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This document summarises our Food Safety policy, outlines our management system and details our key objectives and key principles for managing food safety. The priorities we place on Food Safety is based on our belief and experience that commercial success and good food safety practice and performance are longterm compatible goals. The intent of the policy is to provide a safe and healthy workplace for employees and to protect the food chain. We employ a systematic best practice review process to ensure Food Safety at all stages we are involved within the food chain. XYZ Foods operate a food safety management system based around HACCP and designed to control all Critical Control Points The HACCP is produced by following the Codex Alimentarius code of practice and using the most up to date EU legislation. XYZ Foods has the responsibility and authority for assuring compliance with appropriate regulatory law or guidelines. These shall be clearly assigned to a competent supervisory-level person or persons, and a functional organisational chart shall be maintained. The competent supervisory-level person shall ensure that all employees are aware of their responsibilities and mechanisms are in place to monitor the effectiveness of their operation. The company food safety policy statement will be placed in a suitably visible position and communicated to all staff during their induction training. A positive food safety culture is encouraged within the organisation and is actively supported by senior management. XYZ is committed to conducting its business taking all responsible precautions and ensuring due diligence is exercised to protect and preserve the human food chain at all stages of involvement. Allied is committed to conducting its business taking all responsible precautions and ensuring due diligence is exercised to protect and preserve the human food chain at all stages of involvement.
This section describes XYZ food safety management system that has been developed to assist the company in its quest to continually seek improvements in its food safety performance. Figure 2 below shows the key elements of an effective management system. The international food safety management system standard EN ISO 22000:2005 has been used as best practice and provides the structure of this document
XYZ will ensure that: We comply with the requirements of all relevant food legislation and approved codes of practice; We implement the principles of HACCP as appropriate at food handling locations, clearly setting out the appropriate control and monitoring measures to be exercised to safeguard the food chain; We commit to the development and maintenance of appropriate systems and controls in conjunction with interested third parties, and ensure these are adequately communicated to all XYZ workers in the food chain.
A procedure is in place to ensure that food safety documentation is available to those who need it. Documentation is periodically reviewed, revised as necessary and approved for adequacy by authorised personnel. Records that require maintaining for legal and knowledge preservation purposes are identified.
Management commitment to Food Safety is demonstrated in a number of ways: Food Safety, Health & Environment Committee: This committee comprises XYZ senior management team. This committee and other sub-committees are committed to reviewing and improving performance in the areas of Food Safety and Occupational Health, Safety and the Environment. Management Review: The senior management team shall review the suitability, adequacy and effectiveness of the Food Safety Management System. The management team will assess opportunities for improvement and the need for changes to the food safety management system, including the food safety
policy. The details will be communicated to the board by the monthly Dash Board Showing and demonstrating support: Senior management will provide leadership in Food Safety by: Setting appropriate goals and objectives that support and provide direction to the business on food safety aspects and issues.
5.4.2 Quality Assurance Manager Responsible for all food safety and hygiene for XYZ Foods ensuring at all sites staff are adhering to food hygiene legislation and following the HACCP plan for the site/contract and will ensure that the site managers provide sufficient
resources, in terms of personnel & equipment, are employed in order to achieve the required performance levels. Responsible for maintaining and improving the food safety management system and will also ensure the integrity of the food safety management system is maintained when business changes are made Will have developed the HACCP plan with each of the sites and will have knowledge of the site HACCP plan and an understanding of its importance. Responsible for communication on all food safety related matters and ensuring the company is informed of any legislation updates. 5.4.3 Local Level GENERAL MANAGERResponsible for all food safety and hygiene for site/contract ensuring all staff are adhering to food hygiene legislation and following the HACCP plan for site/contract. The GM will ensure that sufficient resources in terms of personnel & equipment are employed in order to achieve the required performance levels. Responsible for maintaining and improving the food safety management system and will ensure the integrity of the food safety management system is maintained when business changes are made. Will have knowledge of the site HACCP plan and an understanding of its importance. FIRST LINE MANAGERS / TEAM LEADERS Responsible for the supervision of staff with regard to food hygiene in your area, ensuring all staff are adhering to food hygiene legislation and following the HACCP plan for the site. Will have knowledge of the site HACCP plan and an understanding of its importance.
Will be a member of the HACCP team and is responsible for ensuring the HACCP plan is followed and any area identified as a potential breach in food hygiene or safety is logged and corrective action taken and documented
Regularly monitor documentation that may indicate trends of non-conformance and recommend corrective actions , ALL EMPLOYEES - GENERAL RESPONSIBILITIES Responsible for adhering to food hygiene relevant to your role and adhering to the site/contract HACCP plan. All staff must take ownership of the food safety and hygiene systems in operation. All Employees: Are responsible for adhering to food hygiene relevant to your role and adhering to the HACCP plan for the site. Adhere to food safety instructions Operate hygienically Report any problems relating to food safety or a failure in control measures Comply with the law. Work in accordance with any training or instruction given. Follow any food safety arrangements and rules established for the protection of the food chain. Make use of any food safety or protective equipment or devices supplied. Food handlers are expected to report illnesses that may impact on food safety. NOTE: Breaches of Food Safety rules will be handled through the Company disciplinary procedure in the same manner as any other breach of Company rules
5.6 COMMUNICATION
5.6.1 EXTERNAL COMMUNICATION It is important that we ensure sufficient information on issues concerning food safety is available throughout the food chain and, in order to do this, we have identified a number of key relationships that we intend to maintain: Suppliers and Contractors: All our suppliers will complete questionnaire and undergo a vetting and monitoring processes that ensures they have effective food safety arrangements in place. All contractors are briefed on food safety requirements before work commences. Customers: XYZ will, in collaboration with its customer, continuously examine the latest industry techniques, technology and equipment with a view to improving food safety performance. Such improvements may be required as a result of new or changing legislation. If Allied takes on additional work or contracts work out the process or company will be audited to ensure the food safety procedures are safe. Statutory and regulatory authorities: We have a procedure to record and communicate within the business all aspects of working with statutory and regulatory authorities. All commitments and plans agreed are documented and communicated to the central health and safety team in the monthly board report. Professional bodies: We work closely with consultancies, training providers and many other advisory bodies to ensure that we keep abreast of changing legislation and best practices in the area of food safety.
5.6.2 INTERNAL COMMUNICATION It is company policy to establish a HACCP team for all food sites The objectives of the HACCP team meetings are: Monthly Food Safety Review Meetings will take place to review food safety performance, although attendees may vary, generally attendees will include: Food Safety Representative Contract/General Manager As required, representatives from Warehouse, Stock and Admin and Transport management. As required, representatives from the shop floor. Note, this may be a separate meeting or may form part of a management team meeting or health and safety meeting. The following will items be discussed where applicable: Results from audits Review of HACCP system records and results Complaints involving food safety Local document amendments Corrective Actions Examine the site incidents involving food safety. Study food safety statistics and trends so that joint agreement can be reached on remedial measures. Examine food safety inspection reports. Discuss cleaning and sanitation programmes. Assist in developing site HACCP plans. Conduct (ideally as part of the Committee Meeting) periodic inspections of food safety arrangements. Monitor the effectiveness of food safety training, communication, publicity and signage. Discuss and resolve any problems that have previously been raised directly between safety representatives and management, but without resolution .
Food Safety Incidents A food safety incident can be considered as: An event which has potentially harmful implications to the public resulting from the consumption of food The identification of contaminated foodstuffs, that if consumed may lead to illness. The identification of serious human illness that may be linked to contaminated foods. The identification of unhygienic practices in a food business of such a degree as to present an immediate danger to consumers health. The identification of irregular or illegal practices in any food business or in the distribution network that could pose a threat to consumers health. Biological or chemical contamination resulting from deliberate tampering or a terrorist event. A process is in place to ensure that the business can, in the event of a major food safety incident occurring, ensure that the following activities are carried out: Deal with the incident effectively: Audit suppliers if necessary: Report to the relevant enforcing authority: Communicate effectively, both within the company and with local emergency teams, authorities and the community, as appropriate. Investigate the cause of the incident and learn lessons from it.
6. RESOURCE MANAGEMENT
A process is in place to ensure that all staff including permanent, temporary and agency staff, at all levels in the company receive appropriate training. A site induction procedure ensures that all new workers receive appropriate food safety training. The site HACCP team will be required to attend a HACCP workshop covering basic food hygiene, the food safety manual and the audit process. Staff holding Food Safety positions within the company will be competent to carry out their tasks. A system is in place for informing contractors and sub contractors of specific food safety requirements and hazards on site. This may take several forms including formal briefings, food safety reviews, Customer briefings etc. as appropriate. Managers will receive training in their food safety responsibilities under the law, the XYZ Food Safety Management Standards and Customer demands as
XYZ site HACCP members will receive training in their food safety responsibilities. This will cover, as a minimum, compliance with legislation, Company policy and the minimum safety standards document and its associated procedures. XYZ employees will be trained in XYZ Site Specific Procedures as necessary, and this training documented in individual training records. Such training may include the role of packaging in food preservation, vehicle hygiene, good housekeeping, etc. Figure 3 - Summary of Training Requirements MANAGERS AND SUPERVISORS SUBJECTS TO BE COVERED Legal obligations Food microbiology Food poisoning vectors Principle of hazard analysis Effective temperature control techniques Control of visitors to site Industry guidance is instruction of 6-12 hours duration WAREHOUSE PERSONNEL AND DRIVERS SUBJECTS TO BE COVERED Stock rotation Role of packaging in food preservation Cool chain maintenance, statutory standards Good housekeeping Standards Vehicle hygiene (drivers) Industry guidance is instruction of 4-8 hours duration
Quality Management Safety, Health and Environmental Management System Planned preventive maintenance Pest Control Foreign Body Detection / Identification Temperature Control Traceability
A HACCP plan will be established which will, as a minimum, include the following for each critical control point (CCP): a) Food safety hazards to be controlled at the CCP. b) Control measures. c) Critical limits. d) Monitoring procedure(s). e) Corrections and corrective actions to be taken of critical limits are exceeded. f) Responsibilities and authorities. g) Records of monitoring.
The principles of HACCP are used to: Identify food safety hazards and determine acceptable levels. Assess hazard to determine, for each food safety hazard identified, whether its elimination or reduction to acceptable levels is essential to food safety. Select and assess an appropriate combination of control measures capable of preventing, eliminating or reducing food safety hazards to acceptable levels. Control measures may be managed through PRPs or HACCP plans. Establish a documented HACCP plan, see below. A HACCP plan will be established which will, as a minimum, include the following for each critical control point (CCP): a) Food safety hazards to be controlled at the CCP. b) Control measures. c) Critical limits. d) Monitoring procedure(s). e) Corrections and corrective actions to be taken of critical limits are exceeded. f) Responsibilities and authorities. g) Records of monitoring.
7.6 VERIFICATION
The HACCP team (multidisciplinary in membership) will operate on a predetermined frequency, conducting complete inspections of the entire facility no less than once per month. Records of each inspection are an integral part of this requirement, and documentation of specific assignments and actual accomplishments shall be maintained. Follow-up inspections should be done to ensure that items are corrected. Regularly monitor documentation that may indicate trends of non-conformance and recommend corrective actions Ensure that all staff are aware of the food safety system in place, and that food hygiene maintains a high standard
Procedures are in place for the control of non-conforming material, including rejection, acceptance by concession, or re-grading for an alternative use. Such procedures are implemented and worker made aware. Non-conformities will include, but not be limited to, temperature rejections, delivery times, damages, overs/shorts, and poor palletisation/packaging. All nonconforming products are handled or disposed of according to the nature of the problem and/or the specific requirements of the Customer. Procedures are in place to investigate (i.e. determine cause and consequence) and ensure final disposition by authorised person(s). Corrective action systems are established to identify and eliminate the cause of detected nonconformities, to prevent recurrence, and to bring the process or system back in control after nonconformity is encountered. Corrective actions are documented and effective records maintained. Such actions will include:
Reviewing nonconformities (including customer complaints). Reviewing trends in monitoring results that may indicate development towards loss of control. Determining the cause(s) of nonconformities. Evaluating the need for action to ensure that nonconformities do not reoccur. Determining and implementing the actions needed. Recording the results of action taken. Reviewing corrective actions taken to ensure they are effective. Corrective actions shall be recorded. Trend analysis will also be used to reveal non-compliance. Corrective actions will be discussed and agreed at regular food safety meetings. Trends will be monitored but not limited to those categories identified by HACCP Analysis.
Following a review of current food safety issues, management may identify actions designed to improve food safety at Allied. Such actions may be in the form of individual action items; through to establishing working groups, projects, initiatives or programmes. Food safety performance is measured and monitored to determine whether: Food safety policy statement and related objectives are being achieved. Corrective and preventive actions are implemented and are effective. Lessons are learned from food safety failures including near misses, illnesses, product recalls and major incidents. Awareness, training, communication and consultation programmes for employees and interested parties are effective. Committee Initiatives and activities are delivered on time and are effective. Information and data from review and monitoring processes are being produced and being used.
Proactive and reactive monitoring methods are used. Proactive methods include audits, self-assessments, site food safety tours and reactive methods may include environmental health reports. A number of measurement techniques are used as follows: Results of hazard identification, risk assessment and risk control processes. Systematic and regular self-assessments against established minimum food safety standards. Desktop exercises. Benchmark against industry standards. A variety of food safety equipment is used and is calibrated according to manufacturers instruction.
The board review this Food Safety Management System Manual annually and will update other Food Safety Procedures as necessary.