Brc standard for food safety - internal assessment checklist

1.1.1 The site shall have a documented policy which states the site’s intention to meet its obligation to produce safe and legal products to the specified quality and its responsibility to its customers. This shall be:• signed by the person with overall responsibility for the site• communicated to all staff.

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1.1.10 The site’s senior management shall ensure that the root causes of non-conformities identified at the previous audit against the Standard have been effectively addressed to prevent recurrence.

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1.1.2 The site’s senior management shall ensure that clear objectives are defined to maintain and improve the safety, legality and quality of products manufactured, in accordance with the food safety and quality policy and this Standard. These objectives shall be:• documented and include targets or clear measures of success• clearly communicated to relevant staff • monitored and results reported at least quarterly to site senior management.

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1.1.3 Management review meetings attended by the site’s senior management shall be undertaken at appropriate planned intervals, annually as a minimum, to review the site performance against the Standard and objectives set in clause 1.1.2. The review process shall include the evaluation of:• previous management review action plans and timeframes• results of internal, second-party and/or third-party audits• customer complaints and results of any customer feedback• incidents, corrective actions, out-of-specification results and non-conforming materials• review of the management of the systems for HACCP, food defence and authenticity• resource requirements.Records of the meeting shall be documented and used to revise the objectives. The decisions and actions agreed within the review process sh

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1.1.4 The site shall have a demonstrable meeting programme which enables food safety, legality and quality issues to be brought to the attention of senior management at least monthly and allows for the resolution of issues requiring immediate action.

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1.1.5 The company’s senior management shall provide the human and financial resources required to produce food safely and in compliance with the requirements of this Standard.

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1.1.6 The company’s senior management shall have a system in place to ensure that the site is kept informed of and reviews:• scientific and technical developments• industry codes of practice• new risks to authenticity of raw materials• all relevant legislation applicable in the country of raw material supply, production and, where known, the country where the product will be sold.

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1.1.7 The site shall have a genuine, original hard copy or electronic version of the current Standard available and be aware of any changes to the Standard or protocol that are published on the BRC website.

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1.1.8 Where the site is certificated to the Standard it shall ensure that announced recertification audits occur on or before the audit due date indicated on the certificate.

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1.1.9 The most senior production or operations manager on site shall participate in the opening and closing meetings of the audit for Global Standard for Food Safety certification. Relevant departmental managers or their deputies shall be available as required during the audit.

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1.2.1 The company shall have an organisation chart demonstrating the management structure of the company. The responsibilities for the management of activities which ensure food safety, legality and quality shall be clearly allocated and understood by the managers responsible. It shall be clearly documented who deputises in the absence of the responsible person.

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1.2.2 The site’s senior management shall ensure that all employees are aware of their responsibilities. Where documented work instructions exist for activities undertaken, the relevant employees shall have access to these and be able to demonstrate that work is carried out in accordance with the instructions.

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2.1.1 The HACCP plan shall be developed and managed by a multi-disciplinary food safety team that includes those responsible for quality/technical, production operations, engineering and other relevant functions.

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2.1.2 The scope of each HACCP plan, including the products and processes covered, shall be defined.

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The team leader shall have an in-depth knowledge of HACCP and be able to demonstrate competence and experience. The team members shall have specific knowledge of HACCP and relevant knowledge of product, process and associated hazards. In the event of the site not having appropriate in-house knowledge, external expertise may be used, but day-to-day management of the food safety system shall remain the responsibility of the company.

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2.2.1 The site shall establish and maintain environmental and operational programmes necessary to create an environment suitable to produce safe and legal food products (prerequisite programmes). As a guide these may include the following, although this is not an exhaustive list:• cleaning and sanitising• pest control• maintenance programmes for equipment and buildings• personal hygiene requirements• staff training• purchasing• transportation arrangements• processes to prevent cross-contamination• allergen controlsThe control measures and monitoring procedures for the prerequisite programmes must be clearly documented and shall be included within the development and reviews of the HACCP.

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2.3.1 A full description for each product or group of products shall be developed, which includes all relevant information on food safety. As a guide, this may include the following, although this is not an exhaustive list:• composition (e.g. raw materials, ingredients, allergens, recipe)• origin of ingredients• physical or chemical properties that impact food safety (e.g. pH, aw)• treatment and processing (e.g. cooking, cooling)• packaging system (e.g. modifi ed atmosphere, vacuum)• storage and distribution conditions (e.g. chilled, ambient)• target safe shelf life under prescribed storage and usage conditions.

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2.3.2 All relevant information needed to conduct the hazard analysis shall be collected, maintained, documented and updated. The company will ensure that the HACCP plan is based on comprehensive information sources, which are referenced and available on request. As a guide, this may include the following, although this is not an exhaustive list:• the latest scientific literature• historical and known hazards associated with specific food products• relevant codes of practice• recognised guidelines• food safety legislation relevant for the production and sale of products• customer requirements.

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2.4.1 The intended use of the product by the customer, and any known alternative use, shall be described, defining the consumer target groups, including the suitability of the product for vulnerable groups of the population (e.g. infants, elderly, and allergy sufferers).

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2.5.1 A flow diagram shall be prepared to cover each product, product category or process. This shall set out all aspects of the food process operation within the HACCP scope, from raw material receipt through to processing, storage and distribution. As a guide, this should include the following, although this is not an exhaustive list:• plan of premises and equipment layout• raw materials including introduction of utilities and other contact materials (e.g. water, packaging)• sequence and interaction of all process steps• outsourced processes and subcontracted work• potential for process delay• rework and recycling• low-risk/high-risk/high-care area segregation• finished products, intermediate/semi-processed products, by-products and waste.

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2.6.1 The HACCP food safety team shall verify the accuracy of the flow diagrams by on-site audit and challenge at least annually. Daily and seasonal variations shall be considered and evaluated. Records of verified flow diagrams shall be maintained.

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2.7.1 The HACCP food safety team shall identify and record all the potential hazards that are reasonably expected to occur at each step in relation to product, process and facilities. This shall include hazards present in raw materials, those introduced during the process or surviving the process steps, and allergen risks (refer to clause 5.3). It shall also take account of the preceding and following steps in the process chain.

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2.7.2 The HACCP food safety team shall conduct a hazard analysis to identify hazards which need to be prevented, eliminated or reduced to acceptable levels. Consideration shall be given to the following:• likely occurrence of hazard• severity of the effects on consumer safety• vulnerability of those exposed• survival and multiplication of micro-organisms of specific concern to the product• presence or production of toxins, chemicals or foreign bodies• contamination of raw materials, intermediate/semi-processed product, or finished product.Where elimination of the hazard is not practical, justification for acceptable levels of the hazard in the finished product shall be determined and documented.

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2.7.3 The HACCP food safety team shall consider the control measures necessary to prevent or eliminate a food safety hazard or reduce it to an acceptable level. Where the control is achieved through existing prerequisite programmes, this shall be stated and the adequacy of the programme to control the specific hazard validated. Consideration may be given to using more than one control measure.

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2.8.1 For each hazard that requires control, control points shall be reviewed to identify those that are critical. This requires a logical approach and may be facilitated by use of a decision tree. Critical control points (CCPs) shall be those control points which are required in order to prevent or eliminate a food safety hazard or reduce it to an acceptable level. If a hazard is identified at a step where control is necessary for safety but the control does not exist, the product or process shall be modified at that step, or at an earlier step, to provide a control measure.

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2.9.1 For each CCP, the appropriate critical limits shall be defined in order to identify clearly whether the process is in or out of control. Critical limits shall be:• measurable wherever possible (e.g. time, temperature, pH)• Supported by clear guidance or examples where measures are subjective (e.g. photographs).

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2.9.2 The HACCP food safety team shall validate each CCP. Documented evidence shall show that the control measures selected and critical limits identified are capable of consistently controlling the hazard to the specified acceptable level.

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2.10.1 A monitoring procedure shall be established for each CCP to ensure compliance with critical limits. The monitoring system shall be able to detect loss of control of CCPs and wherever possible provide information in time for corrective action to be taken. As a guide, consideration may be given to the following, although this is not an exhaustive list:• on-line measurement• off-line measurement• continuous measurement (e.g. thermographs, pH meters etc.).Where discontinuous measurement is used, the system shall ensure that the sample taken is representative of the batch of product.

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2.10.2 Records associated with the monitoring of each CCP shall include the date, time and result of measurement and shall be signed by the person responsible for the monitoring and verified, when appropriate, by an authorised person. Where records are in electronic form there shall be evidence that records have been checked and verified.

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2.11.1 The HACCP food safety team shall specify and document the corrective action to be taken when monitored results indicate a failure to meet a control limit, or when monitored results indicate a trend towards loss of control. This shall include the action to be taken by nominated personnel with regard to any products that have been manufactured during the period when the process was out of control.

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2.12.1 Procedures of verification shall be established to confirm that the HACCP plan, including controls managed by prerequisite programmes, continues to be effective. Examples of verification activities include:• internal audits• review of records where acceptable limits have been exceeded• review of complaints by enforcement authorities or customers• review of incidents of product withdrawal or recall.Results of verification shall be recorded and communicated to the HACCP food safety team.

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2.13.1 Documentation and record keeping shall be sufficient to enable the site to verify that the HACCP controls, including controls managed by prerequisite programmes, are in place and maintained.

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2.14.1 The HACCP food safety team shall review the HACCP plan and prerequisite programmes at least annually and prior to any changes which may affect product safety. As a guide, these may include the following, although this is not an exhaustive list:• change in raw materials or supplier of raw materials• change in ingredients/recipe• change in processing conditions, process flow or equipment• change in packaging, storage or distribution conditions• change in consumer use• emergence of a new risk (e.g. known adulteration of an ingredient)• following a recall• new developments in scientific information associated with ingredients, process or product.Appropriate changes resulting from the review shall be incorporated into the HACCP plan and/or prerequisite programmes, fully documented and va

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3.1.1 The site’s documented procedures, working methods and practices shall be collated in the form of a printed or electronic quality manual.

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3.1.2 The food safety and quality manual shall be fully implemented and the manual or relevant components shall be readily available to relevant staff.

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3.1.3 All procedures and work instructions shall be clearly legible, unambiguous, in appropriate languages and sufficiently detailed to enable their correct application by appropriate staff. This shall include the use of photographs, diagrams or other pictorial instructions where written communication alone is not sufficient (e.g. there are issues of literacy or foreign language).

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3.2.1 The company shall have a procedure to manage documents which form part of the food safety and quality system. This shall include:• a list of all controlled documents indicating the latest version number• the method for the identification and authorisation of controlled documents• a record of the reason for any changes or amendments to documents• the system for the replacement of existing documents when these are updated.

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3.3.1 Records shall be legible, maintained in good condition and retrievable. Any alterations to records shall be authorised and justification for alteration shall be recorded. Where records are in electronic form these shall be suitably backed up to prevent loss.

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3.3.2 Records shall be retained for a defined period with consideration given to:• any legal or customer requirements• the shelf life of the product.This shall take into account, where it is specified on the label, the possibility that shelf life may be extended by the consumer (e.g. by freezing).As a minimum, records shall be retained for the shelf life of the product plus 12 months.

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3.4.1 There shall be a scheduled programme of internal audits throughout the year with a scope which covers the implementation of the HACCP programme, prerequisite programmes and procedures implemented to achieve this Standard. The scope and frequency of the audits shall be established in relation to the risks associated with the activity and previous audit performance; all activities shall be covered at least annually.

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3.4.2 Internal audits shall be carried out by appropriately trained, competent auditors. Auditors shall be independent (i.e. not audit their own work).

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3.4.3 The internal audit programme shall be fully implemented. Internal audit reports shall identify conformity as well as non-conformity and the results shall be reported to the personnel responsible for the activity audited. Corrective actions and timescales for their implementation shall be agreed and completion of the actions verified.

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3.4.4 In addition to the internal audit programme there shall be a programme of documented inspections to ensure that the factory environment and processing equipment is maintained in a suitable condition for food production. These inspections shall include:• hygiene inspections to assess cleaning and housekeeping performance• fabrication inspections to identify risks to the product from the building or equipment.The frequency of these inspections shall be based on risk but will be no less than once per month in open product areas.

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3.5.1.1 The company shall undertake a documented risk assessment of each raw material or group of raw materials including packaging to identify potential risks to product safety, legality and quality. This shall take into account the potential for:• allergen contamination• foreign-body risks• microbiological contamination• chemical contamination• substitution or fraud (see clause 5.4.2).Consideration shall also be given to the significance of a raw material to the quality of the final product.The risk assessment shall form the basis for the raw material acceptance and testing procedure and for the processes adopted for supplier approval and monitoring. The risk assessments shall be reviewed at least annually.

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3.5.1.2 The company shall have a documented supplier approval and on going monitoring procedure to ensure that all suppliers of raw materials, including packaging, effectively manage risks to raw material quality and safety and are operating effective traceability processes. The approval and monitoring procedure shall be based on risk and include one or a combination of:• certification (e.g. to BRC Global Standards or other GFSI-recognised scheme)• supplier audits, with a scope to include product safety, traceability, HACCP review and good • manufacturing practices, undertaken by an experienced and demonstrably competent product safety auditoror, for suppliers assessed as low risk only, supplier questionnaires.Where approval is based on questionnaires, these shall be reissued at least ever

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3.5.1.3 Where raw materials are purchased from agents or brokers, the site shall know the identity of the last manufacturer or packer or for bulk commodity products the consolidation place of the raw material. Information to enable the approval of the manufacturer, packer or consolidator, as in clause 3.5.1.2, shall be obtained from the agent/broker or directly from the supplier, unless the agent/broker is themselves certificated to the BRC Global Standard for Agents and Brokers.

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3.5.1.4 The procedures shall define how exceptions to the supplier approval processes in clause 3.5.1.2 are handled (e.g. where raw material suppliers are prescribed by a customer) or where information for effective supplier approval is not available (e.g. bulk agricultural commodity products) and instead product testing is used to verify product quality and safety. When a site produces customer-branded product the relevant exceptions shall be identified to the customer.

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3.5.2.1 The company shall have a documented procedure for the acceptance of raw materials and packaging on receipt based upon the risk assessment (clause 3.5.1.1). Raw material including packaging acceptance and its release for use shall be based on one or a combination of:• product sampling and testing• visual inspection on receipt• certificates of analysis – specific to the consignment• certificates of conformance.A list of raw materials including packaging and the requirements to be met for acceptance shall be available. The parameters for acceptance and frequency of testing shall be clearly defined, implemented and reviewed.

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3.5.3.1 There shall be a documented procedure for the approval and monitoring of suppliers of services. Such services shall include, as appropriate:• pest control• laundry services• contracted cleaning• contracted servicing and maintenance of equipment• transport and distribution• off-site storage of ingredients, packaging or products• laboratory testing• catering services• waste management.

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3.5.3.2 Contracts or formal agreements shall exist with the suppliers of services that clearly define service expectations and ensure potential food safety risks associated with the service have been addressed.

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3.5.4.1 The company shall be able to demonstrate that where part of the production process or final packing is outsourced and undertaken off-site this has been declared to the brand owner and, where required, approval granted.

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3.5.4.2 The company shall ensure that subcontractors are approved and monitored by successful completion of either:• certification to the applicable BRC Global Standard for Food Safety or other GFSI-recognised scheme• a documented site audit with a scope to include product safety, traceability, HACCP review and good manufacturing practices by an experienced and demonstrably competent product safety auditor.

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3.5.4.3 Any outsourced processing or packing operations shall:• be undertaken in accordance with established contracts which clearly define any processing and/or packing requirements and product specification• maintain product traceability.

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3.5.4.4 The company shall establish inspection and test procedures for products where part of the processing or packing have been outsourced, including visual, chemical and/or microbiological testing, dependent on risk assessment.

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3.6.1 Specifications for raw materials and packaging shall be adequate and accurate and ensure compliance with relevant safety and legislative requirements. The specifications shall include defined limits for relevant attributes of the material which may affect the quality or safety of the final products (e.g. chemical, microbiological or physical standards).

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3.6.2 Accurate, up-to-date specifications shall be available for all finished products. These shall include key data to meet customer and legal requirements and assist the user in the safe usage of the product.

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3.6.3 The company shall seek formal agreement of specifications with relevant parties. Where specifications are not formally agreed then the company shall be able to demonstrate that it has taken steps to ensure formal agreement is in place.

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3.6.4 Specifications shall be reviewed whenever products change (e.g. ingredients, processing method) or at least every 3 years. The date of review and the approval of any changes shall be recorded.

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3.7.1 The site shall have a documented procedure for handling and correcting failures identified in the food safety and quality system.

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3.7.2 Where a non-conformity places the safety, legality or quality of products at risk this shall be investigated and recorded including:• clear documentation of the non-conformity• assessment of consequences by a suitably competent and authorised person• the action to address the immediate issue• an appropriate timescale for correction• the person responsible for correction• verification that the correction has been implemented and is effective• identification of the root cause of the non-conformity and implementation of any necessary actions to prevent recurrence.

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3.8.1 There shall be documented procedures for managing non-conforming products. These procedures shall include:.• the requirement for staff to identify and report a potentially non-conforming product• clear identification of a non-conforming product (e.g. direct labelling or the use of IT systems)• secure storage to prevent accidental release (e.g. physical or computer-based isolation)• referral to the brand owner where required• defined responsibilities for decision making on the use or disposal of products appropriate to the issue (e.g. destruction, reworking, downgrading to an alternative label or acceptance by concession)• records of the decision on the use or disposal of the product• records of destruction where a product is destroyed for food safety reasons.

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3.9.1 Identification of raw materials, including primary and any other relevant packaging, processing aids, intermediate/semi-processed products, part-used materials, finished products and materials pending investigation shall be adequate to ensure traceability.

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3.9.2 The site shall test the traceability system across the range of product groups to ensure traceability can be determined from raw material including primary packaging to finished product and vice versa, including quantity check/mass balance. This shall occur at a predetermined frequency, as a minimum annually, and results shall be retained for inspection. Full traceability should be achievable within 4 hours.

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3.9.3 The company shall ensure that its suppliers of raw materials have an effective traceability system. Where a supplier has been approved based on a questionnaire, instead of certification or audit, verification of the supplier’s traceability system shall be carried out on first approval and then at least every 3 years. This may be achieved by a traceability test. Where a raw material is received directly from a farm or fish farm, further verification of the farm’s traceability system is not mandatory.

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3.9.4 Where rework or any reworking operation is performed, traceability shall be maintained.

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3.10.1 All complaints shall be recorded, investigated and the results of the investigation of the issue recorded where sufficient information is provided. Actions appropriate to the seriousness and frequency of the problems identified shall be carried out promptly and effectively by appropriately trained staff.

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3.10.2 Complaint data shall be analysed for significant trends. Where there has been a significant increase in a complaint or a serious complaint, root cause analysis shall be used to implement on going improvements to product safety, legality and quality, and to avoid recurrence. This analysis shall be made available to relevant staff.

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3.11.1 The company shall have documented procedures designed to report and effectively manage incidents and potential emergency situations that impact food safety, legality or quality. This shall include consideration of contingency plans to maintain product safety, quality and legality. Incidents may include:• disruption to key services such as water, energy, transport, refrigeration processes, staff availability and communications• events such as fire, flood or natural disaster• malicious contamination or sabotage.Where products which have been released from the site may be affected by an incident, consideration shall be given to the need to withdraw or recall products.

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3.11.2 The company shall have a documented product withdrawal and recall procedure. This shall include as a minimum:• identification of key personnel constituting the recall management team, with clearly identified responsibilities• guidelines for deciding whether a product needs to be recalled or withdrawn and the records to be maintained• an up-to-date list of key contacts (including out-of-hours contact details) or reference to the • location of such a list (e.g. recall management team, emergency services, suppliers, customers, certification body, regulatory authority)• a communication plan including the provision of information to customers, consumers and regulatory authorities in a timely manner• details of external agencies providing advice and support as necessary (e.g. specialist l

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3.11.3 The product recall and withdrawal procedures shall be tested, at least annually, in a way that ensures their effective operation. Results of the test shall be retained and shall include timings of key activities. The results of the test and of any actual recall shall be used to review the procedure and implement improvements as necessary.

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3.11.4 In the event of a product recall, the certification body issuing the current certificate for the site against this Standard shall be informed within 3 working days of the decision to issue a recall.

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3.12.1 Where a company is requested to follow specific customer requirements, codes of practice, methods of working etc., these shall be made known to relevant staff within the site and implemented.

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3.12.2 Effective processes shall be in place for communicating customer-specific requirements to the suppliers of raw materials and services as applicable.

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4.1.1 Consideration shall be given to local activities and the site environment, which may have an adverse impact on finished product integrity, and measures shall be taken to prevent contamination. Where measures have been put into place to protect the site (from potential contaminants, flooding etc.), they shall be reviewed in response to any changes.

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4.1.2 The external areas shall be maintained in good order. Where buildings are surrounded by grassed or planted areas, they shall be regularly tended and well maintained. External traffic routes under site control shall be suitably surfaced and maintained in good repair to avoid contamination of the product.

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4.1.3 The building fabric shall be maintained to minimise potential for product contamination (e.g. elimination of bird roosting sites, sealing gaps around pipes to prevent pest entry, ingress of water and other contaminants).

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4.2.1 The company shall undertake a documented assessment of the security arrangements and potential risks to the products from any deliberate attempt to inflict contamination or damage. Areas shall be assessed according to risk; sensitive or restricted areas shall be defined, clearly marked, monitored and controlled. Identified security arrangements to reduce risks shall be implemented and reviewed at least annually.

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4.2.2 Measures shall be in place to ensure only authorised personnel have access to production and storage areas, and access to the site by employees, contractors and visitors shall be controlled. A visitor reporting system shall be in place. Staff shall be trained in site security procedures and encouraged to report unidentified or unknown visitors.

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4.2.3 External storage tanks, silos and any intake pipes with an external opening shall be locked.

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4.2.4 Where required by legislation, the site shall be registered with, or be approved by, the appropriate authority.

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4.3.1 There shall be a map of the site which designates areas (zones) where product is at different levels of risk from contamination; that is:• high-risk areas• high-care areas• ambient high-care areas• low-risk areas• enclosed product areas• non-product areas.See Appendix 2 for guidelines on defining the production risk zones.This zoning shall be taken into account when determining the prerequisite programmes for the particular areas of the site.

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4.3.2 The site map(s) shall define:• access points for personnel• access points for raw materials (including packaging)• routes of movement for personnel• routes of movement for raw materials• routes for the removal of waste• routes for the movement of rework• location of any staff facilities including changing rooms, toilets, canteens and smoking areas• production process flow.

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4.3.3 Contractors and visitors, including drivers, shall be made aware of all procedures for access to premises and the requirements of the areas they are visiting, with special reference to hazards and potential product contamination. Contractors working in product processing or storage areas shall be the responsibility of a nominated person.

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4.3.4 The movement of personnel, raw materials, packaging, rework and/or waste shall not compromise the safety of products. The process flow, together with the use of demonstrably effective procedures, shall be in place to minimise the risk of the contamination of raw materials, intermediate/semi-processed products, packaging and finished products.

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4.3.5 Where high-risk areas are part of the manufacturing site, there shall be physical segregation between these areas and other parts of the site. Segregation shall take into account the flow of product, nature of materials (including packaging), equipment, personnel, waste, airflow, air quality and utilities provision (including drains). The location of transfer points shall not compromise the segregation between high-risk areas and other areas of the factory. Practices shall be in place to minimise risk of product contamination (e.g. the disinfection of materials on entry).

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4.3.6 Where high-care areas are part of the manufacturing site there should be physical segregation between these areas and other parts of the site. Segregation shall take into account the flow of product, nature of materials (including packaging), equipment, personnel, waste, airflow, air quality and utilities provision (including drains). Where physical barriers are not in place, the site shall have undertaken a documented risk assessment of the potential for cross-contamination, and effective, validated processes shall be in place to protect products from contamination.

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4.3.7 Where ambient high-care areas are required a documented risk assessment shall be completed to determine the risk of cross-contamination with pathogens. The risk assessment shall take into account the potential sources of microbiological contamination and include:• the raw materials and products• flow of raw materials, packaging, products, equipment, personnel and waste• airflow and air quality• utilities (including drains).Effective processes shall be in place to protect the final product from this contamination. These processes may include segregation, management of process flow or other controls.

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4.3.8 Premises shall allow sufficient working space and storage capacity to enable all operations to be carried out properly under safe hygienic conditions.

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4.3.9 Temporary structures constructed during building work or refurbishment etc. shall be designed and located to avoid pest harbourage and ensure the safety and quality of products.

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4.4.1 Walls shall be finished and maintained to prevent the accumulation of dirt, minimise condensation and mould growth, and facilitate cleaning.

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4.4.10 Suitable and sufficient lighting shall be provided for correct operation of processes, inspection of product and effective cleaning.

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4.4.11 Where they constitute a risk to product, bulbs and strip lights – including those on electric fly-killer devices – shall be adequately protected. Where full protection cannot be provided, alternative management such as wire-mesh screens or monitoring procedures shall be in place.

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4.4.12 Adequate ventilation and extraction shall be provided in product storage and processing environments to prevent condensation or excessive dust.

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4.4.13 High-risk areas shall be supplied with sufficient changes of filtered air. The filter specification used and frequency of air changes shall be documented. This shall be based on a risk assessment, taking into account the source of the air and the requirement to maintain a positive air pressure relative to the surrounding areas.

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4.4.2 Floors shall be suitably hard wearing to meet the demands of the process, and withstand cleaning materials and methods. They shall be impervious, be maintained in good repair and facilitate cleaning.

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4.4.3 Drainage, where provided, shall be sited, designed and maintained to minimise risk of product contamination and not compromise product safety. Machinery and piping shall be arranged so that, wherever feasible, process waste water goes directly to drain. Where significant amounts of water are used, or direct piping to drain is not feasible, floors shall have adequate falls to cope with the flow of any water or effluent towards suitable drainage.

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4.4.4 Where sites include high-risk or high-care facilities, there shall be a map of the drains for these areas which shows the direction of flow and location of any equipment fitted to prevent the back-up of waste water. The flow of drains shall not present a risk of contamination of the high-risk/care area.

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4.4.5 Ceilings and overheads shall be constructed, finished and maintained to prevent the risk of product contamination.

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4.4.6 Where suspended ceilings or roof voids are present, adequate access to the void shall be provided to facilitate inspection for pest activity, unless the void is fully sealed.

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4.4.7 Where there is a risk to product, windows, and roof glazing which is designed to be opened for ventilation purposes, shall be adequately screened to prevent the ingress of pests.

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4.4.8 Where they pose a risk to product, glass windows shall be protected against breakage.

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4.4.9 Doors shall be maintained in good condition:• External doors and dock levellers shall be close fitting or adequately proofed.• External doors to open product areas shall not be opened during production periods except in emergencies.Where external doors to enclosed product areas are opened, suitable precautions shall be taken to prevent pest ingress.

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4.5.1 All water used as a raw material in the manufacture of processed food, the preparation of product, hand-washing or for equipment or plant cleaning shall be supplied in sufficient quantity, be potable at point of use or pose no risk of contamination according to applicable legislation. The microbiological and chemical quality of water shall be analysed at least annually. The sampling points, scope of the test and frequency of analysis shall be based on risk, taking into account the source of the water, on-site storage and distribution facilities, previous sample history and usage.

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4.5.2 An up-to-date schematic diagram shall be available of the water distribution system on site, including holding tanks, water treatment and water recycling as appropriate. The diagram shall be used as a basis for water sampling and the management of water quality.

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4.5.3 Where legislation specifically permits the use of water which may not be potable for initial product cleaning (e.g. for the storage/washing of fish), the water shall meet the designated legal requirements for this operation.

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4.5.4 Air, other gases and steam used directly in contact with, or as an ingredient in, products shall be monitored to ensure this does not represent a contamination risk. Compressed air used directly in contact with the product shall be filtered.

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4.6.1 All equipment shall be constructed of appropriate materials. The design and placement of equipment shall ensure it can be effectively cleaned and maintained.

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4.6.2 Equipment which is in direct contact with food shall be suitable for food contact and meet legal requirements where applicable.

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4.7.1 There shall be a documented planned maintenance schedule or condition monitoring system which includes all plant and processing equipment. The maintenance requirements shall be defined when commissioning new equipment.

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4.7.2 In addition to any planned maintenance programme, where there is a risk of product contamination by foreign bodies arising from equipment damage, the equipment shall be inspected at predetermined intervals, inspection results documented and appropriate action taken.

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4.7.3 Where temporary repairs are made, these shall be controlled to ensure the safety or legality of a product is not jeopardised. These temporary measures shall be permanently repaired as soon as practicable and within a defined timescale.

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4.7.4 The site shall ensure that the safety or legality of product is not jeopardised during maintenance and subsequent cleaning operations. Maintenance work shall be followed by a documented hygiene clearance procedure, which records that product contamination hazards have been removed from machinery and equipment.

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4.7.5 Maintenance activities undertaken in high-risk and high-care areas shall respect the segregation requirements of the area. Wherever possible tools and equipment shall be dedicated for use in the area and be retained in the area.

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4.7.6 Materials used for equipment and plant maintenance and that pose a risk by direct or indirect contact with raw materials, intermediate and finished products, such as lubricating oil, shall be food grade and of a known allergen status.

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4.7.7 Engineering workshops shall be kept clean and tidy and controls shall be in place to prevent transfer of engineering debris to production or storage areas.

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4.8.1 Designated changing facilities shall be provided for all personnel, whether staff, visitor or contractor. These shall be sited to allow direct access to the production, packing or storage areas without recourse to any external area. Where this is not possible, a risk assessment shall be carried out and procedures implemented accordingly (e.g. the provision of cleaning facilities for footwear).

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4.8.10 Where catering facilities are provided on the premises, they shall be suitably controlled to prevent contamination of products (e.g. as a source of food poisoning or introduction of allergenic material to the site).

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4.8.2 Storage facilities of sufficient size to accommodate personal items shall be provided for all personnel who work in raw material handling, preparation, processing, packing and storage areas.

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4.8.3 Outdoor clothing and other personal items shall be stored separately from production clothing within the changing facilities. Facilities shall be available to separate clean and dirty production clothing.

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4.8.4 Where an operation includes a high-risk area, personnel shall enter via a specially designated changing facility at the entrance to the high-risk area. The changing facilities shall meet the following requirements:• Clear instructions shall be provided for the order of changing into and out of dedicated protective clothes to prevent the contamination of clean clothing.• Protective clothing shall be visually distinctive from that worn in other areas and shall not be worn outside the high-risk area.• Hand-washing during the changing procedure shall be incorporated to prevent contamination of the clean protective clothing (i.e. hand-washing after hair covering and footwear has been put on, but before handling clean protective clothing).• Prior to entry to high-risk areas, hand-washing a

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4.8.5 Where an operation includes a high-care area, personnel shall enter via a specially designated changing facility with arrangements to ensure that protective clothing will not be contaminated before entry to the high-care area. This shall incorporate the following requirements:• Clear instructions for the order of changing into and out of dedicated protective clothes to prevent the contamination of clean clothing.• Site-provided footwear shall not be worn outside the factory.• Protective clothing shall be visually distinctive from that worn in lower risk areas and shall not be worn outside of the high-care area.• Hand-washing during the changing procedure shall be incorporated to prevent contamination of the clean protective clothing.• On entry to high-care areas, hand-washing and dis

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4.8.6 Suitable and sufficient hand-washing facilities shall be provided at access to, and at other appropriate points within, production areas. Such hand-washing facilities shall provide as a minimum:• advisory signs to prompt hand-washing• a sufficient quantity of water at a suitable temperature• water taps with hands-free operation• liquid/foam soap• single-use towels or suitably designed and located air driers.

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4.8.7 Toilets shall be adequately segregated and shall not open directly into production or packing areas. Toilets shall be provided with hand-washing facilities comprising:• basins with soap and water at a suitable temperature• adequate hand-drying facilities• advisory signs to prompt hand-washing.Where hand-washing facilities within toilet facilities are the only facilities provided before re-entering production, the requirements of clause 4.8.6 shall apply and signs shall be in place to direct people to hand-washing facilities before entering production.

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4.8.8 Where smoking is allowed under national law, designated controlled smoking areas shall be provided which are both isolated from production areas to an extent that ensures smoke cannot reach the product and fitted with sufficient extraction to the exterior of the building. Adequate arrangements for dealing with smokers’ waste shall be provided at smoking facilities, both inside and at exterior locations. Electronic cigarettes shall not be permitted to be used or brought into production or storage areas.

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4.8.9 All food brought into manufacturing premises by staff shall be appropriately stored in a clean and hygienic state. No food shall be taken into storage, processing or production areas. Where eating of food is allowed outside during breaks, this shall be in suitable designated areas with appropriate control of waste.

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4.9.1.1 Processes shall be in place to manage the use, storage and handling of non-food chemicals to prevent chemical contamination. These shall include as a minimum:• an approved list of chemicals for purchase• availability of material safety data sheets and specifications• confirmation of suitability for use in a food-processing environment• avoidance of strongly scented products• the labelling and/or identification of containers of chemicals at all times• a designated storage area with restricted access to authorised personnel• use by trained personnel only.

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4.9.1.2 Where strongly scented or taint-forming materials have to be used, for instance for building work, procedures shall be in place to prevent the risk of taint contamination of products.

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4.9.2.1 There shall be a documented policy for the control of the use of sharp metal implements including knives, cutting blades on equipment, needles and wires. This shall include a record of inspection for damage and the investigation of any lost items. Snap-off-blade knives shall not be used.

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4.9.2.2 The purchase of ingredients and packaging which use staples or other foreign-body hazards as part of the packaging materials shall be avoided. Staples, paper clips and drawing pins shall not be used in open product areas. Where staples or other items are present as packaging materials or closures, appropriate precautions shall be taken to minimise the risk of product contamination.

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4.9.3.1 Glass or other brittle materials shall be excluded or protected against breakage in areas where open products are handled or there is a risk of product contamination.

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4.9.3.2 Documented procedures for handling glass and other brittle materials (other than product packaging) shall be in place where open products are handled or there is a risk of product contamination. These procedures shall include as a minimum:• a list of items detailing location, number, type and condition• recorded checks of condition of items, carried out at a specified frequency that is based on the level of risk to the product• details on cleaning or replacing items to minimise potential for product contamination.

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4.9.3.3 Documented procedures detailing the action to be taken in case of breakage of glass or other brittle items shall be implemented and include the following:• quarantining the products and production area that were potentially affected• cleaning the production area• inspecting the production area and authorising to continue production• changing of workwear and inspection of footwear• specifying those staff authorised to carry out the above points• recording the breakage incident.

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4.9.3.4.2 Systems shall be in place to manage container breakages between the container cleaning/inspection point and container closure. This shall include, as a minimum, documented instructions which ensure:• the removal and disposal of at-risk products in the vicinity of the breakage; this may be specific for different equipment or areas of the production line• the effective cleaning of the line or equipment which may be contaminated by fragments of the container; cleaning shall not result in the further dispersal of fragments, for instance by the use of • high pressure water or air• the use of dedicated, clearly identifiable cleaning equipment (e.g. colour coded) for removal of • container breakages; such equipment shall be stored separately from other cleaning equipment• the use of ded

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4.9.3.4.3 Records shall be maintained of all container breakages on the line. Where no breakages have occurred during a production period, this shall also be recorded. This record shall be reviewed to identify trends and potential line or container improvements.

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4.9.4.1 The storage of the containers shall be segregated from the storage of raw materials, product or other packaging.

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4.9.5.1 Wood should not be used in open product areas except where this is a process requirement (e.g. maturation of products in wood). Where the use of wood cannot be avoided, the condition of wood shall be continually monitored to ensure it is in good condition and free from damage or splinters which could contaminate products.

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4.10.1.1 A documented assessment in association with the HACCP study shall be carried out on each production process to identify the potential use of equipment to detect or remove foreign-body contamination. Typical equipment to be considered may include:• filters• sieves• metal detection• magnets• optical sorting equipment• X-ray detection equipment• other physical separation equipment (e.g. gravity separation, fluid bed technology).

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4.10.1.2 The type, location and sensitivity of the detection and/or removal method shall be specified as part of the site’s documented system. Industry best practice shall be applied with regard to the nature of the ingredient, material, product and/or the packed product. The location of the equipment or any other factors influencing the sensitivity of the equipment shall be validated and justified.

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4.10.1.3 The site shall ensure that the frequency of the testing of the foreign-body detection and/or removal equipment is defined and takes into consideration:• specific customer requirements• the site’s ability to identify, hold and prevent the release of any affected materials, should the equipment fail.

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4.10.1.4 Where foreign material is detected or removed by the equipment, the source of any unexpected material shall be investigated. Information on rejected materials shall be used to identify trends and where possible instigate preventive action to reduce the occurrence of contamination by the foreign material.

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4.10.2.1 Filters and sieves used for foreign-body control shall be of a specified mesh size or gauge and designed to provide the maximum practical protection for the product. Material retained or removed by the system shall be examined and recorded to identify contamination risks.

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4.10.2.2 Filters and sieves shall be regularly inspected or tested for damage on a documented frequency based on risk. Records shall be maintained of the checks. Where defective filters or sieves are identified this shall be recorded and the potential for contamination of products investigated and appropriate action taken.

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4.10.3.1 Metal detection equipment shall be in place unless risk assessment demonstrates that this does not improve the protection of final products from metal contamination. Where metal detectors are not used justification shall be documented. The absence of metal detection would only normally be based on the use of an alternative, more effective method of protection (e.g. use of X-ray, fine sieves or filtration of products).

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4.10.3.2 The metal detector or X-ray equipment shall incorporate one of the following:• an automatic rejection device, for continuous in-line systems, which shall either divert contaminated product out of the product flow or to a secure unit accessible only to authorised personnel• a belt stop system with an alarm where the product cannot be automatically rejected (e.g. for very large packs)• in-line detectors which identify the location of the contaminant to allow effective segregation of the affected product.

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4.10.3.3 The site shall establish and implement documented procedures for the operation and testing of the metal detection or X-ray equipment. This shall include as a minimum:• responsibilities for the testing of equipment• the operating effectiveness and sensitivity of the equipment and any variation to this for particular products• the methods and frequency of checking the detector recording of the results of checks.

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4.10.3.4 Metal detector checking procedures shall be based on good practice and shall as a minimum include the following:• Use of test pieces incorporating a sphere of metal of a known diameter selected on the basis of risk. • The test pieces shall be marked with the size and type of test material contained.• Tests carried out using separate test pieces containing ferrous metal, stainless steel and typically non-ferrous metal, unless the product is within a foil container where ferrous only may be applicable.• A test that both the detection and rejection mechanisms are working effectively under normal working conditions.• Checks that test the memory/reset function of the metal detector by passing successive test packs through the unit at typical line operating speed.• Checks of failsafe sy

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4.10.3.5 The site shall establish and implement corrective action and reporting procedures in the event of the testing procedure identifying any failure of the foreign-body detector. Action shall include a combination of isolation, quarantining and re-inspection of all product produced since the last successful test.

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4.10.4.1 The type, location and strength of magnets shall be fully documented. Documented procedures shall be in place for the inspection, cleaning, strength testing and integrity checks. Records of all checks shall be maintained.

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4.10.5.1 Each unit shall be checked in accordance with the manufacturer’s instructions or recommendations. Checks shall be documented.

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4.10.6.1 Based on risk assessment, procedures shall be implemented to minimise foreign-body contamination originating with the packaging container (e.g. jars, cans and other pre-formed rigid containers). This may include the use of covered conveyors, container inversion and foreign-body removal through rinsing with water or air jets.

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4.10.6.2 The effectiveness of the container cleaning equipment shall be checked and recorded during each production. Where the system incorporates a rejection system for dirty or damaged containers, the check shall incorporate a test of both the detection and effective rejection of the test container.

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4.11.1 The premises and equipment shall be maintained in a clean and hygienic condition.

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4.11.2 Documented cleaning procedures shall be in place and maintained for the building, plant and all equipment. Cleaning procedures for processing equipment, food contact surfaces and environmental cleaning in high-care/high-risk areas shall as a minimum include the:• responsibility for cleaning• item/area to be cleaned• frequency of cleaning• method of cleaning, including dismantling equipment for cleaning purposes where required• cleaning chemicals and concentrations• cleaning materials to be used• cleaning records and responsibility for verification.The frequency and methods of cleaning shall be based on risk.The procedures shall be implemented to ensure appropriate standards of cleaning are achieved

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4.11.3 As a minimum for food contact surfaces, processing equipment and for environmental cleaning in high-care/high-risk areas, limits of acceptable and unacceptable cleaning performance shall be defined. This shall be based on the potential hazards (e.g. microbiological, allergen, foreign-body contamination or product-to-product contamination). Acceptable levels of cleaning may be defined by visual appearance, ATP bioluminescence techniques (see glossary), microbiological testing or chemical testing as appropriate. Where cleaning procedures are part of a defined prerequisite plan to control the risk of a specific hazard the cleaning and disinfection procedures and frequency shall be validated and records maintained. This shall include the risk from cleaning chemical residues on food cont

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4.11.4 The resources for undertaking cleaning shall be available. Where it is necessary to dismantle equipment for cleaning purposes or to enter large equipment for cleaning, this shall be appropriately scheduled and, where necessary, planned for non-production periods. Cleaning staff shall be adequately trained or engineering support provided where access within equipment is required for cleaning.

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4.11.5 The cleanliness of equipment shall be checked before equipment is released back into production. The results of checks on cleaning, including visual, analytical and microbiological checks, shall be recorded and used to identify trends in cleaning performance and instigate improvements where required.

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4.11.6 Cleaning equipment shall be:• hygienically designed and fit for purpose• suitably identified for intended use (e.g. colour coded or labelled)• cleaned and stored in a hygienic manner to prevent contamination.Equipment used for cleaning in high-care and high-risk areas shall be visually distinctive and dedicated for use in that area.

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4.11.7.1 Cleaning-in-place (CIP) facilities, where used, shall be monitored and maintained to ensure their effective operation.

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4.11.7.2 A schematic diagram of the layout of the CIP system including process piping circuits shall be available. There shall be an inspection report or other validation that:• systems are hygienically designed with no dead areas, limited interruptions to flow streams and good system drain ability• scavenge/return pumps are operated to ensure that there is no build-up of CIP solutions in the vessels• spray balls and rotating spray devices effectively clean vessels by providing full surface coverage and are periodically inspected for blockages• CIP equipment has adequate separation from active product lines (e.g. through the use of double seat valves, manually controlled links, blanks in pipework or make-or-break connections with proxy switches as interlocks) to prevent or safeguard agains

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4.11.7.3 The CIP equipment shall be operated to ensure effective cleaning is carried out:• The process parameters, time, detergent concentrations, flow rate and temperatures shall be defined to ensure removal of the appropriate target hazard (e.g. soil, allergens, vegetative micro-• organisms, spores). This shall be validated and records of the validation maintained.• Detergent concentrations shall be checked routinely.• CIP process verification shall be undertaken by analysis of rinse waters and/or first product through the line for the presence of cleaning fluids or by tests of ATP (bioluminescence techniques), allergens or micro-organisms as appropriate.• Detergent tanks shall be kept stocked up and a log maintained of when these are drained, cleaned, filled and emptied. Recovered post-

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4.12.1 Where licensing is required by law for the removal of waste, it shall be removed by licensed contractors and records of removal shall be maintained and available for audit.

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4.12.2 External waste collection containers and rooms housing waste facilities shall be managed to minimise risk. These shall be:• clearly identified• designed for ease of use and effective cleaning• well maintained to allow cleaning and, where required, disinfection• emptied at appropriate frequencies• covered or doors kept closed as appropriate.

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4.12.3 If unsafe products or substandard trademarked materials are transferred to a third party for destruction or disposal, that third party shall be a specialist in secure product or waste disposal and shall provide records which include the quantity of waste collected for destruction or disposal.

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4.13.1 Surplus customer-branded products shall be disposed of in accordance with customer-specific requirements. Customer brand names shall be removed from packed surplus products under the control of the factory before the product enters the supply chain unless authorised otherwise by the customer.

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4.13.2 Where customer-branded products which do not meet specification are sold to staff or passed on to charities or other organisations this shall be with the prior consent of the brand owner. Processes shall be in place to ensure that all products are fit for consumption and meet legal requirements.

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4.13.3 By-products and downgraded/surplus products intended for animal feed shall be segregated from waste and protected from contamination during storage. Products for animal feed shall be managed in accordance with relevant legislative requirements.

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4.14.1 If pest activity is identified it shall not present a risk of contamination to products, raw materials or packaging. The presence of any infestation on site shall be identified in pest control records and be part of an effective pest management programme to eliminate or manage the infestation such that it does not present a risk to products, raw materials or packaging.

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4.14.10 Results of pest control inspections shall be assessed and analysed for trends on a regular basis, but, as a minimum:• in the event of an infestation• annually.This shall include a catch analysis from trapping devices to identify problem areas. The analysis shall be used as a basis for improving the pest control procedures.

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4.14.11 Employees shall understand the signs of pest activity and be aware of the need to report any evidence of pest activity to a designated manager.

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4.14.2 The site shall either contract the services of a competent pest control organisation, or shall have appropriately trained staff, for the regular inspection and treatment of the site to deter and eradicate infestation. The frequency of inspections shall be determined by risk assessment and shall be documented. Where the services of a pest control contractor are employed, the service scope shall be clearly defined and reflect the activities of the site.

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4.14.3 Where a site undertakes its own pest control, it shall be able to effectively demonstrate that:• pest control operations are undertaken by trained and competent staff with sufficient knowledge to select appropriate pest control chemicals and proofing methods and understand the limitations of use, relevant to the biology of the pests associated with the sitestaff undertaking pest control activities meet any legal requirements for training or registration• sufficient resources are available to respond to any infestation issues• there is ready access to specialist technical knowledge when required• legislation governing the use of pest control products is understood• dedicated locked facilities are used for the storage of pesticides.

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4.14.4 Pest control documentation and records shall be maintained. This shall include as a minimum:• an up-to-date plan of the full site, identifying numbered pest control device locations• identification of the baits and/or monitoring devices on site• clearly defined responsibilities for site management and for the contractor• details of pest control products used, including instructions for their effective use and action to be • taken in case of emergencies• any observed pest activity• details of pest control treatments undertaken.

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4.14.5 Bait stations or other rodent control devices shall be appropriately located and maintained to prevent contamination risk to product. Toxic rodent baits shall not be used within production or storage areas where open product is present except when treating an active infestation. Where toxic baits are used these shall be secured. Any missing bait stations shall be recorded, reviewed and investigated.

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4.14.6 Fly-killing devices and/or pheromone traps shall be correctly sited and operational. If there is a danger of insects being expelled from a fly-killing extermination device and contaminating the product, alternative systems and equipment shall be used.

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4.14.7 In the event of infestation, or evidence of pest activity, immediate action shall be taken to identify at-risk product and to minimise the risk of product contamination. Any potentially affected products should be subject to the non-conforming product procedure.

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4.14.8 Records of pest control inspections, pest proofing and hygiene recommendations and actions taken shall be maintained. It shall be the responsibility of the site to ensure that all of the relevant recommendations made by its contractor or in-house expert are carried out in a timely manner.

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4.14.9 An in-depth, documented pest control survey shall be undertaken at a frequency based on risk, bu• provide an in-depth inspection of the facility for pest activity• review the existing pest control measures in place and make any recommendations for change.The timing of the survey shall be such as to allow access to equipment for inspection where a risk of stored product insect infestation exists.

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4.15.1 Documented procedures to maintain product safety and quality during storage shall be developed on the basis of risk assessment, understood by relevant staff and implemented accordingly. These may include, as appropriate:• managing chilled and frozen product transfer between temperature-controlled areas• segregation of products where necessary to avoid cross-contamination (physical, microbiological or allergens) or taint uptake• storing materials off the floor and away from walls• specific handling or stacking requirements to prevent product damage.

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4.15.2 Where appropriate, packaging shall be stored away from other raw materials and finished product. Any part-used packaging materials suitable for use shall be effectively protected from contamination and clearly identified to maintain traceability before being returned to an appropriate storage area. Obsolete packaging shall be stored in a separate area and systems shall be in place to prevent accidental use.

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4.15.3 Where temperature control is required, the storage area shall be capable of maintaining product temperature within specification and operated to ensure specified temperatures are maintained. Temperature recording equipment with suitable temperature alarms shall be fitted to all storage facilities or there shall be a system of recorded manual temperature checks, typically on at least a 4-hourly basis or at a frequency which allows for intervention before product temperatures exceed defined limits for the safety, legality or quality of products.

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4.15.4 Where controlled atmosphere storage is required, the storage conditions shall be specified and effectively controlled. Records shall be maintained of the storage conditions.

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4.15.5 Where storage outside is necessary, items shall be protected from contamination and deterioration. Items shall be checked for suitability before being brought into the factory.

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4.15.6 The site shall facilitate correct stock rotation of raw materials, intermediate products and finished products in storage and ensure materials are used in the correct order in relation to their manufacturing date and within the prescribed shelf life.

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4.16.1 Documented procedures to maintain product safety and quality during loading and transportation shall be developed and implemented. These may include, as appropriate:• controlling temperature of loading dock areas• the use of covered bays for vehicle loading or unloading• securing loads on pallets to prevent movement during transit• inspection of loads prior to dispatch.

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4.16.2 All vehicles or containers used for the dispatch of products shall be inspected prior to loading to ensure that they are fit for purpose. This shall ensure that they are:• in a clean condition• free from strong odours which may cause taint to products• in a suitable condition to prevent damage to products during transit• equipped to ensure any temperature requirements can be maintained.Records of inspections shall be maintained.

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4.16.3 Where temperature control is required, the transport shall be capable of maintaining product temperature within specification, under minimum and maximum load. Temperature data-logging devices which can be interrogated to confirm time/temperature conditions or a system to monitor and record at predetermined frequencies the correct operation of refrigeration equipment shall be used and records maintained.

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4.16.4 Maintenance systems and documented cleaning procedures shall be available for all vehicles and equipment used for loading/unloading. There shall be records of the measures taken.

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4.16.5 The company shall have documented procedures for the transport of products, which shall include:• any restrictions on the use of mixed loads• requirements for the security of products during transit, particularly when vehicles are parked and unattended• clear instructions in the case of vehicle breakdown, accident or failure of refrigeration systems, which ensure the safety of the products is assessed and records maintained.

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4.16.6 Where the company employs third-party contractors, all the requirements specified in this section shall be clearly defined in the contract and verified or the contracted company shall be certificated to the Global Standard for Storage and Distribution or similar GFSI-recognised scheme.

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5.1.1 The company shall provide clear guidelines on any restrictions to the scope of new product developments to control the introduction of hazards which would be unacceptable to the site or customers (e.g. the introduction of allergens, glass packaging or microbiological risks).

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5.1.2 All new products and changes to product formulation, packaging or methods of processing shall be formally approved by the HACCP team leader or authorised HACCP committee member. This shall ensure that hazards have been assessed and suitable controls, identified through the HACCP system, are implemented. This approval shall be granted before products are introduced into the factory environment.

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5.1.3 Trials using production equipment shall be carried out where it is necessary to validate that product formulation and manufacturing processes are capable of producing a safe product of the required quality.

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5.1.4 Shelf-life trials shall be undertaken using documented protocols reflecting conditions experienced during storage, transport and handling. Results shall be recorded and retained and shall confirm compliance with relevant microbiological, chemical and organoleptic criteria. Where shelf-life trials prior to production are impractical, for instance for some long-life products, a documented science-based justification for the assigned shelf life shall be produced.

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5.2.1 All products shall be labelled to meet legal requirements for the designated country of use and shall include information to allow the safe handling, display, storage, preparation and use of the product within the food supply chain or by the customer. There shall be a process to verify that ingredient and allergen labelling is correct based on the product recipe.

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5.2.2 There shall be effective processes in place to ensure that labelling information is reviewed whenever changes occur to:• the product recipe• raw materials• the supplier of raw materials• the country of origin of raw materials• legislation

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5.2.3 Where a product is designed to enable a claim to be made to satisfy a consumer group (e.g. a nutritional claim, reduced sugar), the company shall ensure that the product formulation and production process is fully validated to meet the stated claim.

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5.2.4 Where the label information is the responsibility of a customer or a nominated third party the company shall provide:• information to enable the label to be accurately created• information whenever a change occurs which may affect the label information.

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5.3.1 The site shall carry out an assessment of raw materials to establish the presence and likelihood of contamination by allergens (refer to glossary). This shall include review of raw material specifications and, where required, obtain additional information from suppliers, for example through questionnaires to understand the allergen status of the raw material, its ingredients and the factory in which it is produced.

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5.3.2 The company shall identify and list allergen-containing materials handled on site. This shall include raw materials, processing aids, intermediate and finished products, and any new product development ingredients or products.

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5.3.3 A documented risk assessment shall be carried out to identify routes of contamination and establish documented policies and procedures for handling raw materials, intermediate and finished products to ensure cross-contamination is avoided. This shall include:• consideration of the physical state of the allergenic material (i.e. powder, liquid, particulate)• identifi cation of potential points of cross-contamination through the process flow• assessment of the risk of allergen cross-contamination at each process step• identifi cation of suitable controls to reduce or eliminate the risk of cross-contamination.

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5.3.4 Documented procedures shall be established to ensure the effective management of allergenic materials to prevent cross-contamination into products not containing the allergen. This shall include as appropriate:• physical or time segregation while allergen-containing materials are being stored, processed or packed• the use of separate or additional protective overclothing when handling allergenic materials• use of identifi ed, dedicated equipment and utensils for processing• scheduling of production to reduce changes between products containing an allergen and products not containing the allergen• systems to restrict the movement of airborne dust containing allergenic material• waste handling and spillage controls• restrictions on food brought onto site by staff , visitors, contractor

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5.3.5 Where rework is used, or reworking operations are carried out, procedures shall be implemented to ensure rework containing allergens is not used in products that do not already contain the allergen.

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5.3.6 Where the nature of the production process is such that cross-contamination from an allergen cannot be prevented, a warning should be included on the label. National guidelines or codes of practice shall be used when making such a warning statement.

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5.3.7 Where a claim is made regarding the suitability of a food for allergy or food sensitivity sufferers, the site shall ensure that the production process is fully validated to meet the stated claim and the effectiveness of the process is routinely verified. This shall be documented.

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5.3.8 Equipment or area cleaning procedures shall be designed to remove or reduce to acceptable levels any potential cross-contamination by allergens. The cleaning methods shall be validated to ensure they are effective and the effectiveness of the procedure routinely verified. Cleaning equipment used to clean allergenic materials shall either be identifiable and specific for allergen use, single use, or effectively cleaned after use.

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5.4.1 The company shall have processes in place to access information on historical and developing threats to the supply chain which may present a risk of adulteration or substitution of raw materials. Such information may come from:• trade associations• government sources• private resource centres.

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5.4.2 A documented vulnerability assessment shall be carried out on all food raw materials or groups of raw materials to assess the potential risk of adulteration or substitution. This shall take into account:• historical evidence of substitution or adulteration• economic factors which may make adulteration or substitution more attractive• ease of access to raw materials through the supply chain• sophistication of routine testing to identify adulterants• nature of the raw material.The vulnerability assessment shall be kept under review to reflect changing economic circumstances and market intelligence which may alter the potential risk. It shall be formally reviewed annually.

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5.4.3 Where raw materials are identified as being at particular risk of adulteration or substitution appropriate assurance and/or testing processes shall be in place to reduce the risk.

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5.4.4 Where products are labelled or claims are made on finished packs which are dependent on a status of a raw material including:• specific provenance or origin• breed/varietal claims• assured status (e.g. GlobalGAP)• genetically modified organism (GMO) status• identity preserved• named specific trademarked ingredientsthe status of each batch of the raw material shall be verified.The facility shall maintain purchasing records, traceability of raw material usage and final product packing records to substantiate claims. The site shall undertake documented mass balance tests at a frequency to meet the particular scheme requirements or at least every 6 months in the absence of a scheme-specific requirement.

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5.4.5 Where claims are made about the methods of production (e.g. organic, Halal, Kosher) the site shall maintain the necessary certification status in order to make such a claim.

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5.4.6 The process flow for the production of products where claims are made shall be documented and potential areas for contamination or loss of identity identified. Appropriate controls shall be established to ensure the integrity of the product claims.

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5.5.1 When purchasing or specifying food contact packaging the supplier of packaging materials shall be made aware of any particular characteristics of the food (e.g. high fat content, pH or usage conditions such as microwaving) which may affect packaging suitability. Certificates of conformity or other evidence shall be available for product packaging to confirm it complies with relevant food safety legislation and is suitable for its intended use.

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5.5.2 Product liners and bags purchased by the company for use in direct contact with ingredients, or work in process, shall be appropriately coloured and resistant to tearing to prevent accidental contamination.

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5.6.1.1 There shall be a scheduled programme of testing covering products and the processing environment, which may include microbiological, chemical, physical and organoleptic testing according to risk. The methods, frequency and specified limits shall be documented.

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5.6.1.2 Test and inspection results shall be recorded and reviewed regularly to identify trends. The significance of external laboratory results shall be understood and acted upon accordingly. Appropriate actions shall be implemented promptly to address any unsatisfactory results or trends.

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5.6.1.3 The site shall ensure that a system of ongoing shelf-life assessment is in place. This shall be based on risk and shall include sensory analysis and, as applicable, microbiological testing and relevant chemical factors such as pH and aw. Records and results from shelf-life tests shall verify the shelf-life period indicated on the product.

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5.6.2.1 Pathogen testing shall be subcontracted to an external laboratory or, where conducted internally, the laboratory facility shall be fully segregated from the production and storage areas and have operating procedures to prevent any risk of product contamination.

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5.6.2.2 Where routine testing laboratories are present on a manufacturing site, they shall be located, designed and operated to eliminate potential risks to product safety. Controls shall be documented, implemented and shall include consideration of:• design and operation of drainage and ventilation systems• access and security of the facility• movement of laboratory personnel• protective clothing arrangements• processes for obtaining product samples• disposal of laboratory waste.

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5.6.2.3 Where the company undertakes or subcontracts analyses which are critical to product safety or legality, the laboratory or subcontractors shall have gained recognised laboratory accreditation or operate in accordance with the requirements and principles of ISO/IEC 17025. Documented justification shall be available where accredited methods are not undertaken.

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5.6.2.4 Procedures shall be in place to ensure reliability of laboratory results, other than those critical to safety and legality specified in clause 5.6.2.3. These shall include:• use of recognised test methods, where available• documented testing procedures• ensuring staff are suitably qualified and/or trained and competent to carry out the analysis required• use of a system to verify the accuracy of test results (e.g. ring or proficiency testing)• use of appropriately calibrated and maintained equipment.

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5.7.1 Where products require positive release, procedures shall be in place to ensure that release does not occur until all release criteria have been completed and release authorised.

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6.1.1 Documented process specifications and work instructions shall be available for the key processes in the production of products to ensure product safety, legality and quality. The specifications as appropriate shall include:• recipes – including identification of any allergens• mixing instructions, speed, time• equipment process settings• cooking times and temperatures• cooling times and temperatures• labelling instructions• coding and shelf-life marking• any additional critical control points identified in the HACCP plan.Process specifications shall be in accordance with the agreed finished product specification.

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6.1.2 Process monitoring, such as of temperature, time, pressure and chemical properties, shall be implemented, adequately controlled and recorded to ensure that product is produced within the required process specification.

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6.1.3 In circumstances where process parameters or product quality are controlled by in-line monitoring devices, these shall be linked to a suitable failure alert system that is routinely tested.

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6.1.4 Where variation in processing conditions may occur within equipment critical to the safety or quality of products, the processing characteristics shall be validated and verified at a frequency based on risk and performance of equipment (e.g. heat distribution in retorts, ovens and processing vessels; temperature distribution in freezers and cold stores).

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6.1.5 In the case of equipment failure or deviation of the process from specification, procedures shall be in place to establish the safety status and quality of the product to determine the action to be taken.

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6.2.1 There shall be a formal process for the allocation of packaging materials to packing lines and control in the packing area which ensures that only the packaging for immediate use is available to the packaging machines. Where off -line coding or printing of packaging materials occurs, checks shall be in place that only correctly printed material is available at the packaging machines.

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6.2.2 Documented checks of the production line shall be carried out before commencing production and following changes of product. These shall ensure that lines have been suitably cleared and are ready for production. Documented checks shall be carried out at product changes to ensure all products and packaging from the previous production have been removed from the line before changing to the next production.

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6.2.3 Documented procedures shall be in place to ensure that products are packed into the correct packaging and correctly labelled. These shall include checks:• at the start of packing• during the packing run• when changing batches of packaging materials• at the end of each production run.The checks shall also include verification of any printing carried out at the packing stage including, as appropriate:• date coding• batch coding• quantity indication• pricing information• bar coding• country of origin.

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6.2.4 Where on-line vision equipment is used to check product labels and printing, procedures shall be in place to ensure that the system is correctly set up and capable of alerting or rejecting product when packaging information is out of specification.

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6.3.1 The frequency and methodology of quantity checking shall meet the requirements of appropriate legislation governing quantity verification, and records of checks shall be retained.

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6.3.2 Where the quantity of the product is not governed by legislative requirements (e.g. bulk quantity), the product must conform to customer requirements and records shall be maintained.

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6.4.1 The site shall identify and control measuring equipment used to monitor critical control points, product safety and legality. This shall include as a minimum:• a documented list of equipment and its location• an identification code and calibration due date• prevention from adjustment by unauthorised staff• protection from damage, deterioration or misuse.

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6.4.2 All identified measuring devices, including new equipment, shall be checked and where necessary adjusted:• at a predetermined frequency, based on risk assessment• to a defined method traceable to a recognised national or international standard where possible.Results shall be documented. Equipment shall be readable and be of a suitable accuracy for the measurements it is required to perform.

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6.4.3 Reference measuring equipment shall be calibrated and traceable to a recognised national or international standard and records maintained. The uncertainty of calibration shall be considered when equipment is used to assess critical limits.

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6.4.4 Procedures shall be in place to record actions to be taken when the prescribed measuring devices are found not to be operating within specified limits. Where the safety or legality of products is based on equipment found to be inaccurate, action shall be taken to ensure at-risk product is not offered for sale.

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7.1.1 All relevant personnel, including agency-supplied staff, temporary staff and contractors, shall be appropriately trained prior to commencing work and adequately supervised throughout the working period.

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7.1.2 Where personnel are engaged in activities relating to critical control points, relevant training and competency assessment shall be in place.

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7.1.3 The site shall put in place documented programmes covering the training needs of relevant personnel. These shall include as a minimum:• identifying the necessary competencies for specifi c roles• providing training or other action to ensure staff have the necessary competencies• reviewing the eff ectiveness of training• the delivery of training in the appropriate language of trainees.

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7.1.4 All relevant personnel, including engineers, agency-supplied staff and temporary staff and contractors, shall have received general allergen awareness training and be trained in the site’s allergen-handling procedures.

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7.1.5 Records of all training shall be available. This shall include as a minimum:• the name of the trainee and confirmation of attendance• the date and duration of the training• the title or course contents, as appropriate• the training provider.Where training is undertaken by agencies on behalf of the company, records of the training shall be available.

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7.1.6 The company shall routinely review the competencies of its staff. As appropriate, it shall provide relevant training. This may be in the form of training, refresher training, coaching, mentoring or on-the-job experience.

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7.2.1 The requirements for personal hygiene shall be documented and communicated to all personnel. This shall include as a minimum the following requirements:• watches shall not be worn• jewellery shall not be worn, with the exception of a plain wedding ring or wedding wristband• rings and studs in exposed parts of the body, such as ears, noses, tongues and eyebrows, shall not be worn• fingernails shall be kept short, clean and unvarnished• false fingernails and nail art shall not be permitted• excessive perfume or aftershave shall not be worn.• Compliance with the requirements shall be checked routinely.

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7.2.2 Hand-washing shall be performed on entry to the production areas and at a frequency that is appropriate to minimise the risk of product contamination.

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7.2.3 All cuts and grazes on exposed skin shall be covered by an appropriately coloured plaster that is different from the product colour (preferably blue) and contains a metal detectable strip. These shall be site issued and monitored. Where appropriate, in addition to the plaster, a glove shall be worn.

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7.2.4 Where metal detection equipment is used, a sample from each batch of plasters shall be successfully tested through the equipment and records shall be kept.

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7.2.5 Processes and written instructions for staff shall be in place to control the use and storage of personal medicines, so as to minimise the risk of product contamination.

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7.3.1 The site shall make employees aware of the symptoms of infection, disease or condition which would prevent a person working with open food. The site shall have a procedure which enables notification by employees, including temporary employees, of any relevant symptoms, infection, disease or condition with which they may have been in contact or be suffering from.

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7.3.2 Where there may be a risk to product safety, visitors and contractors shall be made aware of the types of symptoms, infection, disease or condition which would prevent a person visiting areas with open food. Where permitted by law, visitors shall be required to complete a health questionnaire or otherwise confirm that they are not suffering from any symptoms which may put product safety at risk, prior to entering the raw material, preparation, processing, packing and storage areas.

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7.3.3 There shall be documented procedures for employees, contractors and visitors relating to action to be taken where they may be suffering from or have been in contact with an infectious disease. Expert medical advice shall be sought where required.

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7.4.1 The company shall document and communicate to all employees (including agency and temporary personnel), contractors or visitors the rules regarding the wearing of protective clothing in specified work areas (e.g. high-care or high-risk areas). This shall also include policies relating to the wearing of protective clothing away from the production environment (e.g. removal before entering toilets, use of canteen and smoking areas).

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7.4.2 Protective clothing shall be available that:• is provided in sufficient numbers for each employee• is of suitable design to prevent contamination of the product (as a minimum containing no external pockets above the waist or sewn-on buttons)• fully contains all scalp hair to prevent product contamination• includes snoods for beards and moustaches, where required, to prevent product contamination.

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7.4.3 Laundering of protective clothing shall take place by an approved contracted or in-house laundry using defined criteria to validate the effectiveness of the laundering process. The laundry must operate procedures which ensure:• adequate segregation between dirty and cleaned clothes• effective cleaning of the protective clothing• protective clothing for high-risk or high-care areas is commercially sterile following the washing and drying process• cleaned clothes are supplied protected from contamination until use (e.g. by the use of covers or bags).Washing of protective clothing by the employee is exceptional but shall be acceptable where the protective clothing is to protect the employee from the products handled and the clothing is worn in enclosed product or low-risk areas only.

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7.4.4 Where protective clothing for high-care or high-risk areas is cleaned by a contracted or in-house laundry, this shall be audited either directly or by a third party. The frequency of these audits should be based on risk.

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7.4.5 Protective clothing shall be changed at an appropriate frequency, based on risk. For high-risk and high-care areas the protective clothing shall be changed at least daily.

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7.4.6 If gloves are used, they shall be replaced regularly. Where appropriate, gloves shall be suitable for food use, of a disposable type, of a distinctive colour (blue where possible), be intact and not shed loose fibres.

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7.4.7 Where items of personal protective clothing that are not suitable for laundering are provided (such as chain mail, gloves and aprons), these shall be cleaned and sanitised at a frequency based on risk.

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General Comments

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Brc standard for food
safety - internal assessment checklist

General > Brc standard for food safety - internal assessment checklist

Anonymous User

This template can be used by managers to determine the readiness of the business to get certified for the brc standard for food safety. use this checklist to help assess how close is the business to meeting the 7 requirements of brc version 7.

I. Senior Management Commitment

II. The Food Safety Plan – HACCP

III. Food safety and quality management system

IV. Site Standards

V. Product control

VI. Process Control

VII. Personnel

Completion

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