In this article we’re going to look at what is required to implement the FSSC Transport and Storage Standard.

This is the last in this series of articles, where we look at the FSSC22000 Standards and review them for implementation.  In the previous articles we have covered:

 

Also, if you’d like to look at our previous series of articles which compares the BRCGS and the IFS Standards, they’re all here for you:

 

FSSC22000 Transport and Storage

In the FSSC Food review for implementation article we explained that we can’t compare the FSSC and BRCGS Standards, in the same way that we did for IFS. Because it’s like comparing apples and pears. We also explained the benefits and pitfalls of going with the FSSC Standard.

For this reason, we’re not comparing the Standards, but instead we’re providing you with a summary of what is needed under each of the 18 topic headings.

The FSSC22000 Transport and Storage Standard is made up of the following:

  • FSSC22000 Standard
  • ISO9001
  • ISO22000
  • NTA 8059:2016 (Technical specification)

Under each of the 18 topics, we’ve split a summary of the requirements for ISO (9001 and 22000), FSSC and also the transport and storage technical specification.

 

1. Senior management commitment

ISO

There must be effective communication systems in place. This includes receiving information from external sources and feeding that information through the relevant internal channels.

Senior management must ensure that a Quality Policy is in place, along with the resources to achieve it. Roles, responsibilities and management are required and there must be a system of continuous improvement including management review.

Management must appoint a competent person to manage the management system and this role must have the required authority to lead its continuous improvement.

2. Document management

ISO

Before the management system is developed there are a number of pieces of work that are needed, to establish:

  • What is the purpose of the management system.
  • What the management system is expected to achieve.
  • What the boundaries are to the system (scope).
  • Identify the risks and opportunities that need addressing.

Once this is done, a plan must be put in place to:

  • Ensure that all the above points are met.
  • To develop and implement a change management system.
  • To set, communicate and then monitor objectives to ensure that the management system is effective.
  • Ensure that all the required resources are provided to achieve the above.

When the management system is developed or managed externally, the application and day-to-day management must remain the responsibility of the company.

There is a specific section for customer focus to ensure that customer requirements are met.

3. Continuous improvement

ISO

Non-conforming product process is required.

Internal audits are required.

Corrective and preventive actions are needed. Root cause analysis is not specifically mentioned but implied through the need to determine the cause of non-conformances to establish preventive actions.

Continuous improvement is a key focus and covers all aspects of the Standard.

Transport and storage technical specification

A non-conforming product procedure required.

4. Contingency

ISO

Contingency plans for emergency situations and recall and withdrawal processes are required.

Transport and storage technical specification

Withdrawal procedures are required.

5. Hazard analysis

ISO

The hazard analysis system must include OPRP’s (operational prerequisites). Hazards do not highlight radiological specifically. Hazard analysis is required for food safety purposes only; quality does not require hazard analysis.

A process is required for handling products that are out of specification because they are unsafe.

Transport and storage technical specification

PRP’s (prerequisite procedures) must be implemented to protect the product and this includes from radiological contamination.

6. Contamination control

FSSC

An allergen risk management system is required.

Transport and storage technical specification

  • Utilities must not pose a risk of contamination, including water, boiler chemicals, air and ventilation.
  • Chemicals and processing aids must be identifiable, segregated and secure, and approved for use.
  • Microbiological, allergenic, chemical, radiological and physical contamination controls must be in place.

7. Product development

FSSC

Labelling must meet the legal requirements for the country where the product will be sold.

ISO

A product development process is required which ensures that quality objectives and customer requirements are met, including:

  • Planning
  • Inputs and outputs of the system
  • Review
  • Verification and validation
  • And change management

8. Supplier management

ISO

Where suppliers are used for systems, products or services which relate to the management system they must be selected based on set criteria and then monitored.

The system must verify that purchased materials comply with specification.

Transport and storage technical specification

  • Supplier selection, approval and monitoring is required to ensure that materials meet specification.
  • Materials must be covered by a certificate of conformance as a minimum.

9. Testing

FSSC

External labs used for product safety testing must comply with ISO17025 requirements.

A risk based environmental monitoring programme is required for food and packaging sites.

A system of monitoring, measuring and analysis needs to be implemented, which ensures that the product and process meets specification.

Monitoring equipment must be accurate.

Customer satisfaction must be measured.

10. Maintenance

Transport and storage technical specification

  • Equipment must be of a hygienic design.
  • Planned preventive maintenance is required.
  • Corrective maintenance must be controlled.
  • Product contact lubricants must be food grade.
  • Hand back procedure needed.

11. Product defence

FSSC

Both a threat assessment and also a vulnerability assessment is required. There is now a new FSSC guideline about how product defence should be handled, which is similar to an interpretation guide.

Transport and storage technical specification

There must be controls in place for food defence of the site, transport and distribution.

12. Training

ISO

Personnel who work internally or who support externally, must be competent in their role. The company must set the competency required and then ensure that this is met.

Competency must include an understanding of:

  • The food safety policy.
  • Objectives application to their role.
  • How they contribute to the management system.
  • The benefits of getting it right and the consequences of getting it wrong.

13. Personnel

ISO

There is a specific section of the Standard about resources. To ensure that the required resources are provided to meet the needs of the management system and in the case of personnel, they must be competent.

It also states that the work environment that is provided for personnel must be suitable.

This means it must be suitable from:

  • An ethical perspective (e.g. regarding discrimination)
  • A physiological perspective (e.g. mental health)
  • A health and well being perspective (e.g. noise, temperature)

Transport and storage technical specification

  • Hygienic staff facilities must be provided, including toilets, handwashing, changing facilities and staff eating areas.
  • Rules must state how personal hygiene and behaviour is managed, including smoking, eating, personal items and medicines.
  • Product contact equipment must not be lockers.
  • Nail polish, false nails and eyelashes are not allowed, you’re not allowed to carry a pen behind your ear and lockers must be kept clean if you work in open product areas.
  • Personnel who handle unpacked product must wear protective clothing, which is maintained and doesn’t have buttons or outside pockets above the waist.
  • Personnel who work in food areas must wash their hands and keep fingernails short.
  • Medical screening is required.

14. Site standards

ISO

Also within the resources section, the company must provide the resources needed to ensure that the physical infrastructure of the site is fit for purpose and maintained.

Transport and storage technical specification

  • Building construction must be fit for purpose and maintained.
  • Assessment of the local area must be carried out.
  • The site must be maintained.
  • Layouts and flow must adhere to good hygiene practices.
  • Internal fabrication must be fit for purpose and maintained.
  • Equipment must be located so that it can be cleaned and maintained.
  • Lighting must be adequate.

15. Microbiologically controlled facilities

Not mentioned specifically.

16. Hygiene

ISO

Customer property (product) that is unsuitable for use must be controlled.

Transport and storage technical specification

  • Waste must be controlled; identified, segregated, located in a designated area, fit for purpose so they can be cleaned, closed when not in use and locked where needed.
  • Drainage must be managed hygienically.
  • A cleaning programme is required for facilities and equipment, including frequency, responsibility, method, tools, monitoring and inspection/verification.
  • A pest management system is required.
  • Canopies over loading areas are required for pest control and to protect the product from weather.

17. Process control

ISO

Operational processes are required, suitable to the operation. This includes traceability.

Transport and storage technical specification

Traceability is required throughout the process (They call this ‘product identification’ and they call the trace/batch code an ‘identifier’).

18. Storage and distribution

FSSC

Transport and system conditions must minimise the risk to product.

ISO

  • A positive release process is required.
  • The product must be preserved and protected.

Transport and storage technical specification

  • Materials must be protected from contamination during storage and transport and cleaned inbetween loads where needed.
  • Hygiene and integrity checks must be carried out before loading and unloading.
  • Previous loads and cleaning of bulk container checks are required.
  • Warehousing and transport environmental conditions, including temperature must be controlled.
  • Stock rotation must be in place.
  • Storage must be secure.
  • Vehicle maintenance and emergency procedures are needed.
  • Gasoline or diesel not to be used for equipment where product is stored.
  • Cross-docking and transhipment must comply with the requirements listed.

Summary

  • FSSC requires the implementation of many documents; FSSC22000, ISO 22000, ISO 9001 and for transport and storage the NTA 5089 (please note; when we refer to ‘FSSC’ in this summary we mean FSSC and all the associated documents).
  • When reading through the different sections and requirements, there’s nothing really that stands out as different – other than needing aspects such as OPRP’s.
  • The way a management system for FSSC needs to be put together is totally different to BRCGS.
  • It requires a great deal of initial preparation and much more focus on establishing and developing the needed controls.
  • There is a ‘flow’ throughout the Standard. Everything you do for FSSC has a purpose; an input and an output. The output of which then leads into the input of the next requirement.
  • This ‘input and output’ theory could be drawn as a flow chart and is a totally different way of thinking from BRCGS.
  • The language used in FSSC is difficult to read and understand.
  • The requirements are very brief as they are all based on risk, so it’s very open to interpretation (rightly or wrongly) and there is no interpretation guide.
  • There is more detail in the NTA 8059 technical specification for transport and storage, than the other technical specs for food and packaging. Some requirements are very prescriptive, for example; not wearing pens behind your ears, which we thought was an interesting point to pick out!

 

What do you think?

So, what are your thoughts on FSSC and the work that would be needed?

What do you think about the additional requirements?

What do you think about the topics that are not included?

Share your thoughts with your fellow techie’s and add them to the comments box below.

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