information

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THE STANDARD REQUIREMENTS

• 2.11 Documentation Control (continued summary)
• Approved for adequacy prior to issue
• Documents shall be authorised
• Identification and issue status controlled
• Ensure access to documentation at all appropriate
  levels
• Control of customer / supplier documents
• Obsolete documentation removed from use
• Completed documents and records controlled

41
THE STANDARD REQUIREMENTS

• 2.12 Corrective Action
• Investigation of cause
• Assessment of risk
• Corrective actions completed in a timely manner
• Implementation of corrective actions
• Review of corrective actions
• Verification of actions
• Impact - Refer to HACCP

42
THE STANDARD REQUIREMENTS

• 2.13 Traceability
• Raw materials
• Work in progress
• Finished goods
• Product identifiable at all stages of production

43
THE STANDARD REQUIREMENTS

• 2.13 Traceability (continued summary)
• Raw materials supply
• Component supply
• Packaging supply
• Product re-call at all stages of production
• Appropriate reference documentation
• Reworking operations control

44
THE STANDARD REQUIREMENTS

• 2.14 Management Of Incidents and
• Product Recall
• Product re-call at all stages of production
• Appropriate reference documentation
• Testing of the system(s)

45
THE STANDARD REQUIREMENTS

• 2.14 Management Of Incidents and
• Product Recall
• Documented incident reporting procedure
• Customer notification
• Documented recall procedure
• Product re-call at all stages of production
• Control of non conforming products
• Corrective and preventive actions
• Verification of recall systems

46
THE STANDARD REQUIREMENTS

• 2.15 Complaint Handling
• Documented system for complaints
• Effective management review
• Implementation of corrective and preventive
  actions
• Complete records of action taken
• Approval of actions

47
THE STANDARD REQUIREMENTS

• 3. FACTORY ENVIRONMENT STANDARDS
• 3.1 Location
• Location away from offensive trades
• Maintenance of buildings and infrastructures
• Internal fabric to prevent contamination
• Boundaries clearly defined
• Security of site location
• Authorised movement of personnel

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THE STANDARD REQUIREMENTS

• 3.2 Perimeter Grounds
• Proper drainage
• Waste water
• Contaminated water / effluent
• Storage protected from contamination
• Security of the site boundary
• Regular monitoring (audited)

49
THE STANDARD REQUIREMENTS

• 3.3 Layout / Product Flow
• Process flow to prevent contamination
• Operative working space
• Cross contamination (biological / chemical)
• Laboratory facilities (where provided)
• Environmental controls
• Washing of equipment

50
THE STANDARD REQUIREMENTS

• 3.4 Fabrication
• 3.4.1Walls
• Should be appropriate design
• Finished surfaces
• Removal of dirt, mould, bacteria
• Consideration when cleaning of corners

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THE STANDARD REQUIREMENTS

• 3.4 Fabrication
• 3.4.2 Floors
• Water / drainage flow away from high risk
• Clean and well maintained
• Should be appropriate design
• Finished surfaces
• Removal of dirt, mould, bacteria
• Consideration when cleaning of corners

52
THE STANDARD REQUIREMENTS

• 3.4 Fabrication
• 3.4.3 Ceilings / Overheads
• Clean and well maintained
• Should be appropriate design
• Finished surfaces
• Removal of dirt, mould, bacteria
• Consideration when cleaning of corners
• Falling items / dirt

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THE STANDARD REQUIREMENTS

• 3.4 Fabrication
• 3.4.4 Windows
• Clean and well maintained
• Should be appropriate design
• Prevention of ingress of pests
• Glass should be protected from breakage
• Use of glass should be avoided

54
THE STANDARD REQUIREMENTS

• 3.4 Fabrication
• 3.4.5 Doors
• Clean and well maintained
• Should be appropriate design
• Prevention of ingress of pests
• Use of glass should be avoided
• Use of curtains
• Secure

55
THE STANDARD REQUIREMENTS

• 3.4 Fabrication
• 3.4.6 Lighting
• Should be adequate to carry out the function
• Should be appropriate design
• Glass (bulb, strip lights) should be protected
• EFK tubes should be protected
• Procedures for replacement of lighting
• Glass management

56
THE STANDARD REQUIREMENTS

• 3.4 Fabrication
• 3.4.7 Air Conditioning / Ventilation
• Should be appropriate design
• Adequate ventilation
• Dust and fume extraction
• Use of filters
• Air movement monitoring

57
THE STANDARD REQUIREMENTS

• 3.4 Fabrication
• 3.4.8 Services
• Use of water, ice, and steam supply
• Cleaning according to source
• Monitored to prevent risk of contamination

58
THE STANDARD REQUIREMENTS

• 3.5 Equipment
• Positioned to give access
• Ease of cleaning
• Properly specified and commissioned
• Planned maintenance programmes
• Working use and set-up instructions
• Operate to legal and safety requirements

59
THE STANDARD REQUIREMENTS

• 3.6 Maintenance
• Planned maintenance programme
• Technically competent personnel
• Outside Contractors
• Manufacturers instruction (where applicable)
• Breakdown procedures

60
THE STANDARD REQUIREMENTS

• 3.7 Staff Facilities
• Changing facilities
• Work-wear appropriate to the task for staff and
  visitors
• Suitable equipment
• Hand-washing / shower facilities
• Toilet, smoking and catering facilities
• Personal lockers and food controls

61
THE STANDARD REQUIREMENTS

• 3.8 Physical Chemical Contamination Risk
• Appropriate and secure storage areas
• Handling procedures and personnel training
• Elimination (where possible) of wood, glass,
  clear plastics in the raw material process areas
• Glass and hard plastic register

62
THE STANDARD REQUIREMENTS

• 3.9 Housekeeping Hygiene
• Cleaning schedules
• Approved cleaning instruction / methods
• Use of approved cleaning detergents
• Cleaning practices to minimise the risk of cross
  contamination
• Monitoring of effectiveness

63
THE STANDARD REQUIREMENTS

• 3.10 Waste / Waste Disposal
• Minimise accumulation of waste in production
• Disposal must meet legal requirements
• Use of licensed waste contractors
• Use of appropriate containers (closed / covered)
• Aware of waste packaging regulations (obligation
  towards recovery / recycling initiatives)

64
THE STANDARD REQUIREMENTS

• 3.11 Pest Control
• Use of approved contractors for pest control
• Records and location of pest control baits
• Correctly sited E.F.Ks
• Use of screens on drains
• Minimise waste materials on site
• Raw materials inspected for pest infestation
• Baits identified on plan

65
THE STANDARD REQUIREMENTS

• 3.12 Transport
• All vehicles must be fit for purpose
• Good repair and hygienic
• Part of a cleaning programme
• Refrigeration controls must be to specification
• In transit breakdown procedures (product
  controls safety, legality and quality)
• Maintenance programme

66
THE STANDARD REQUIREMENTS

• 4. PRODUCT CONTROL
• 4.1 Product Design / Development
• New products shall under-go production trials
• Processes reviewed to ensure legally safe
• Product testing and verification of methods
• Shelf life cycles to be confirmed / verified
• Use of storage conditions detailed
• Plot new processes (HACCP)

67
THE STANDARD REQUIREMENTS

• 4.2 Product Packaging
• Minimise risk of contamination from packaging
• Confirm packaging conforms to specification
• Food safety legislation
• Use of metal staples / other items
• Packaging stored separate from raw materials

68
THE STANDARD REQUIREMENTS

• 4.3 Product Analysis
• Confirm product conforms to specification
• Test results reliable
• Use of accredited test laboratory
• Technically qualified personnel
• Records of results and verification

69
THE STANDARD REQUIREMENTS

• 4.4 Segregation
• Prevention of cross-contamination
• In-process controls
• raw meat
• cooked meat
• packaging
• waste materials

70
THE STANDARD REQUIREMENTS

• 4.5 Stock Rotation
• Identification of product location
• Unique stock / item number
• Details of shelf life
• Product labelling (supplier traceable)
• Internal audit programme

71
THE STANDARD REQUIREMENTS

• 4.6 Metal Detection / Foreign Body Detection
• Form a part of the HACCP documentation
• Appropriate to the nature of the product
• Minimise the risk
• Procedures for equipment use
• Maintenance of equipment
• Isolation and quarantine procedures
• Form a part of the internal audit programme

72
THE STANDARD REQUIREMENTS

• 4.7 Product Release
• Final product inspections / tests
• Records of all inspections
• Authorised personnel only (procedures)
• Use of despatch documentation

73
THE STANDARD REQUIREMENTS

• 4.8 Control of Non-Conforming Product
• The company shall deal with non-conformity using
  one or more of the following methods
• Reject, remove and destroy product
• Authorising product use by concession
• Taking action to preclude product original use
• Product correction, verified to specification

74
THE STANDARD REQUIREMENTS

• 4.8 Control of Non-Conforming Product
• (continued summary)
• Identification of product
• Segregation of product
• Total rejection controls
• Re-working and concessions
• Product disposal (confirmation)
• Records for all actions

75
THE STANDARD REQUIREMENTS

• 4.8 Control of Non-Conforming Product
• (continued summary)
• Final product inspections / tests
• Records of all inspections
• Authorised personnel only (procedures)
• Use of despatch documentation

76
THE STANDARD REQUIREMENTS

• 5. PROCESS CONTROL
• 5.1 Temperature / Time Control
• Where applicable
• Control of raw materials
• Control of work-in-progress
• Environmental controls
• Use of alarms in case of temperature failure
• Procedures for all areas

77
THE STANDARD REQUIREMENTS

• 5.2 Quantity Control
• EU (UK) legal requirements
• Quantity (average / minimum)
• Measurement / weight (calibration)
• Importers shall control packaging in line with EU
  regulations
• Inspection and testing records

78
THE STANDARD REQUIREMENTS

• 5.3 Equipment Process Validation
• Validation of
• Process methods (HACCP)
• Product formulation (Specification)
• Use of equipment (calibration and maintenance)
• Regular review (internal auditing)
• Control of records

79
THE STANDARD REQUIREMENTS

• 5.4 Calibration and Control of Measuring and
  Monitoring Devices
• Traceable calibration of all test and measurement
  equipment, including
• Scales and weigh bridges
• Temperature
• Control of equipment calibration / test records

80
THE STANDARD REQUIREMENTS

• 5.5 Specific Handling Requirements
• Prevent cross-contamination (all areas)
• Example
• Meat / vegetarian products
• Peanuts anaphylactic shock
• Use of handling methods / procedures
• Use of customer specified procedures, as required
  under contract

81
THE STANDARD REQUIREMENTS

• 6. PERSONNEL
• 6.1 Personal Hygiene controls
• Raw material handling
• Processing
• Packing
• Storage areas

82
THE STANDARD REQUIREMENTS

• 6.1 Personal Hygiene controls
• Finger nails
• Jewellery
• Exposed skin / cuts
• Smoking / eating
• Hand cleaning
• Perfume / after-shave

83
THE STANDARD REQUIREMENTS

• 6.2 Medical Screening
• Induction training / contract
• Reporting procedures for infections, etc.
• Visitors / contractors, where appropriate shall
  be medically screened prior to visiting
  production process areas

84
THE STANDARD REQUIREMENTS

• 6.3 Protective Clothing
• Hair covered to prevent contamination
• Appropriate footwear used
• Appropriate clothing (spares)
• Approved laundry services (contractors)
• Available for visitors

85
THE STANDARD REQUIREMENTS

• 6.4 Training
• Induction training supervision
• Personnel training at all levels to include
  contractors and temporary staff
• Review of training procedures
• Use of equipment
• Health and safety
• Personnel (personal) records
• Training records

86

• PROTOCOL

87
PROTOCOL

• Certification Bodies
• Only Accredited Certification bodies to EN45011
  with the appropriate scope, shall carry out
  evaluations against the BRC Standard, and issue
  certificates, or
• Until 31st May 2003, to include those
  Certification Bodies actively seeking
  accreditation to EN45011
• The BRC requirement was EN 45004

88
PROTOCOL

• Before the initial evaluation
• The Supplier is required to review the BRC
  Standard
• Make any necessary amendments or improvements to
  its operation and systems
• Provide background information on the site
  concerned, by completion of a pre-evaluation
  questionnaire or pro-forma information sheet.

89
PROTOCOL

• The scope of the evaluation shall be defined
  between the Supplier and the Certification Body
• The scope shall be identified in the evaluation
  report and any certificate of inspection.
• The Supplier may contract the Certification Body
  to evaluate matters beyond the scope of the BRC
  Standard, but no relevant elements of the BRC
  Standard shall be omitted.

90
PROTOCOL

• Any additions to evaluation scope may or may not
  fall within the scope of the Certification Bodies
  accreditation
• A supplier may be advised to check with either
  the Certification Body or UKAS before contracting
  such additional work

91
PROTOCOL

• Evaluation Procedures
• Duration of evaluations will be dependant upon a
  number of factors but due regard must be given
  to
• size of the site
• the types of processes to produce and store
  product
• number of product lines

92
PROTOCOL

• Evaluation Procedures (continued)
• the number of employees related to food
• (food safety)
• size of random sampling
• the number of non conformances as recorded in
  previous evaluation

93
PROTOCOL

• At all evaluations there are four elements, which
  shall be carried out
• opening meeting
• review of quality systems and procedures
• site inspection
• closing meeting

94
PROTOCOL

• Major
• There is substantial failure to meet the
  requirements of a statement of intent and any
  mandatory clause of the Standard.
• Depending upon the level of certification sought
  (Foundation or Higher), the mandatory clauses
  will differ.
• The mandatory clauses for Foundation Level are
  all those listed in the Foundation Level column.
• The mandatory clauses for Higher Level are as for
  Foundation Level, and in addition, all the
  clauses in the Higher Level column.

95
PROTOCOL

• Minor
• This is where absolute compliance to the
  statement of intent and a mandatory clause has
  not been demonstrated, but on the basis of
  objective evidence the conformity of the
  products safety and legality is not in doubt

96
PROTOCOL

• Recommendation
• There is a failure to meet a recommendation of
  good practice.

97
PROTOCOL

• The report contains the following sections
• evaluation details
• evaluation summary- overview of performance
• details of non-conformance and corrective action
  plan
• detailed evaluation report

98
THE STANDARD REQUIREMENTS

• QUESTIONS