• Summary;

M&S FOR THE IMPLEMENTATION OF HACCP AT MARKS & SPENCER FOOD SUPPLIERS February 2013 v2

M&S 1.0 Obtain Senior management commitment

  • 1.1 The membership of the HACCP team must include at least one Senior Manager. The Senior Manager member is responsible for reporting HACCP non conformances and the results of HACCP reviews to the rest of the Senior Management team. HACCP non conformances and results of HACCP reviews must be escalated to board level.

  • 1.2 Senior Management must provide adequate resources to meet the requirements of this Code of Practice

M&S 2.0 Define the terms of reference / scope of the study

  • 2.1 The HACCP study must consider biological, chemical, physical and allergen hazards. All hazards must be precisely defined (e.g. specific pathogens associated with the product in question)

  • 2.2 Reference must be made to key Marks & Spencer Code of Practice applicable to the site (e.g. Codes of Practice used specifically to define product category, critical limits, validation methods etc.).

  • 2.4 The HACCP team must clearly define the Marks & Spencer product category for all product types supplied. The categories are defined as: • High Acid • Low Acid • Ambient Stable (e.g. Aw, CIMSCEE controlled etc.) • Produce • Cheese and Dairy • Frozen or Chilled (refer to Marks & Spencer Code of Practice and Guidelines – Manufacturing Standard for Chilled and Frozen Finished Products)

M&S 3.0 Select the team

M&S 3.1 The HACCP Team Leader

  • 3.1.1 The HACCP team leader is responsible for ensuring the entire HACCP team has the appropriate knowledge, qualification and competence to develop the HACCP plan.

M&S 3.2 HACCP Training

  • 3.2.1 As a minimum, at least one member of the HACCP team must have completed a 2 day, Intermediate HACCP training course (e.g. examined to Level 3 or internal equivalent).

  • 3.2.2 As a minimum, all core members of the HACCP team must have completed a 1 day Foundation HACCP training course (e.g. examined to Level 2 or internal equivalent). Training must be undertaken within 2 months of joining the HACCP team.

  • 3.2.3 A program of HACCP awareness training must be in place for all production personnel.

  • 3.2.4 Production personnel responsible for monitoring CCPs must be provided with specific CCP training which should be recorded and auditable.

  • 3.2.5 A progressive approach should be adopted towards refresher training for HACCP team members.

M&S 3.3 Group Resource

  • 3.3.1 Group resource may be used to facilitate the HACCP process, however the day- to-day management of the HACCP plan remains the responsibility of the manufacturing site.

M&S 3.4 External Consultants

  • 3.4.1 Where sites do not have the appropriate in-house knowledge, the use of external consultants may be considered. The justification for using a consultant must be formally documented within the HACCP plan.

  • 3.4.2 An external consultant cannot act as the Team Leader, or be responsible for formally documenting the HACCP plan. External consultants can facilitate the HACCP process, however the operation of the HACCP plan must remain the responsibility of the site.

M&S 4.0 Describe the product

  • 4.1 The product description must clearly consider the safety hurdles (i.e. what makes a product safe).

M&S 5.0 Identify intended use of the product

  • 5.1 The HACCP team must identify all likely future uses of the product and product packaging by the consumer. Examples may include freezing of chilled/ambient products, or further consumer use of empty product packaging. This should also include references to any child safety or specific hardware requirements.

M&S 6.0 Construct a process flow diagram

  • 6.1 The format and presentation of the process flow diagram shall be a matter of choice for the site. At this stage, CCPs should not be detailed on the process flow diagram.

  • 6.2 Where high care transfer barriers are in place, process flow diagrams must clearly define the transfer points across each barrier for raw materials, WIP, packaging and waste (refer to Marks & Spencer COP & Guidelines for the Manufacturing Standard for Chilled and Frozen Finished Products).

M&S 7.0 On-site confirmation of the flow diagram

  • 7.1 Verification of each process flow diagram must include the HACCP team physically walking the process within the factory environment. Records of verifying each process flow must be maintained.

M&S 8.0 List all potential hazards associated with each process step, conduct a hazard analysis and determine the measures to control the identified hazards (Codex Principle 1)

  • 8.1 The documented hazard analysis must determine all significant hazards for food safety.

  • 8.2 The method used to identify the overall risk of each hazard shall be a matter of choice for the site. The HACCP team must clearly define and document each level of likelihood and severity used in the decision making process.

  • 8.3 Sites must refer to Fig 1 to assist with the categorization of prerequisites, operational prerequisites and control measures of CCPs

  • 8.4 The control measure for each hazard identified must clearly make reference to a specific procedure or control document.

M&S 9.0 Determine the Critical Control Points (CCPs) (Codex Principle 2)

  • 9.1 A decision tree must be used for each significant hazard to determine critical control points. Documented evidence of decision tree use must be maintained.

  • 9.2 Once CCPs have been established, the HACCP team should update the process flow diagram to reference the location of each CCP

M&S 10.0 EstablishcriticallimitsforthecontrolmeasuresateachCCP (Codex Principle 3)

  • 10.1 Critical limits must be based on defined legislation and relevant Marks & Spencer Codes of Practice and Guideline documents.

M&S 11.0 EstablishamonitoringsystemforeachCCP(CodexPrinciple4)

  • 11.1 Equipment used to monitor CCPs must be calibrated at an appropriate frequency against a national standard. Records must be available to demonstrate this.

M&S 12.0 EstablishacorrectiveplanforeachCCP

  • 12.1 The site must prepare a summary of CCPs. The summary must include a list of process steps, critical limits, monitoring procedures and corrective actions for each CCP.

  • 12.2 When during production a CCP deviates from a critical limit, and there remains a food safety risk to Marks & Spencer product after the corrective action has been taken, all effected product must be quarantined. The Marks & Spencer Technologist must be notified and the product must not be released. Any subsequent actions taken must be agreed with the M&S technologist and documented. A written record of authorisation must be retained.

  • 12.3 The company shall maintain a log of all instances where critical control limits have fallen out of control. As a minimum, the log must identify;  immediate actions needed to regain control  the destruction/rework actions  communication and authorisation from technologist (refer to 12.2)  cause of deviation  appropriate remedial actions to prevent recurrence

M&S 13.0 Perform validation, verification and review activities

M&S 13.1 Validation

  • 13.1.1 Validation of the HACCP plan must include specific validation activities detailed within relevant Codes of Practice (e.g. Code of Practice and Guidelines for Manufacturing Standard for Chilled and Frozen Foods).

  • 13.1.2 The HACCP validation must be formally signed off by the HACCP team leader and the Senior Management member of the HACCP team (this may be the same person).

M&S 13.2 Verification

  • 13.2.1 Verification activities shall include factory based audits (refer to Hygiene Code of Practice Section 8: Hygiene & Food Safety Self Auditing Systems).

  • 13.2.2 Verification of pre-requisite procedures must be routinely conducted. This must include documented evidence of compliance to Marks & Spencer Codes of Practice and Guidelines.

  • 13.2.3 Other third party verification studies of CCPs can be used to supplement the sites own verification study.

M&S 13.3 Change Management

  • 13.3.1 Before the implementation of any changes on site that may affect product safety, the HACCP team must undertake a documented risk assessment to determine if a review of the HACCP plan is required. A list of activities which have been identified as requiring review must be detailed in the HACCP plan to demonstrate that the site is in control of change management.

  • 13.3.2 As defined in the Marks & Spencer Best in Class process, the HACCP risk assessment and list of CCPs for each product should be added to the Gate 4 Product Passport. The technologist must review these CCPs and ensure that where M&S have specific requirements for critical limits these are satisfied.

M&S 13.4 Review

  • 13.4.1 A formal documented review of the HACCP plan must be performed at least annually. Further reviews must be undertaken before the implementation of any change which may affect product safety.

M&S 13.5 Documents

  • 13.5.1 All documentation used to develop, implement, validate, verify and review the HACCP plan must be retained (including flip chart and white board notes).

M&S 14.0 Establishdocumentationandrecordkeeping

  • 14.1 Records shall be retained for a defined period with consideration given to any legal requirements and to the shelf life of the products. This shall take into account, where it is specified on the label, the possibility that the shelf life is extended by the consumer (eg home freezing). As a minimum, records shall be retained: Short Life Perishable – 12 months from the withdrawal of the product from sale Long Life – 3 years from the withdrawal of the product from sale

TFMS Section 2 Food safety and quality management v6

  • 2.1 Quality management system
    The site must have a Quality Management System (QMS), which is maintained, documented and regularly reviewed, annually as a minimum. The QMS must include procedures and records as required to meet the requirements of the Tesco standard within a quality manual. The manual must be available to key site employees and integrated into day to day operations.

  • 2.2 Document control, completion and retention
    All documents related to legality, quality and product safety must be adequately controlled, authorised and the correct versions must be in use. Alterations to records must be appropriately authorised and a change log maintained. All records must be accurate and fully complete. All documentation and records must be retained for a defined period with consideration given to:  any legal or customer requirements  the product life  specific Tesco requirements All documentation and records must be available within 4 hours from request.

  • 2.3 Prerequisite programmes
    All environmental, operational and Good Manufacturing Practice controls that are necessary to produce safe and legal food must be in place. This may include the following, although this is not an exhaustive list:  cleaning, sanitising and disinfection  foreign object controls  maintenance programmes for equipment and buildings  material segregation controls e.g. allergens  personal hygiene requirements  pest management
     processes to prevent cross-contamination  purchasing  storage, distribution and transportation arrangements  training  utilities and services (e.g. compressed air, ice, steam, ventilation, water etc.)  waste controls The control measures and monitoring procedures for the pre-requisite programme must be clearly identified and documented.

  • 2.4 The use of HACCP
    The site must have a HACCP food safety system, which is maintained, implemented and documented. The HACCP system must be based on Codex Alimentarius principles which include a minimum of:  identifying the hazards (occurrence and severity, microbiological, chemical, physical and allergenic)  determining CCP’s  establish validated critical limits  monitoring and control measures  corrective actions  documentation procedures (documents must be signed by the person completing the check, and then verified by an authorised person)  verification procedures (can include internal audits, review of complaints and testing results)

  • 2.5 HACCP team
    The HACCP plan must be developed by a multi-disciplinary team which has the correct product knowledge and expertise. The team leader must have an in-depth knowledge of HACCP and be able to demonstrate competence and experience. This can be demonstrated by:  the quality of the plan and its adherence to the Codex principles  successfully completed, formal and up to date HACCP training  demonstrable, extensive experience in implementing and/or training HACCP  no site history of HACCP related major non-conformances arising from third party audits Other team members must also have knowledge of HACCP, product, process and the associated hazards. In the event that the site (or wider company) does not have the appropriate in-house knowledge (either product expertise and/or HACCP), external expertise may be used. However the day-to-day management of the food safety systems must remain the responsibility of the site.

  • 2.6 Product and its intended use
    A full description of the product must be documented including relevant safety information. This may include the following, although this is not an exhaustive list:  composition  origin of ingredients  physical or chemical structure (e.g. water activity, pH etc.)  treatment and processing (e.g. heating, freezing, salting)  packaging (e.g. modified atmosphere, vacuum)  storage and distribution conditions (e.g. with specified temperatures)  durability and required shelf-life  instructions for use The intended use of the product by the customer, must be described, defining the target consumer groups, including the suitability of the product for vulnerable groups of the population (e.g. infants, elderly, pregnant women, and people with allergies).

  • 2.7 Process flow schematic
    A flow diagram must be prepared to cover all products, product categories and/or processes as appropriate. This must set out all aspects of the food process operation within the HACCP scope, from raw material receipt through to processing, storage and distribution. The diagram must include:  plan of premises and equipment layout  raw material flows including introduction of utilities and other food contact materials, e.g. ice, water, gas and packaging  people flows  sequence and interaction of all process steps  critical control points  process delay (maturation)  outsourced processes and subcontracted work  rework and recycling  key segregation All documents must be validated, signed and dated by the HACCP team.

  • 2.8 Training
    Personnel in the factory who monitor critical controls must have an understanding of HACCP and have specific training against the latest version of the relevant monitoring procedure.

  • 2.9 Review
    The HACCP plan must be reviewed at a pre-determined frequency (annually as a minimum) or prior to changes of product/process which may affect product safety. This may include changes in the following areas, although this is not an exhaustive list:
     supply or specification of raw materials or packaging  process steps (including storage and/or distribution)  site layout or flow  introduction of new or modification to existing equipment  new product development

BRC 2 THE FOOD SAFETY PLAN – HACCP v7

BRC 2.1 THE HACCP FOOD SAFETY TEAM – CODEX ALIMENTARIUS STEP 1 v7

  • 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. 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.

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

BRC 2.2 PREREQUISITE PROGRAMMES v7

  • 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 controls. The 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.

BRC 2.3 DESCRIBE THE PRODUCT – CODEX ALIMENTARIUS STEP 2 v7

  • 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. modified atmosphere, vacuum) • storage and distribution conditions (e.g. chilled, ambient) • target safe shelf life under prescribed storage and usage conditions.

  • 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.

BRC 2.4 IDENTIFY INTENDED USE – CODEX ALIMENTARIUS STEP 3 v7

  • 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, allergy sufferers).

BRC 2.5 CONSTRUCT A PROCESS FLOW DIAGRAM – CODEX ALIMENTARIUS STEP 4 v7

  • 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.

BRC 2.6 VERIFY FLOW DIAGRAM – CODEX ALIMENTARIUS STEP 5 v7

  • 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.

BRC 2.7 LIST ALL POTENTIAL HAZARDS ASSOCIATED WITH EACH PROCESS STEP, CONDUCT A HAZARD ANALYSIS AND CONSIDER ANY MEASURES TO CONTROL IDENTIFIED HAZARDS – CODEX ALIMENTARIUS STEP 6, PRINCIPLE 1 v7

  • 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.

  • 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.

BRC 2.8 DETERMINE THE CRITICAL CONTROL POINTS (CCPs) – CODEX ALIMENTARIUS STEP 7, PRINCIPLE 2 v7

  • 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.

BRC 2.9 ESTABLISH CRITICAL LIMITS FOR EACH CCP – CODEX ALIMENTARIUS STEP 8, PRINCIPLE 3 v7

  • 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).

  • 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.

BRC 2.10 ESTABLISH A MONITORING SYSTEM FOR EACH CCP – CODEX ALIMENTARIUS STEP 9, PRINCIPLE 4 v7

  • 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.

  • 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.

BRC 2.11 ESTABLISH A CORRECTIVE ACTION PLAN – CODEX ALIMENTARIUS STEP 10, PRINCIPLE 5 v7

  • 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.

BRC 2.12 ESTABLISH VERIFICATION PROCEDURES – CODEX ALIMENTARIUS STEP 11, PRINCIPLE 6 v7

  • 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.

BRC 2.13 HACCP DOCUMENTATION AND RECORD KEEPING – CODEXALIMENTARIUS STEP 12, PRINCIPLE 7 v7

  • 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.

BRC 2.14 REVIEW THE HACCP PLAN v7

  • 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 validation recorded.

Morrisons 2.0 The Food Safety Plan – HACCP v4

  • 2.11.2 Corrective action shall be based on a recognisable root cause analysis process which is fully documented and its effectiveness must be verified.

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