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How to structure your preventive controls food safety plan…

In this post we’re going to go through how to structure your preventive controls food safety plan, using the risk assessments that we’ve completed in the previous posts:
Supply-chain preventive controls
Allergen preventive controls
Sanitation preventive controls
Process preventive controls
Putting all the above risk assessments, with the resulting preventive controls and your recall plan – together, make up your preventive controls food safety plan. It is useful to have all the information displayed in one folder.

 

The FSPCA suggest that the front of this folder includes all the background information that you should gather to be able to produce your food safety plan.  Although this isn’t part of the FDA’s rule, it is a suggestion from the FSPCA.  This information would be the type of information you would typically see in the scope and terms of reference for a HACCP plan, such as:

  • Scope
  • Product description (including intended use, intended user etc.)
  • Process flow diagram
  • Process description

Therefore, the sections of the folder may go like this:

  1. Background information
  2. Allergens:
    • Allergen risk assessment
    • Preventive controls summary
    • Preventive controls monitoring procedures and records
  3.  Sanitation:
    • Zoning assessment
    • Sanitation risk assessment
    • Preventive controls summary
    • Preventive controls monitoring procedures and records
  4.  Supply-chain:
    • Raw material risk assessment
    • Supplier risk assessment
    • Preventive controls summary
    • Preventive controls monitoring procedures and records
  5.  Process:
    • Process flow risk assessment
    • Preventive controls summary
    • Preventive controls monitoring procedures and records
    • Process preventive controls summary (CCPs)
    • Process preventive controls (CCP) monitoring procedures and records
    • Process preventive controls validations
  6. Recall plan
  7. Review/re-analyse

It makes sense to me to have the allergen, sanitation and supply-chain elements before the process flow driven risk assessment.  This is because the results from the allergen, sanitation and supply-chain risk assessments are needed, to feed into the process flow driven risk assessment. For example, you need to understand what allergens you have on site, which products they are in and what process steps in the process flow are at risk from allergen cross-contact – in order to put the relevant hazard in the right place in the process driven risk assessment.

In the same way, you need to understand, what hazards are relevant from your raw material risk assessment (from your supply-chain section), to assess them effectively through the process flow. Plus, you would need to understand the zoning for the facility, before you can establish what hazards are relevant at points such as transfer into high hygiene areas.

By doing each of these risk assessments first, and adding it to the information gathered in the background information section, this should provide you with the detail you need to do the process flow driven assessment effectively. Structuring your preventive controls food safety plan in this manner will help you to make sure you’re got all of the elements covered.  I found it also helped me understand and appreciate what the FDA are looking for. Essentially, they are expecting facilities to develop their own food safety management system – a bit like the what we would usually term as a ‘Quality Management System’ (QMS), but just focused on food safety.

By putting the folder together in this way, you have pulled out of your QMS the elements that FDA expect to meet the rule.  What remains in your QMS are the quality and legal elements, with the exception of perhaps one element – your glass and hard plastic risk assessment…

In my opinion, there may be some process driven preventive controls that are due to glass and hard plastic hazards. To be able to feed this information into your process driven risk assessment, the glass and hard plastic register and risk assessment would need adding to the folder – as a separate section, perhaps called ‘foreign body’.  However, this currently isn’t a requirement of the FDA – but perhaps it will become part of the rule in the future?

We have a number of documentation packs that will help with the elements of the folder  – check these out below…

preventive controls food safety plan
preventive controls food safety plan
preventive controls food safety plan

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