Risk Assessment: WSEP CoP 2.1.1 Risk Assessment; BRC V8 4.9; CFMSR V2 33.1 Foreign Body Controls and Risk Assessment; SQF ED 8 9.7.4 Control of Foreign Matter

  • WSEP CoP 2.1.1 Risk Assessment; BRC V8 4.9; SQF ED 8 9.7.4 Control of Foreign Matter
    - A risk assessment, carried out using HACCP Principles, must be documented. This must cover:
    • Glass and Hard (Brittle) Plastic in production & storage areas including 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.
    • The use of wood within the site’s production and storage areas.
    • The type, use and positioning of metal tools, implements/equipment in production and stores
    • Plastic films and bags (e.g. empty bottle bags), disposable PPE, WIP bags, etc.
    • The use of cardboard and paper
    • Maintenance procedures, tools, lubricants, cloths
    • Each process is assessed to identify potential equipment to detect or remove foreign–body contamination.

    The risk assessment should 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 or deterioration.
    The expectation is that this risk assessment will be completed using HACCP principles and be documented in the HACCP plan.
    Note: This is normally covered in your HACCP programs under Physical assessment. Please review all HACCP systems to ensure all potential foreign object groups above have been noted in HACCP Hazard Analysis sheets.
    Use of pressurised air lines must be risk assessed to ensure it is not a risk to product integrity and/or cross contamination.

Elimination/detection systems (where applicable to site): WSEP CoP 2.1.2

  • Where elimination/detection systems are used, establish limits for detection based on the type of product and its packaging as well as the position of the detector in the process.
    The system must operate at the optimum setup with validation records to demonstrate how the optimum setup is established.
    ● Consider line speed in the set up and the validation process.
    ● Where multiple detection systems are utilised (such as sieves and metal detector), validation records must include both systems and it should demonstrate how the limitation of one detection system is being covered by the other.
    ● The system must be located at the appropriate point of the process to effectively remove the target foreign body and this location recorded.
    ● The setup can be maintained without periodic adjustment.

  • Verification & Monitoring of Elimination Detection Systems WW CoP 8.1, 8.2
    All checks on the elimination/detection system must be documented and signed by the trained personnel who have carried out the check. THE ACTUAL TIME OF THE CHECK MUST BE RECORDED, the checks should include:
    ● Date, Shift, Operator responsible.
    ● Product name, size, quantity of run, identification (batch or date code).
    ● Start of production, during production (at a defined frequency) and end of production.
    ● Details of the checks (e.g. what was checked? How was it checked?). The strength or size details must also be recoded.
    ● Amount of rejects (count, weight or volume)
    ● Corrective actions for any failed checks. Investigation on any rejected product from production.
    ● Magnets must be kept magnetically clean

    All employees must be briefed on the material handling procedures during induction.
    All production managers and engineers must be trained to understand and apply these procedures and those of any elimination/detection systems used.

  • WW CoP 8.1, 8.2 Verification & Monitoring of Elimination Detection Systems - All checks on the elimination/detection system must be documented and signed by the trained personnel who have carried out the check.
    THE ACTUAL TIME OF THE CHECK MUST BE RECORDED, the checks should include:
    ● Date, Shift, Operator responsible.
    ● Product name, size, quantity of run, identification (batch or date code).
    ● Start of production, during production (at a defined frequency) and end of production. ● Details of the checks (e.g. what was checked? How was it checked?). The strength or size details must also be recoded.
    ● Amount of rejects (count, weight or volume)
    ● Corrective actions for any failed checks. Investigation on any rejected product from production.
    ● Magnets must be kept magnetically clean

  • Training 8.2 - All employees must be briefed on the material handling procedures during induction.
    All production managers and engineers must be trained to understand and apply these procedures and those of any elimination/detection systems used.

Equipment Controls: WSEP CoP 2.2.1

  • All pens used in production, storage and packing areas must be site issued, one piece and of a contrasting colour.
    Staples, hole punches, drawing pins etc. must not be used in production, packing or storage areas.
    The number of miscellaneous items should be kept to a minimum and must retained in a closed container with an inventory.
    Required miscellaneous items and utensils must be of a contrasting colour, detectable where possible and managed e.g. calculators, rulers, scoops.
    Does the site have a register of necessary items permitted to be used in processing/packaging areas? (Visitors and contractors must also comply to this list).
    Note: If the site has a metal detector, detectable equipment required in processing area must be sourced where available.(e.g. scrapers, detectable one­ piece pens and stainless steel clipboards).

Foreign Object Identification, Reporting and Auditing: WSEP CoP 2.3.1, 2.3.2; 2.3.3; CFMSR V2 33.5, 33.7

  • Is there a “bag/bucket audit” of open product/process areas conducted weekly?
    Note: MO-023 Foreign Matter Bucket Walk states weekly for this bucket walk.
    Immediate surrounds of fillers are checked as part of the Pre-start checks daily.
    Are results of the bucket audit recorded.
    Is there a system in place to report a foreign object finding? This must include an investigation, root cause and any corrective/preventive action.
    Foreign object findings must be documented and trended to establish any common sources.
    Does the site have a foreign object reduction target?
    Coles Medium Areas: Procedures must be in place for actions when foreign bodies are found (e.g. ‘Bag and Tag’ systems to document what was found, when, and where).
    A full investigation must take place to ensure the source of contamination is identified and corrective action plan implemented and product is dealt with in an appropriate manner.
    Details of the investigation must be recorded.

    Does site have start-up checks of the production line and immediate environment before production commences? This should include:
    • Condition of glass like materials and perspex
    • Machinery functioning with no loose nuts, bolts, screws, etc.
    • Conveyors with no missing pieces or shredding sides. Any missing pieces are to be recorded, monitored and their replacement planned by maintenance.
    Is the start­-up check documented and signed by the manager responsible for the area?

Training: CFMSR V2 33.3, 33.13

  • Are all employees briefed on the Glass, Brittle /Hard Plastic, and Ceramic, Metal and Wood procedures at induction and refresher training?
    Note: All staff involved with foreign body detection must be trained not only in the technical and operational aspects but also in the principles of metal and foreign body detection to ensure full understanding of the purpose at induction and refresher training.

Glass / Hard Plastic and Ceramic Control: CFMSR V2 33.8; WW CoP 3.1, 3.2; BRC V8 4.9.3 General Requirement; CFMSR V2 33.10 Glass and Plastic Register; CFMSR V2 33.11 Glass, Plastic & Ceramic Audits

  • Are all glass, brittle / hard plastic and ceramic items protected (e.g. protective film applied to windows, machine control screens, mobile phones, tablets, etc.). Are light bulbs/fixtures/fluorescent tubes shatter proof or covered?
    Is there a register of all glass, brittle /hard plastic, ceramic, and other like items in:
    • Production areas
    • Storage areas
    • Production offices
    • Employee facilities
    • Maintenance areas
    • Laboratories

    Is it reviewed/audited annually?
    The audit must record the condition of the item e.g.intact, broken, damaged but intact, undamaged etc.
    Areas over open product or packaging shall be assessed daily as part of pre-start operational checks.

    Note: MO-004 Glass, Hard and Soft Plastics and Ceramics Management - requires yearly audits of glass, plastic and ceramic items on register.
    Site Register must be a controlled document - MO-004-0? Glass, Plastic and Ceramic Register.

  • Glass, Hard Plastic and Ceramic Breakage: CFMSR V2 33.12; BRC V8 4.9.3.3; WW CoP 3.3; WW CoP 3.6 Glass Replacement
    Is the site aware of the procedure in place for the management of Glass, & Hard (Brittle) Plastic breakage - MO-004 Glass, Hard and Soft Plastics and Ceramics Management This includes:
    ● Details of cleaning methods and equipment
    ● Stopping of production
    ● Restriction of movement through the affected area
    ● Quarantine 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 glass­like materials, e.g. 10 metre radius.
    ● Report to management
    ● Clean up of breakage, safe removal of glass from area and disposal/cleaning of cleaning equipment
    ● Repair or replacement of damaged item
    ● The checking of PPE (including footwear) and changing if necessary
    ● Completion of incident log/sign off that production can restart, by a responsible/senior person.
    ● Where practical, piecing fragments back together to determine whether all of glass has been accounted for.
    ● A sample of broken glass must be retained in a safe manner.
    ● Corrective action to prevent reoccurrence
    Note: Glass Breakage Management is covered in MO-004 Glass, Hard and Soft Plastics and Ceramics Management procedure.
    High pressure water, compressed air hoses or vacuum cleaners are not to be used as these are known to increase the dispersion of the broken material.
    Where possible, glass replacement should be carried out outside production hours. Records should be kept of any glass replacement work in production areas.

Control of Soft Plastic: WW CoP 6.1, 6.2; CFMSR V2 33.26, 33.31, 33.33

  • Soft / flexible plastics used for disposable protective clothing, must be contrast coloured.
    The company must work with its raw material suppliers to ensure raw materials are delivered in the most appropriate packaging.
    Plastic bag liners must be in a contrasting colour.
    Do opening/resealing methods minimise the risk of potential contamination. e.g. use of scissors or sharp knife and not tearing or plastic of sufficient gauge (thickness) that the risk of tearing is reduced.
    The use of food containers (e.g. bottles, bags etc.) to store other materials (nuts, bolts) must not be permitted
    Plastic liner‐bags used during production (e.g. for temporary storage of ingredient, work in progress, rework or primary packaging), must be in a contrasting colour to the product.

Wood Control: CFMSR V2 33.15; WSEP COP 4.1; BRC V8 4.9.5

  • Is the use of wood in production, storage and maintenance areas eliminated (e.g. hand tools, pencils, clip boards, brooms, furniture, etc.)?
    Are wooden pallets in good condition - not posing a contamination risk?
    Are raw materials and product protected from contamination by wood splinters through use of a slip sheet or other physical barrier

Cardboard, Paper and Labels: WW CoP 7.1; CFMSR V2 33.24

  • Is cardboard use minimised on site and not used in open product handling areas?
    Where raw materials are packaged into cardboard, safe knives must be provided for opening product so cardboard is not torn.
    Tags (of any materials) used in production areas must be controlled and detectable where possible.
    Packaging CFMSR V2 33.28 - All unnecessary packaging must be removed prior to transfer of raw materials and packaging into production areas but traceability must be maintained.
    All wrapping must be removed from materials before cutting (e.g. cheese).

    Labels CFMSR V2 33.36.1; WW CoP 7.2.2
    Paper labels in open food areas must be kept to a minimum. They must be controlled and a contrasting colour to product.
    Is all signage secure and effectively sealed against the wall e.g. to minimise the risk of debris collecting between sign and wall?
    Cardboard must not be used for signage and all signage must be washable


Metal Control: CFMSR V2 33.20; BRC V8 4.9.2, 4.9.2.2; WW CoP 5.1 – 5.4 Equipment

  • Are company issued, captive, identified, numbered and registered knives, blades and scissors only used? Snap‐off blade knives must not be used.
    Equipment must be accounted for, condition checked at start and completion of production day by independent person.
    Is the procedure MO -030-01 Knife and Scissors Management in Production Areas, implemented for the control of metal objects used in production e.g. knives, needles, scissors?
    Is safe storage available for this equipment? Knives and blades must not be stored in personal lockers.
    Is there a record of inspection for damage to these items?
    Is the disposal of used or damaged knives and blades as per the above procedure?
    Is procedure followed for disposing of used knives, blades, scissors, and needles.
    Are replacement knife blades securely controlled by Supervisor?
    Are there cleaning procedures for knife blades and scissors?
    Staples, paper clips and drawing pins are not to be used in open product areas.
    The number of miscellaneous items should be kept to a minimum and where possible retained in a tool box with an inventory.
    Note: Plastic scabbards are only to be used for temporary knife storage due to potential of cross contamination – allergens.

  • Maintenance and Engineering: CFMSR V2 33.21; WW CoP 5.3
    Are Maintenance equipment, tools, and parts counted / checked at the beginning and end of each task? This is normally done using the Toolbox Inventory.
    In the event of damage or loss, all parts must be accounted for and the incident logged.
    Corrective action must be taken to prevent reoccurrence.
    Are swarf mats used in the Maintenance workshop?
    Are wire brushes and scourers in good condition and stored away from the production process or below product height when not in` use?
    Note: Pre-op start‐up checks of equipment must identify damaged or missing parts.

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