Title Page
-
Document No.
-
Audit Title - Foreign Matter M&S Only
-
Client / Site - Tamarfoods
-
Conducted on
-
Prepared by - Debra Phipps
-
Location
-
Personnel
-
Summary;
M&S FOREIGN BODY PREVENTION: METAL February 2016 v9
M&S 1.1Preventative Measures
-
1.1.1 Essential Requirement: Planned Preventative Maintenance (PPM) (i) A documented PPM programme must be in place with the aim of limiting wear
-
(ii) The PPM system must include arrangements for ensuring that jobs are raised and completed on time and highlight if they are not carried out regardless of the reason.
-
(iii) Engineers must be trained to competently carry out planned maintenance on the equipment in the factory.
-
(iv) The PPM system must include frequent in-depth visual checks on critical machinery components in order to identify damage, metal-on-metal contact or wear. These checks must be documented together with a record of any necessary corrective action taken.
-
(v) The documented PPM system must be kept up to date to ensure it reflects the equipment that is present in the factory and incorporates any changes in the frequency or nature of PPM activities.
-
1.1.2 Engineering Practices and Facilities (i) Engineering practices must not compromise the safety or quality of Marks and Spencer products. All contractors working on site must be on a documented approved contractor list and site food safety requirements must be communicated to each person working on site prior to them entering food storage, handling or manufacturing areas.
-
(ii) Welding, drilling, riveting and soldering must not take place on any plant whilst being used for production or any plant immediately adjacent, unless suitable hygienic screening is in place and a documented pre-engineering work risk assessment has been adequately completed.
-
(iii) Missing fixings on equipment must be accounted for and/or replaced.
-
(iv) Workshops and engineering equipment must be maintained in a clean condition.
-
(v) Engineer’s tool boxes must be kept clean internally and free from unnecessary extraneous matter which could be hazardous to production i.e. foreign bodies, allergens etc.
-
(vi) Thorough cleaning must be carried out following engineering work. Cleaning procedures, including hand backs to production, must be developed and implemented after maintenance and/or repair operations.
-
(vii) Equipment repaired in the workshop must be thoroughly cleaned to remove all debris before being returned to production areas.
-
(viii) Documentation following engineering work must be in place to confirm that:- Cleaning has occurred in accordance with standard operating procedures. Production, Technical or QA personnel have visually checked to confirm that production lines are clean and production may recommence.
-
(ix) All welding must be continuous and ground smooth.
-
(x) Engineers must be involved in every investigation of metal contamination incidents. These may arise through internal metal finds or customer complaints. Suitable investigation procedures must be in place to determine the source of any metal contaminants detected and any corrective actions derived must be implemented to prevent future recurrence. Investigations must be documented. (Please refer to Foreign Body Prevention: Customer Complaint COP for further details).
-
(xi) For sites that use magnets or sieves as an in-line control measure, they must be subject to regular, documented inspection and cleaning e.g. daily. A documented record of all sieve integrity checks and magnet checks must be kept for future reference as well as any retained foreign matter.
-
1.1.3 Maintenance of Metal Detector and X-ray Equipment<br>(i) Any service work relating to breakdown or failure of the detection system (i.e. not including motors, conveyors, sensors etc.) must be undertaken by the equipment manufacturer or their appointed agent/representative and any spare parts fitted must, where available, be original parts and fully supported by the manufacturer’s warranty.
-
(ii) A complete system test, including all failsafes, must be carried out following any repairs, maintenance or adjustments.
-
1.1.4 Raw Materials<br>(i) Where raw materials are a known source of metal contamination (or any other detectable contaminant, such as glass, stones, some bones etc), in-line metal detection or x-ray systems must be considered.
-
(ii) Where such systems are installed upstream of an end-of-line metal detector/x- ray, the in-line system does not have to meet the specification and fail-safe requirements of an end-of-line system.
-
1.2 The Detection of Metal<br>(i) Suppliers must ensure that the detection equipment used on all Marks & Spencer lines is the most suitable for the type of finished products produced by the site.
-
(ii) All suppliers that provide finished retail product to Marks & Spencer must comply with the ‘Standard Level Compliance’ requirements that apply to their method of detection i.e. metal detector or x-ray.
-
(iii) The requirement to comply with the ‘Higher Level Compliance’ specification will be determined on a site by site, and line by line, basis by discussion and agreement with Marks & Spencer. This will be based on the number of metal complaints being received and it is in addition to the ‘Standard Level Compliance’ requirements.
-
(iv) All systems must meet M&S sensitivities as detailed in section 1.4.3.
-
(v) All suppliers must complete the x-ray decision tree in this section if they have any M&S production line(s) that do not meet the sensitivity specification stated in Section 1.4.3 and/or: currently use ferrous in foil metal detectors pack product in Aluminium or metallised film pack product in cans pack product in glass containers with metallised lids pack product in ceramic containers (terracotta ceramics contain iron) In these instances, suppliers must complete the decision tree in Section 1.3 for each relevant production line to determine whether an x-ray system is required. This must take account of every Marks and Spencer finished product made at the site.
-
(vi)Essential Requirement: The outcome of the decision tree must be formally agreed and signed-off by the Marks & Spencer Food Technologist and made available on audits. Where the need for an x-ray system has been identified, suppliers must install an x-ray system that complies in full with the requirements of this document.
-
(vii) Where belt-stop systems are used e.g. potential damaged product in bulk production, this must be authorized in writing by a Marks & Spencer Technologist (excluding A list suppliers).
M&S 1.4 DETECTION SYSTEMS - Standard Level Compliance
-
1.4.1 General Requirements for All Systems (i) Thesystemmustbelocatedafterthefinishedproductpackingpointandinline with the main production flow.
-
(ii) The metal detector/x-ray system conveyor must be capable of running at the maximum speed of the product in-feed packing conveyor.
-
(iii) Production packs must be presented to the detection system in regular spacing and with sufficient space between packs for the reject device to operate correctly. Product packs must not be allowed to back up onto the metal detector/x-ray conveyor system.
-
(iv)A way of indicating the reason for active faults must be included within the system i.e. an alarm, on-screen explanation or light that triggers when a fault occurs and easily indicates to line operatives the reason for the fault.
-
(v) If a detection system goes into a ‘fault state’ i.e. activation of a fail-safe or detector head fault, the system must be designed to maintain the fault state (until cleared by the user via the key switch reset) even if the equipment is turned off and back on again. This only applies to new equipment installed after the 1st of April 2016. Standard or Higher Level equipment installed prior to this date does not have to be upgraded to include this feature unless the site/line in question has been classified as being required to operate to the higher level specification as a mandatory requirement.
-
1.4.2 Essential Requirement - Metal Detector and X-ray Specifications All systems, including existing installed systems, must include the following features depending on their type of detection:
-
1.4.3 Metal Detector and X-ray Sensitivity As the detection of metal in finished product packs is often classified as a CCP, critical limits must be set to achieve optimum sensitivity and the metal detector/X-ray must be of a size appropriate for the product being screened. Optimum sensitivities must be established and set for each product (including bulk materials produced by A-list suppliers) and this activity must be carried out by trained factory technical personnel, such as the Subject Matter Expert (SME), and/or the detection system manufacturer or their appointed agent. Achievable sensitivities will relate to the product’s size, type and packaging. (i) If detection systems are moved within the factory or new products introduced, the equipment performance and operation must be re- validated to ensure compliance with this Code of Practice.
-
(ii) The sensitivity of the detection system must be maximised to the optimum level, however, this must not result in instability where the effects of product/environment cause false rejections.
-
(iii) Records of sensitivity set up trials and results for each product must be retained for review during the Marks & Spencer audits (including confirmation by the equipment manufacturer or their appointed agent of the smallest reliable test piece sizes for each test piece material and an accurate record of the density of each test piece used in x-ray trials).
-
(iv)Sensitivity adjustment controls must only be accessed by nominated staff who are trained to a minimum of Tier C (see Section 1.6) and must not be accessible to any other personnel.
-
(v) The detection sensitivities which must be achieved are set out in the tables below.
-
1.4.4 Essential Requirement - Metal Detector and X-ray Testing Procedures to be followed by all Suppliers Metal detector/x-ray testing procedures must be clearly documented and communicated to all staff responsible for carrying out these tests. The procedure must be available for easy reference e.g. an integral part of the record sheet. Routine Testing (i) The metal detector/x-ray function must be routinely tested at the following intervals: - At the start of each shift. - Between each product change. This excludes lines with short runs at the same sensitivties i.e. 5 – 10 minutes. In these instances, it is acceptable to carry out the routine test at the standard frequency e.g. every 30 minutes or every hour instead of every 5 minutes when the product changes; however, the routine test must be completed if the sensitivity settings of the metal detector/x-ray are changed. - At the end of each shift or production run. - The frequency of testing during production runs must not be greater than hourly intervals, unless agreed in writing with a member of the M&S Hygiene Team.
-
(ii) Routine testing must be carried out by placing all three test packs onto the line consecutively at normal product spacing.
-
(iii) The frequency of testing must allow for the identification, recall and retesting of all products which have passed through a failed system since the last successful test. The products must not have left site.
-
(iv) For testing conventional metal detectors, ferrous, non-ferrous and stainless steel test pieces must be used.
-
(v) Where ‘ferrous in foil’ detectors are in use, two ferrous test pieces must be used.
-
(vi) Where X-ray systems are in place, sites must use 3 test pieces one of which must be stainless steel. The other two test pieces should be made up of the most relevant foreign bodies to the product manufactured and/or reflect potential foreign bodies in their raw materials or manufacturing environment, i.e. glass, ceramic, stone, or other metals. These test pieces must be of the same density as those used when each product was initially set-up, as described in section 1.4.3(iii).
-
(vii) Test packs must be made up from products that have successfully passed through the detection system and must be clearly marked and labelled so that they cannot be inadvertently distributed.
-
(viii)Fresh test packs must be made up for each production line at a frequency which reflects the nature, durability and shelf life of the product and must be the same product as the one in production.
-
(ix) Test packs and test pieces must not be kept stored within the locked Reject Bin.
-
(x) Every test pack must be detected and rejected for the routine test to have been successful. If any part of the routine test fails, production must be stopped to allow the necessary investigations and corrective action to be carried out. It is not acceptable to simply repeat the test until the test packs are rejected successfully and then allow production to continue.
-
(xi) If a routine test fails, product manufactured since the last satisfactory test must be isolated, put on hold and re-screened using a system set to the same standard as the original system. This re-test must be fully documented.
-
Routine Testing of Conveyorised Metal Detection Systems Make-up of Test Packs - Each test piece (ferrous, non-ferrous and stainless) must be placed within or attached securely onto the product to ensure that during testing, the test pieces pass as close as possible to the geometric centre of the detection head aperture (only for metal detectors). The test pieces must be introduced to the metal detector in the following manner: 1st pack – test piece placed at leading edge. <br>2nd pack – test piece placed in centre. 3rd pack – test piece placed at trailing edge.
-
Routine Testing of Conveyorised X-ray Systems Make-up of Test Packs - Each test piece (stainless steel plus 2 relevant foreign bodies such as glass and ceramic) must be placed within or attached securely onto the product in the position where they are hardest to detect. This will vary according to the product and its packaging. Where it is not obvious where the test piece should be positioned, the x-ray system provider/manufacturer must give guidance on suitable locations for each pack format.
-
Routine Testing of Belt-Stop Metal Detection Systems Each test pack must be individually passed through the detector head and the conveyor must stop immediately each time. The conveyor belt must stop before the test pack transfers to the product outfeed conveyor. Where this does not occur, the product outfeed conveyor must be linked to metal detector conveyor so that both stop immediately when metal is detected.
-
Routine Testing of Freefall ‘Throat’ Metal Detection Systems – Bulk Production The system must be tested by individually inserting the ferrous, non-ferrous and stainless steel test pieces through the test piece insertion point and observing the operation of the reject system rejecting the test pieces into the test piece capture system.
-
Routine Testing of Freefall ‘Throat’ Metal Detection Systems – Retail Packs Ferrous, non-ferrous and stainless steel test pieces must be individually placed in the product flow and successful rejections observed e.g. double pack made and audible and/or visual alarm activated and the take away conveyor immediately after the bag maker must stop.
-
Routine Testing of Pipeline Metal Detection Systems The system must be tested by inserting the test pieces between the pipeline and search head and observing the operation of the reject system.
-
Fail-safe Testing (i) In addition to the routine testing, the following failsafe features must be tested at the start of every shift or at least daily where continuous production makes this impractical.
-
(ii) If a fail-safe test is not successful or a fault develops during production, the necessary corrective action must be taken and all of the failsafe tests successfully repeated before production recommences. Also, in these cases, all products on the ‘stopped’ belt (and downstream conveyor where relevant) must be collected from the line and re-passed through the detector once the fault has been rectified.
-
(iii) Controls related to re-starting a conveyor belt after a fail-safe has activated: - The conveyor belt cannot re-start until the fail safe has been de- activated. - If a conveyor can be switched on whilst the fail safe is still activated, the re-start button must be locked and only an authorised person can switch the line conveyor back on.
M&S 1.5 Essential Requirement - Rejected Product
-
(i) Any Marks & Spencer product (or bulk raw material) which has been rejected by a metal detector or x-ray must not be packed for Marks & Spencer after re-testing, regardless of whether it is rejected again. This does not include product rejected during normal test procedures. If products rejected during routine testing are in a sound condition they may be placed in the product flow and re-detected.
-
(ii) All rejected products must be fully investigated to determine if metal is present (or, in the case of an x-ray machine, other foreign bodies). This should take place as soon as practical (at least within that production shift) and before the rest of the product leaves site. In addition, all confirmed metal found prior to metal detection/x-ray systems must be recorded and fully investigated to identify the origin and generate appropriate corrective action. The investigation and corrective action should be fully documented.
-
(iii)Production for Marks & Spencer must be stopped in the following circumstances: If more than one metal contaminant is found (through detection or observation) on any one production line within any 24 hour period. If more than one metal contaminant (of the same type of metal) is found (through detection or observation) in the factory within any 24 hour period.
-
(iv)The Senior Management team must ensure the identification and elimination of the cause of multiple rejects. The relevant Marks & Spencer Technologist must be informed of action taken before production of Marks & Spencer products recommences, and a joint decision must be made regarding the release or otherwise of stock placed ‘on hold’.
-
(v) An escalation process must be in place for incidents occurring outside M&S HQ working hours, i.e. where there is a potential risk of contaminated products having left site.
M&S 1.6 Training
-
1.6.1 All relevant staff must be adequately trained in the principles of metal detection and must have a thorough knowledge of their equipment and testing routines. Only those staff who can demonstrate effective training has been received should have any interaction with a metal detector/x- ray system. Training Certification must be in place for all metal detection training.
-
1.6.2 Subject Matter Expert (SME) - All Marks & Spencer suppliers must have a SME on site at all times covering all production shifts. This person must have an in-depth knowledge of metal detector/x-ray technology (as relevant), the requirements of this COP and be able to give basic training in detecting metal and the Marks and Spencer requirements to other relevant staff.
-
1.6.3 Tier A – General Understanding of metal contaminants and detection This level of training must be given at Induction to anyone who is likely to come into contact with a metal detector/x-ray machine, including cleaning staff. It must include: What to do to prevent metal contamination The reasons for inspection of products for potential metal contamination Operatives’ responsibilities in relation to metal
-
1.6.4 Tier B – Routine Testing Requirements This level of training must be given to all staff who are responsible for setting-up production lines and testing the equipment i.e. Line Management, Technical staff, Engineering staff and Line Operators. This must be carried out annually and must include: The content of previous levels of training (i.e. Tier A) The basics of how a metal detector/x-ray works (as relevant) An overview of Marks and Spencer Prevention of Metal Contamination COP requirements Detection sensitivity requirements Reason for routine testing and how to conduct routine tests Reason for fail-safes and how to conduct fail-safe tests<br> Control of rejected products Metal reject investigations What corrective actions are required Any senior management intervention required General rules i.e. keep passwords personal etc
-
1.6.5 Tier C – SME This level of training must be given by the metal detector/x-ray manufacturer, their appointed agent or suitable competent external company in conjunction with the person responsible for technical/quality standards on site. This must be carried out on a 3 yearly basis or more frequently if required and must cover: All of the previous levels of training (i.e. Tiers A and B) The principles of Maintenance and Performance Validation Understanding of their equipment’s specification Full understanding of the Marks and Spencer COP requirements New product set-up including how to optimise detection sensitivities
-
1.6.6 Tier D – Engineering Training This level of training must be given by the detector/x-ray manufacturer, their appointed agent or suitable competent external company to site Engineers. Tier D Engineers must have an appreciation of the content of the previous levels of training (i.e. Tiers A, B and C) but must also be trained on: How to trace faults – root cause analysis Importance of maintenance and Performance Validation Manufacturer’s maintenance recommendations, lubrication requirements, critical locations on the equipment Good engineering practices to reduce the risk of product contamination
M&S 1.7 Metal Detector/X-ray Performance Validation
-
1.7.1 All detection equipment used to screen Marks & Spencer products must receive a Performance Validation (PV) on at least an annual basis, with the exception of belt stop metal detectors.
-
1.7.2 The person undertaking the PV must be able to demonstrate evidence of competency. Evidence of competency must relate to the individual concerned and not just the organisation they represent and be attached to all PV Certificates issued for each metal detector/x-ray that has been validated.
-
1.7.3 PV checks MUST include: Metal detector/x-ray manufacturer’s initial build parameters (not accessible to the user) Electrical and mechanical installation checks System functionality checks including adherence to the specified critical limits Product related information checks Fail-safe functionality checks Customer’s test piece verification checks An audit of a random member of the production personnel (whose job it is to conduct routine and failsafe testing) in order to assess their knowledge and skills during the routine and fail-safe testing Specifically for X-ray - safety interlocks and radiation emissions safety check (legal requirement) Specifically for X-ray - tank alignment and detector stability checks
M&S 1.8 Documentation and Record Keeping
-
The following documentation and records must be kept: Commissioning and sensitivity tests/records for new equipment and following the movement of equipment. Results of all daily routine and failsafe tests showing time, result, sensitivity, Marks and Spencer product and any necessary corrective action taken (retained according to site’s record keeping timeframe). Number of rejected packs each shift. Number and details of detected contaminants. Investigations into metal finds or metal that has been detected together with action taken to trace the source of contaminants. Planned preventive maintenance programme and service work. Performance Validation Certificates. Certificates of Competency of external organizations. Training records for all staff. A procedure for removal of product from the line in the event of a ‘stop’ must be in place (including instances of total power failure i.e. power cut). SOP for routine and fail safe testing
M&S 1.9 DETECTION SYSTEM - Higher Level Compliance
-
In certain circumstances, sites will be required to meet the ‘Higher Level Compliance’ specification. The requirement to comply with the Higher Level will be determined by Marks and Spencer on a site by site, and line by line basis. This will be based on the number of metal complaints being received. When a site is required to meet the Higher Level Compliance, it must carry out an immediate evaluation of their existing metal detection equipment and demonstrate that it is the most suitable for the type of product manufactured. The outcome of the evaluation must be agreed with the Marks and Spencer Technologist. Higher Level Compliance sites must comply with the following requirements on existing equipment and any new purchases of metal detection equipment and this is in addition to ‘Standard Level Compliance’.
M&S FOREIGN BODY PREVENTION: PLASTIC February 2016 v6
M&S 1.1 General Requirements
-
1.1.1 The correct type, grade and quality of plastic must be selected for each application including food contact containers and utensils as well as other items such as cleaning materials and PPE. This will require detailed consideration of the factors which can cause or accelerate damage such as freezing, blast chilling, high temperatures in washing equipment, contact with acid or alkaline substances, abrasion or impact damage.
-
1.1.2 ESSENTIAL REQUIREMENT: All plastic must be kept in good condition so as to not pose a risk of contaminating food products.
-
1.1.3 Where plastic comes into contact with food, the material specification must demonstrate it is suitable for contact with food and complies with all relevant legislation.
-
1.1.4 Impact or abrasion contact between plastic and metal articles (e.g. trays, scrapers) or machinery components must be avoided.
-
1.1.5 Combinations of plastic trays and metal racks must be designed to be fully compatible to minimise the risk of plastic damage.
M&S 1.2 Raw Material Suppliers
-
1.2.1 Technical approval of raw material suppliers must include assessment of their controls to prevent plastic foreign body contamination of the materials supplied. This assessment must be fully documented.
-
1.2.2 The performance of each raw material supplier must be periodically reviewed and trended (e.g. quarterly) and, where there is evidence of an upward trend in plastic foreign bodies, this should prompt a supplier audit.
-
1.2.3 Raw material specifications must include packaging details, including colour and gauge of plastic. This will allow for the easy identification of plastic foreign bodies.
M&S 1.3 Raw Material and Work in Progress Containers
-
1.3.1 Containers and/or packaging in which raw materials are delivered must be inspected on arrival for signs of damage. Where there is damage, appropriate corrective action must be taken and if necessary the container and its contents rejected. All inspections, faults found and action taken must be recorded and signed off.
-
1.3.2 Single use raw material containers (e.g. mayonnaise buckets) are not robust in the factory environment and must not be re-used for any activity, including the storage or transfer of equipment, raw materials or product.
-
1.3.3 Work in progress trays and tubs must be inspected before each use (e.g. after washing) for signs of damage. Damaged items must be discarded or placed in a quarantine area until they are suitably repaired and records should be kept of all rejections/replacements. The presence of any fractures, however small, indicates that the material is failing and the container must be rejected.
-
1.3.4 After any such repairs, the equipment must be washed to remove any remaining fragments of plastic before being returned for use.
-
1.3.5 Plastic covers must only be used for covering ingredients/work in progress where materials are exposed to a significant cross contamination risk if they are not used for a period of time e.g. an entire shift or overnight or for necessary allergen controls.
-
1.3.6 Where plastic covers are the only option these must conform to the minimum specification outlined in the Marks & Spencer Guidelines G4 - Use of Coloured Polythene in Food Factories (see Appendix 1.0 to this document) in order to be robust enough to prevent shredding/disintegration if damaged.
M&S 1.4 Raw Material Packaging (Polythene bags and liners)
-
1.4.1 All direct food contact polythene bags, liners and wrapping materials, including those used for the delivery of raw materials, must be coloured to contrast with the product and conform to the minimum specification outlined in the Appendix 1.0.
-
1.4.2 The supplier must demonstrate that each item of plastic packaging is fit for purpose and able to withstand any changes in temperature which occur as a result of manufacturing process or due to storage conditions during cold weather.
-
1.4.3 Periodically, i.e. at a minimum frequency of every 3 months, raw material quality checks must include an assessment of the supplier’s conformance to the agreed packaging specification.
-
1.4.4 There must be a detailed bag opening procedure in place which covers the entire site. This procedure must take the form of a practical guide to bag opening which uses photographs to demonstrate methods. Bags must not be torn open.
-
1.4.5 Bags must not be opened directly over any open product (i.e. over kettles or hoppers) irrespective of whether a sieve is in use.
-
1.4.6 Polythene wrapping must be completely removed from blocks of butter, fat, cheese, frozen protein etc before any sampling or cutting takes place.
-
1.4.7 Where bags of frozen raw materials or work in progress are decanted prior to defrosting, the decanting and inspection method must ensure that any entrapped polythene is removed.
-
1.4.8 The method of closing bags must not introduce additional plastic risks, therefore, tape and ties must not be used to close bags. Instead, bags should be loosely knotted so they can be re-opened without tearing.
-
1.4.9 The use of shrink-wrap or stretch wrap may be necessary to stabilise stacked loads. Shrink-wrap or stretch wrap must be removed away from areas where open raw materials or open foods are present.
M&S 1.5 Plastic Utensils and Other Equipment
-
1.5.1 The use of plastic equipment (i.e. scoops, scrapers, safety knives, brushes with plastic bristles as well as equipment such as conveyor belts) must be assessed against fitness for purpose and durability.
-
1.5.2 A proactive system must be in place for the replacement of plastic equipment (e.g. safety knives, trays, scrapers, belts, brushes) to prevent them from becoming a source of potential plastic contaminants.
-
1.5.3 Plastic conveyors and elevators carrying unwrapped materials must be inspected at least daily for signs of damage and trimmed/replaced where necessary. Inspections and actions arising must be recorded and signed off.
-
1.5.4 All other plastic equipment mentioned above should be inspected daily for evidence of wear or damage and any items which could present a risk of product contamination must be replaced immediately.
M&S 1.6 Plastic Finished Product Packaging Materials
-
1.6.1 Products should be sourced from packaging suppliers holding a BRC A or B grade certification or an alternative GFSI benchmarked packaging standard.
-
1.6.2 Direct food contact finished product packaging materials should be delivered in polythene bags or liners which are coloured and conform to the minimum specification outlined in Appendix 1.0 to this document.
-
1.6.3 A detailed quality check must be carried out on each batch of packaging that is received to ensure the materials meet the agreed specification.
-
1.6.4 The performance of each finished product packaging supplier must be periodically reviewed and, where there is evidence of an upward trend in foreign bodies, this should prompt a supplier audit.
-
1.6.5 Plastic finished product packaging must be handled according to the manufacturer’s specification. Factors such as load and stacking limits and performance at low/high temperatures must be understood and taken into account.
-
1.6.6 When selecting a new innovative plastic packaging product, a review of the filling and sealing equipment which will be used at the food manufacturing site must be completed to ensure that the plastic container is compatible. Any modifications to food production machinery or the container design must be completed and assessed on-line before the first production run.
-
1.6.7 Plastic finished product containers must be inverted, compressed air rinsed or visually inspected prior to use to ensure the removal of any potential foreign matter contamination.
-
1.6.8 Where there is a risk of plastic containers shattering in sealing machinery, a documented procedure must be in place to prevent any product contamination by plastic fragments. Every time pots shatter, the procedure must be strictly followed and the corrective actions taken must be recorded and signed off (i.e. to be treated in a similar way to a glass breakage). This will involve: - Stopping the production line<br>- Removing and disposing of all damaged packaging and potentially affected product - Removing a specified quantity of undamaged packaging on either side of the area where the damage occurred - Supervisory sign off before re-starting the line
-
1.6.9 Form, fill and seal equipment (e.g. Multivacs) must have an enclosed container to completely catch and retain off cuts. This must be regularly emptied and the equipment thoroughly cleaned to remove any loose plastic fragments. The base film reel must be segregated from the cutting process (e.g. by a polycarbonate guard) to prevent loose plastic off-cuts adhering to the reel due to static electrical attraction or earthed to prevent static build up.
M&S 1.7 Personal Protective Equipment (PPE)
-
1.7.1 Plastic PPE e.g. gloves, aprons, sleeves, must only be used where necessary and must be assessed to ensure they are fit for the intended purpose. The results from this assessment must be documented.
-
1.7.2 Staff must be made aware of the risks from damaged PPE and the need to change it as soon as any damage occurs; informing their manager if they believe any part of it has been lost.
-
1.7.3 There must be adequate provision for production staff to change their PPE which will remove any need for staff to work with damaged equipment.
M&S 1.8 Start up checks
-
1.8.1 Start up checks for production machinery, lines and areas must be detailed and focus on the integrity of plastic components/items in locations where if damage should occur, there could be a risk of product contamination.
-
1.8.2 Sufficient time, training and equipment (i.e. torches) must be given to those responsible for conducting the start up checks on production machinery.
M&S 1.9 Plastic Complaints
-
1.9.1 Any plastic foreign body returned as a customer complaint or found in raw materials, work in progress or finished products on site must be thoroughly investigated to identify the source and root cause. These investigations must be thorough and recorded in sufficient detail (refer to the Foreign Body Prevention: Customer Complaint COP).
-
1.9.2 If more than 1 plastic contaminant of the same type is found in any M&S product or raw material in the factory within any 24 hour period, the source and root cause of the contaminant must be immediately investigated and remedied.
-
1.9.3 The Senior Management team must ensure the identification and elimination of the cause of multiple finds. The relevant M&S Technologist must be informed of causes and action taken.
-
1.9.4 Following receipt of any plastic complaints, effective action must be put in place with the clear objective of preventing recurrence of any further similar complaints. This includes re-training of staff where the results of these investigations show this to be necessary.
-
1.9.5 The customer complaint trend analysis system must break down plastic complaints according to the type of plastic materials commonly used in the factory. This must be detailed, including the colour, type and use of plastic together with location of contamination. This data should be used to identify and action key trends and complaint drivers.
M&S 1.10 Staff Training
-
1.10.1 Suitable training must be given to all employees to develop recognition and reduction of potential sources of plastic foreign body contamination.
-
1.10.2The training should form part of an active and ongoing awareness programme aimed at the prevention of foreign body contamination.
M&S FOREIGN BODY PREVENTION: GLASS February 2016 v5
M&S 1.1 Prevention of Contamination
-
1.1.1 Essential Requirement: A documented risk assessment of all glass and glass- like materials must be carried out and signed-off by the nominated Senior Manager.
-
1.1.2 The risk assessment must include details of the location of the material, its condition and proximity to ingredients/raw materials, product, packaging or production equipment, and likelihood of product contamination in the event of breakage.
-
1.1.3 The risk assessment must subsequently be used to form the basis for determining action such as replacement, protection and monitoring the condition of the glass/glass-like material as appropriate.<br>(i) There must be a programme to remove, and replace with suitable alternative materials, all unprotected glass in production areas and where food materials are exposed. Where this is not practicable, shatter-resistant security film that conforms to BS 6206 must be applied to the glass on the surface facing the food area. (ii) Raw materials must not be delivered in glass containers. (iii) The introduction of new equipment, or changes to existing equipment must be fully reviewed to ensure that glass is, whenever practical, totally eliminated and that any hard plastic used is appropriate in order to reduce breakage hazards. (iv) Due to the potential of contamination, glass food and drinks containers (including Thermos type flasks) must not be brought onto the factory site. Any exceptions must be approved in writing by the responsible senior factory manager
-
Protection of Glass (i) Glass components in food vessels which cannot be replaced due to process temperatures/pressures, must be “toughened” and conform to British Standard 3436 (1975) 1988: Specification for Observation and Gauge Glasses for Pressure Vessels, or DIN 7090/8902 which set the standards for pressure resistant sight-glasses. (ii) Glass windows must be part of the documented risk assessment to determine the risk of food product contamination in the event of breakage. Where such a risk determines no requirement to add a shatter-resistant security film, this must be agreed with a Marks and Spencer Hygiene Technologist. (iii) Light fittings in all food processing and storage areas, and other areas associated with production e.g. production offices, corridors, loading bays, engineering areas and changing rooms, must be protected against damage. Fluorescent tubes including tubes in electronic fly-killing units, must be provided with a protective shatter resistant outer sheath, or housed in a protective fitting.
-
Monitoring of Glass and Glass-like Materials (i) All glass and glass-like materials must be identified and logged so that their condition can be audited. (ii) Glass and glass-like materials sited directly on, over or adjacent to production lines, food processing equipment, and in areas where products or ingredients are exposed, must be inspected daily for signs of damage and appropriate corrective action taken where necessary. (iii) For all other areas, there must be a regular audit of the condition of the glass, or glass-like materials at a frequency determined by the risk assessment; however it is expected that audits will be carried out at least monthly.
M&S 1.2 Procedure Following Breakage of Glass and Glass-like Materials
-
1.2.1 There must be a written breakage procedure in place which specifies the action to be taken in the event of any breakage of glass or glass-like material. Employees must be made aware of the procedure and they must inform their line manager in the case of any breakage.
-
1.2.2 A nominated senior manager must be responsible for ensuring the actions contained within the breakage procedure are followed. As a minimum, the procedure for production and associated storage areas must contain instructions for the following: Where appropriate, stopping production. Restriction of personnel in and out of the area. Isolation of all food and packaging materials possibly contaminated. A record of product, codes, and quantities to be logged for reference. Designation of the size of area to be isolated and searched for fragments of glass or glass-like materials, e.g. 10 metre radius. All cleaning equipment used to remove glass must be either dedicated for glass breakages or immediately disposed of with the glass outside the factory. For factories handling glass as a packaging material a dedicated cleaning kit must be used to remove glass breakages. Vacuum cleaners should not be used for glass clean-up operations unless dedicated for this use and marked accordingly. Removal and inspection of fragments of glass or glass-like materials. Where practical, piecing fragments back together to try to determine whether all of the glass has been accounted for. Retention of a sample of the glass for reference and, if necessary, further analysis. Checking soles of boots, shoes and protective clothing of all personnel leaving the breakage area. Inspecting the area in detail when cleaning has been completed.
-
1.2.3 An incident report with corrective action if appropriate must be completed and signed-off by a senior manager to formally release the area back into use.
-
1.2.4 If Marks & Spencer products or raw materials could have been contaminated, production must be stopped immediately and Marks & Spencer informed of the action being taken.
M&S 1.3 Glass Replacement
-
1.3.1 Extreme care must be taken during replacement of glass.
-
1.3.2 The location of the glass to be replaced in relation to any production lines, or storage areas must be taken into account when considering precautions to be taken. Other considerations must include the safe removal of the damaged glass for disposal and the clearance procedure at the end of the work.
-
1.3.3 A hand-back/release procedure must be in place to ensure the work was completed successfully and the area is clear of foreign body risks
-
1.3.4 Where possible, glass replacement must be carried out outside production hours.
M&S 1.4 Customer Complaints
-
1.4.1 All customer complaints of glass and glass-like materials must result in an immediate, thorough, documented investigation of the incident.
-
Add signature
