Section1: Food Safety and QMS
Regulatory and Customer Standards: CFMSR 3.1 Coles Brand Policies and Requirements ; CFMSR 3.2 Site Registrations /Certifications; CFMSR 3.4 Food Safety and Quality Management System WW FMR Sect 1; BRC 1.1.6 ; Management Commitment
A current copy of CFMSR, WSEP and BRC standards must be held on site and available at time of audit.
Current copies of the relevant Coles Brand Policies,related Coles Brand Guidelines and Woolworths Codes of Practice are to also be available at time of audit.
Note: Found in Quality Assurance National\ Standards\ Woolworths, CFMSR (Coles )etc
Must be able to demonstrate understanding of the regulatory requirements for Dairy in this country and the country of sale.
There must be a system to keep the site informed of Scientific and technical developments,new risks to authenticity of raw materials, legislation applicable to raw material supply and production.
The site must have current copies of registrations (Dairy Licence, DoAWR Export Registration) and certifications ( eg Organic, BRC, Coles, Woolworths, Aldi, Spotless, ISO 22000)
The site must have a Food Safety and Quality Management System (FSQMS), which is maintained and regularly reviewed.
Site Plan: CFMSR 3.4.3 Site Plan
The site must have a site plan to define the following areas;
• Perimeter and boundaries
• Base, Medium, High areas for Coles
• Employee facilities (including smoking areas)
• Chemical and waste storage
• Bulk or outdoor storage.
Management Commitment: WSEP 1.1 & BRC 1.1.1 Management Commitment; CFMSR 3.5, 3.6.2 Food Safety and Quality Policy; CFMSR 3.8 Organisational Structure; Approved WSEP 1.5 Food Fraud; BRC 1.1.9
A Food Safety and Quality Policy authorised by senior management, must be in place - stating the company’s intentions to produce safe, legal, and quality products.
The policy must be effectively communicated to all employees.
Sections of the food safety and quality manual must be accessible by all personnel required to complete their task (e.g. copies of the latest versions of procedures).
An organisational structure chart must be in place showing management responsibility and authority.
Staff roles & Responsibilities must be clearly defined in Position Descriptions.
Senior management shall identify and document the job roles for any employees having an impact on food safety, legality, or quality. This documentation shall include the skills, experience, responsibilities, and levels of authority for each job role.
Details of deputising coverage for personnel with responsibility for legal, safety, and quality must be documented.
The Quality Assurance Manage/QA department must have sufficient authority to make decisions.
Product supplied to Woolworths must meet the product name and / or specification in full.
Issues such as adulteration, mislabelling and dilution of product either knowingly or not are considered critical nonconformances
A procedure must be developed, documented and implemented to demonstrate how the company completes a review of the quality management system and implements the improvements required.
Senior Management shall ensure that the root cause of non conformities from previous external audits have been effectively addressed to prevent recurrence.
Business Continuity Plan: WSEP 1.4 Business Continuity
Senior Management must review the business continuity plan at least annually and more often if key resources and personnel change to ensure the plan continues to be effective.
Section 2 Management Review
Management Review: BRC 1.1.2 Management Review; CFMSR 4.6 Senior Management Review ; Approved Arrangement S2 C 7.1, 7.2 and 7.3 ; WSEP 1.6 Senior Management Review; BRC 1.1.3; CFMSR 4.7 Continuous Improvement.
Senior Management must conduct as a minimum, a quarterly review of all systems and documentation. Members of the management team must represent production, technical/quality, logistics (as a minimum) to ensure all areas of the business relating to Woolworths and Coles are in place to verify the effectiveness of the entire Woolworths WSEP and Coles CFMSR standards are captured.
Approved Arrangement, Management Review process ensures that all elements of the AA are reviewed on an annual basis.
This will include, at a minimum:
• The quality management system
• Importing Country Requirements/Trade Descriptions
• Previous MR action plans, and corrective actions.
• Product Standards
• Structural requirements
• Management of systems for HACCP, Food Defence and raw material authenticity
• Allergen management
• Management of cleaning, hygiene and GMP
• Records of internal and external audits
• Pest monitoring and prevention
• Customer complaints and feedback
• Incidents, out of spec results, and non conforming materials
• Withdrawals and Recalls
• Foreign object controls
• Resource requirements
Records of the review and any corrective actions must be kept.
Ensure root cause analysis has been completed where required.
This review may form part of regular scheduled management meetings, where the Technical / Quality department provide information on site performance (e.g. (KPIs)).
Review of the data shall be at defined intervals and demonstrate a culture of continual improvement.
Continuous Improvement activities shall be documented.
Documentation and Record Retention: CFMSR 3.10 Document and Record Retention; CFMSR 3.11 Record Completion; CFMSR 3.12 Record Review And Authorisation;
All documentation and records must be retained on site for at least shelf life of the product plus one year and available for review within 4 hours from the request.
All records must be legible, accurate, and fully complete and must not be recorded in pencil or amended by correction fluid or tape.
Records of production shall be reviewed and authorised by trained and competent personnel.
Records must be retrievable even after IT upgrades or changes.
Change Management Procedure: CFMSR 3.13
A process for change management shall be defined and documented. The change management program shall be used prior to any changes that can have an impact on food safety, legality, or quality which include changes to:
• Raw material suppliers
• Formulation (including any changes to
formulation of supplied materials)
• Manufacturing processes or inspections
Check Site Compliance to ;
MO-043 Change Management Guidelines
MO-043-A Operations and Supply Chain Change Management Checklist
Change Management Records: MO-043 Change Management Guidelines MO-043-A Operations and Supply Chain Change Management Checklist
The change management records must include:
• A description of the change
• The planning for the change
• Review of the changes by the HACCP Team for any impact on food safety, legality or quality
• Identification of any documentation that needs to be updated, including the HACCP plan
• Notification to the Coles CBM / PT of any changes that can affect product safety, legality, or quality.
• Changes to equipment or locations
• How the changes will be reviewed after completion of the change to ensure food safety or quality has not been compromised.
Site Management and Communication; CFMSR 4.3 Site Management; CFMSR 4.5 Site Communication; BRC 1.1.4
Senior Site Management shall ensure that there is
adequate management coverage for all production
A process for communication from staff to management issues affecting food safety, legality, or quality shall be established.
The site must have a meeting program which enables Food safety, quality and legality issues to be brought to the attention of senior management at least monthly and allows for the resolution of issues needing immediate action.
Root Cause Analysis: CFMSR 4.8 Root Cause Analysis
Management shall establish, document, and implement a methodology for root cause analysis that is undertaken when responding to non conformance at the site. This shall include;
• Assignment of responsibility and time frame for action
• Prioritisation of issues based on risk status
• Consideration of impact on food safety and quality
• Identification of corrective actions (including any short term (temporary) and long term actions and responsibility and timeframes for completion
• Identification of preventive actions to prevent occurrence of any potential issues and responsibility and timeframes for completion
• Implementation of changes to procedures and HACCP Plans
• Training of personnel in any changes to documentation or process changes
• Validation of any changes to the HACCP documentation
• Approval by the HACCP Team
• Verification audit to ensure implementation and ongoing implementation is effective.
Complaints (Completed by Corporate)
Complaints General CFMSR 7.1, 7.2 Complaints Procedure; WSEP Section 1.7 -1.7.3; BRC 3.10.1
A documented policy and procedure to handle complaints must be in place.
Complaints from all methods of reporting (e.g. mail, telephone, email, websites, and social media where used) must be captured on a logging system.
Each complaint must have a unique reference number. Complaint log includes:
• Date of complaint
• Nature of complaint
• Product information
• Product code e.g. best‐before / use‐by
• Whether product sample has been requested
• Person assigned to manage the complaint
• Corrective action
• Complaint close‐out date
All complaints must be investigated in detail by competent personnel.
The investigation must determine whether the complaint is product specific or an issue which may affect more than one product.
The complaint handling procedure must identify what information to check depending on complaint type.
Complaint types can include examples such as:
Foreign bodies, alleged illness, taste, quality, correct quantity, labelling, llergens.
Full records must be kept and the outcome of the investigation promptly reported to relevant personnel and departments.
Corrective actions must be effective to prevent reoccurrence. Where requested the full corrective actions must be reported to a Coles or WW CategoryBrand Manager or Poduct Technologist.
Detailed records of communication with both Coles/ Woolworths and the customer must be retained showing effective and diligent complaint investigation, resolution and corrective action.
Complaint Trend Analysis WSEP 1.7.4; CFMSR 7.5; BRC 3.10.2
Complaints must be trend analysed by volume produced and complaint category as a minimum, and should include all product produced on site as well as Private Label products.
Trend analysis, investigations and details of individual complaints must be maintained and available to Woolworths or Coles upon request.
Corrective action should be applied to individual complaints and root cause(s) in a timely manner to reduce and eliminate reoccurring complaints.
Complaint numbers must be tracked and trended against units sold and complaint type.
Complaint targets must be set and agreed with the Coles/Woolworths Product Technologist for House Brand Products.
Complaint trends must be monitored and compared against targets.
An increase in complaints must prompt an investigation.
Information from trend analysis of complaints must be communicated to the site management and production teams.
Up to date complaint trend information is graphically displayed on suitable notice boards at site access points with examples displayed to increase awareness e.g. foreign bodies.
Complaint Mechanisms must be in place for briefing and discussing preventative action with production teams.
Complaint Reduction CFMSR 7.6
A target for complaint reduction shall be agreed with the Coles or Woolworths CBM / PT for Private Label Brand products and the site must have a plan in place to reduce complaint levels in general and for worst offending categories/products.
Food Safety Incident Escalation CFMSR 7.7
If a food safety or legality issue is detected through customer complaints, the complaint procedures must document how issues will be escalated to the recall, withdrawal, and incident management procedures.