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M&S FOR THE SEGREGATION OF MARKS AND SPENCER RAW MATERIALS AND FINISHED PRODUCTS CARRYING A BRAND INTEGRITY CLAIM Jan 2017 v3
M&S Section 1 - Responsibilities
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1.1. M&S A List Raw Material & Finished Product Suppliers must: Establish a suitable, trained, multi-disciplined team to review Brand Integrity. The skills of the team members must be relevant to allow thorough risk assessment of threats and vulnerabilities to the end to end raw material supply chain (farm to finished product). This team must include technical, operations and procurement/purchasing as a minimum, and could be an extension of the HACCP team. We are referring to this team as the site TACCP team, with the focus on raw materials, supply chain & product vulnerability. Identify and risk assess any raw materials, finished products and processes that carry a Marks & Spencer Brand Integrity Claim. Understand the points within the complete end to end supply chain that are at risk of the Brand Integrity Claim being compromised. Implement controls for the identified risks to ensure they are removed or mitigated to an acceptable level. Have in place a robust verification process.
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1.1. M&S A List Raw Material & Finished Product Suppliers must:<br>The risk assessment must consider: The potential for contamination with another raw material with a different Brand Integrity Claim during the complete end to end supply chain, parts of which may not be directly within your control. The potential for contamination with another raw material with a different Brand Integrity Claim that is within your process and therefore within your control. The storage and handling of raw materials at all stages of the process:- Harvest through to despatch of raw materials or finished products, Slaughter & butchery through to despatch of raw materials or finished products. Catch & filleting through to despatch of raw materials or finished products, Intake of raw materials, WIP, processing, assembly through to packing and despatch of raw materials or finished product. The potential for process equipment to be a cause of cross-contamination. The potential for rework or recirculation processes to cross contaminate. The potential for wrong product in pack/wrong label on product. The potential for contamination from personnel. The potential for contamination from other sources – environment, production routes & raw material/product movement & transfer. Efficacy of hygiene procedures in ensuring segregation.
M&S Section 3 – Risk assessment for all ‘A list’ Raw Material & Finished Product Suppliers
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Essential Requirement: All sections must be completed and form an integral part of a sites internal control and audit program. The supplier must be able to demonstrate the implementation of the risk assessment outputs within the factory environment. There must be robust GMP & factory segregation controls to ensure products are manufactured using methods that maintain Brand Integrity.
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Complete the following 5 steps: Step 1<br>Identify and document all brand integrity claims on site and their associated products.
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Step 2 Document all process steps that the products and associated components/raw materials go though. Identify the potential points in the process where brand integrity claims could be compromised. This could be cross contamination, or incorrect use.
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Step 3 Risk assess each point in the process of potential compromise and determine whether it is ‘low risk’ or ‘at risk’.
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Step 4 For all ‘at risk’ points identify and document all actions needed to reduce the risk to low. If this is not possible an action plan in order to mitigate the risk to an acceptable level must be put in place.
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Step 5 Review the risk assessment and any associated mitigations with your M&S lead technologist.
M&S STEP 1 - Identify and document all brand integrity claims on site and their associated products.
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The site must have identified and documented every UPC or bulk raw material for upstream use in the M&S supply chain, with any Brand Integrity Claim. The supplier must document all finished products on site carrying a Brand Integrity Claim. If the claim is related to a raw material within the finished product then the associated raw materials that carry the claim must also be listed.
M&S STEP 2. Document all process steps that the products and associated components/raw materials go though. Identify the potential points in the process where brand integrity claims could be compromised. This could be cross contamination, or incorrect use.
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The site must have a documented risk assessment identifying the processing points and cross contamination risks from undeclared, unintended or incorrect raw materials. This must capture all processes, products and raw materials onsite. This must include mapping the flow of the raw materials during the end to end supply chain. Some cross contamination causes which may be outside of your direct control i.e. any risks identified prior to your first point of handling (e.g. goods intake), however these must still be considered and must be documented in the raw material specification. The objective of this stage of the risk assessment is to establish any risks of contamination at any stage of handling/ production that therefore has potential impact on the Brand Integrity Claim of the finished product.
M&S STEP 3 - Risk assess each point of potential compromise and determine whether it is ‘low risk’ or ‘at risk’.
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Identified hazards must be graded as ‘Low risk’ or ‘At risk’. Supporting evidence must be available to justify the decision. The risk assessment must be based on current controls and practices. Colour coding should be used to provide clear information on the table. At Risk is defined when there is probable or possible compromise of the Brand Integrity Claim within raw materials or finished products, without further controls in the process to prevent this. Low Risk is defined when the risk of compromise to the Brand Integrity Claim is remote or does not exist.
M&S STEP 4: For all ‘At Risk’ points identify and document all actions needed to reduce the risk to low. If this is not possible an action plan in order to mitigate the risk to an acceptable level must be put in place.
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The site must have an up to date document that states the control measures in place to ensure that any highlighted ‘At Risk’ points in the process/supply chain are satisfactorily controlled so that any Brand Integrity Claims on M&S products are robustly maintained. The resulting action plan must be robust, documenting the Brand Integrity Claim at risk, the area of site and process under consideration, the area of concern along with the rationale behind the decision. Any control measures currently in place and any further controls that are required must be detailed with agreed and appropriate timescales for completion.
M&S STEP 5: Review the risk assessment and any associated mitigations with your M&S Lead technologist.
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The results of the action plan must be discussed and reviewed with the M&S Lead Technologist for your site.
M&S Section 4 - Specific Segregation Requirements
M&S 4.1 Raw material control in the Primary supply base
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4.1.1 The direct supplier must understand the chain of custody for all raw materials carrying a Brand Integrity Claim. They must understand where there is a risk to the Brand Integrity Claim in the supply chain (e.g. they handle visually similar raw materials with different brand values, handle multi protein species or handle non-vegetarian raw materials).
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4.1.2 Where a risk to a Brand Integrity Claim has been identified in the supply chain, the direct supplier must have documented details of how this identified risk is mitigated.
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4.1.3 Assessment against this Code of Practice must be undertaken by the supplier and documented in the raw material specification. Specifications must be agreed and signed off between the raw material supplier and the M&S supply site
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4.1.4 Direct suppliers to Marks and Spencer must also request notification from their raw material suppliers if their site status changes, (e.g. the raw material supplier introduces visually similar raw materials with different brand values, multi protein species or non-vegetarian raw materials).
M&S 4.2 Manufacturing segregation
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4.2.1 Adequate segregation procedures must be in place to prevent cross- contamination risks from those raw materials and products that do not carry the Brand Integrity Claim. This applies at all stages of manufacture, including incoming good checks, storage, work-in-progress, processing, assembly, rework and packaging processes.
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4.2.2 The level of segregation required must be determined by the results of risk analysis and documented in line with this Code of Practice however below are minimum requirements that must be considered:-
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4.2.3 Where time and equipment design does not permit thorough cleaning of food contact equipment between Brand Integrity Claim products (e.g. non- vegetarian/vegetarian & protein species production), dedicated equipment must be used.
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4.2.4 Production scheduling should be managed to allow Vegan production to run first, followed by Vegetarian with Pork containing products running last.
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4.2.5 Where a site handles multiple protein species, the priority segregation must be given to Pork and Pork based products.
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4.2.5 Vegan, Vegetarian and non-vegetarian products must not be fried in the same oil. When practical, frying lines should be dedicated to the frying of vegetarian products. Where separate frying lines are not practical, the fryer must be deep cleaned prior to use for vegetarian production.
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4.2.6 For Vegan / Vegetarian, Named Raw Materials and Welfare/Legal composition standards where adequate segregation cannot be achieved, products must NOT carry the Brand Integrity Claim.
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4.2.7 Products must be designed where practical to avoid “hidden” protein species - for example Roast Beef meal containing pork gelatine gravy.
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4.2.8 Factory layout, product flow and wash room procedures should be designed to minimise the risk of cross-contamination.
M&S 4.3 Personnel Controls
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4.3.1 Where a risk of cross contamination through personnel handling has been identified, staff must wash their hands between products at all stages of the manufacturing process.
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4.3.2 To manage cross contamination risks it may be appropriate for personnel to change protective clothing or wear colour-coded/disposable protective clothing.
M&S Section 5 - Compliance monitoring Essential requirement – the site must both validate the risk assessment and verify its continued relevance and compliance. There must be a system of ensuring the mitigations identified are consistently delivered and processes adhered to. This must be part of the site’s internal audit programme.
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5.1 The risk analysis must be fully documented and must be subject to a formal process of validation by the site HACCP/TACCP team, on an annual basis.
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5.3 Where there is insufficient mitigation in place to support a Brand Integrity Claim on pack then this must be formally communicated to the M&S technologist.
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5.4 If there are any changes to the product, process or supply chain, the risk assessment must be reviewed to ensure that the Brand Integrity Claims have not been compromised.
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5.5 Challenge of the appropriateness and effectiveness of the controls must be done on a frequent basis through site internal audit. Any issues identified through this process must be incorporated into the risk assessment, new controls implemented if necessary and formally signed off by the M&S Lead Technologist.
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5.6 Internal audits must be carried out by a trained, competent member of staff.
M&S Section 6 - Policy and Procedures
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6.1 Based on the results of the risk analysis and the requirements of this Code of Practice, a documented Integrity policy must be produced, accompanied by detailed documented segregation procedures. All key control measures must be referenced within the documented policy.
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6.2 The site HACCP/TACCP team must ensure that the introduction of new products, recipe re-formulations, equipment, and any production schedule changes are fully reviewed to ensure the continued adherence to this Code of Practice.
M&S Section 7 - Staff Training
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7.1 All staff must receive comprehensive training against the identified key control measures and mitigations and have an understanding of the risk to the Marks and Spencer Brand should these not be followed.
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7.2 Appropriate documented training and refresher training must be in place for all staff involved and training records retained.
TFMS Section 14 Process control v6
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14.6 Segregation during storage and processing<br>Risk assessment must identify materials which need segregation during storage and processing e.g. chemicals, organic, allergens, sensitive materials, those susceptible to taint. Where required, suitable segregation controls must be used to reduce the risk of cross contamination or taint, and to retain the identity of the product. If dedicated lines are not in place for materials requiring segregation, the scheduling of production and cleaning must ensure the risk of cross–contamination is minimised. All equipment (including production lines and utensils) used for materials requiring segregation must be cleaned using a method which removes any risk of cross–contamination e.g. chemical cleaning, hot water cleaning, (equipment dismantled where possible), prior to use for products not requiring segregation. The type of cleaning must be selected based on site risk assessment and full validation and verification of the cleaning process. Utensils used in preparation of, or associated with products containing sensitive materials must be colour coded and only be used for those products.
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14.7 Segregation – Tesco Requirements<br>Where applicable the site must comply with the requirements as detailed in Tesco Requirements for Suppliers 60500 – Site segregation management.
TFMS Site Segregation Management 60500 September 2017 v4
3. Documentation and training
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3.1 Suppliers must have a Segregation Management System in place and this must be clearly documented;<br>Training on the appropriate sections or procedures must be provided to all relevant staff and visitors
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3.2 Suppliers must provide training that is appropriate and effective in ensuring that all employees and visitors including agency staff and contractors are aware of and understand the risks and consequences associated with all potential contaminants on site.
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3.3 Employees must receive sufficiently detailed training on any specific controls and procedures for maintaining segregation which directly form part of their job role. This includes non-production personnel such as those involved in new product development (NPD), engineers, cleaning staff, laboratory staff and production planners.
4. Risk Assessment
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4.1 All sites manufacturing Tesco products must undertake and document a risk assessment for the identification of potential contaminants. This risk assessment must include an assessment of all raw materials, ingredients, components, finished products and their derivatives on site. This must incorporate and consider their storage, transport and processing.<br>New product development and test kitchens, and sub-contracted processes in third-party sites must also be risk assessed.
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4.2 Sites manufacturing Tesco products must also ensure that establishments supplying ingredients and raw materials to them also undertake a risk assessment and establish the appropriate controls based on the steps identified at 4.4 to prevent contamination of raw materials before they arrive. See also 6.1.
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4.3 The outcome of the risk assessment must provide a clear understanding of what products and ingredients are at risk from what contaminants and where in the process this could occur.
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4.4 Suppliers must carry out validation that demonstrates that the controls are effective in preventing contamination of the final product.
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4.5 Ongoing monitoring must be in place to verify that the controls are implemented consistently and that they continue to be effective. The type of risk and form of the risk must always be taken into consideration to ensure the control is suitable.
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4.6 Evidence of the validation process and results from ongoing verification of the controls put in place must be documented.
5. Hierarchy of controls
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5.1 On completion of a risk assessment the action needed to manage the risk identified must be established. In order to ensure effective action is taken the following hierarchy of controls should be reviewed. These are given in the order of most effective first: Remove the risk from the product or process Minimise the risk to the lowest acceptable level Manage the remaining or residual risk through procedures Mitigate the risk through information and communication
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5.2 Mitigating the risk through information and communicating alone, such as through signage, is not sufficient. If the risk cannot be removed completely, information and communication about the importance of why processes and controls that manage the risk need to be in place and followed
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5.3 Once all potential contaminants and the potential locations for cross contamination have been identified through the risk assessment control mechanisms must be put in place. It is crucial to firstly attempt to prevent or eliminate the risk but where this is not possible the risk must be minimised and managed through controls and procedures that have been validated as effective.
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5.4 The risk assessment must be reviewed as a minimum annually and updated if there are any changes to the following, although this is not an exhaustive list: Your manufacturing process or equipment used Production schedules, in particular where one product might contain ingredients that have potential to contaminate products produced using the same equipment later The formulation of the product you are producing for Tesco Any other products being produced on site (either for Tesco or another customer) Raw materials or supplying sites Site design and layout and additionally; Following any incident such as where the segregation system has failed
6. Segregation management
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6.1 Process flow and site layout The risk of cross contamination will be dependent on the site layout and manufacturing process. Suppliers must therefore produce a detailed and documented flow diagram of their full operation from intake to dispatch, including people flow. This will allow suppliers to ensure GMP is maintained throughout and identify processes and areas where cross contamination could occur. By combining this with the raw material risk assessment outcome a site will then be able to implement the appropriate controls where necessary.
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6.2 Raw materials Every site that supplies Tesco product must ensure that all raw materials are only purchased from suppliers which have been subjected to the supplier’s approval process, and are therefore documented on an approved supplier list. As part of that approval, the ingredient and raw materials suppliers must also be able to demonstrate that they meet the standards required in this document and related Tesco Standards such as the Tesco Manufacturing Standard. A specification must be in place for all raw materials used on site, containing a full breakdown of all ingredients and components. The specification must be agreed and signed by both parties. If a potential contaminant within the raw materials or ingredients is identified from step 4.2 the effect and impact it will have on the final product and consumer must be assessed.<br>If full removal or replacement is not an option, for example due to the raw material being intrinsic to the final product, the potential contaminants must be documented and made available to all relevant employees to ensure awareness and understanding of the risks associated with the materials they handle within their job role, for themselves and the end consumer, and area of the site they work in. If the removal of the risk(s) is not possible, controls must be in place to effectively manage the risk. The following sections of this document not only lay out Tesco requirements in relation to segregation control but also offer suggestions of best practice. Tesco fully appreciate that each site and manufacturing process is unique and therefore it is important to note that these are only offered as guidance; however a site must be able to offer evidence that the controls they have implemented are effective and capable of managing any identified risk of cross contamination.
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6.3 Segregation <br>Storage-for example, marked areas, covered bins, controlled access (such as restricted access storage areas for nuts) o storage of products from raw materials through to finished product must be controlled to ensure that the location in which products are stored and the other products that they are stored with does not create a risk of cross contamination
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Labelling (unfinished product) - Consistent and clear labelling of raw materials (both unopened and opened) and work in progress (WIP) o Once any raw material, WIP or finished product has, through risk assessment, been identified as a potential risk for cross contamination it must be clearly identifiable.
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Personal protective equipment (PPE) - if raw materials or product are likely to contaminate employees clothing during handling, then additional protective over clothing must be worn where employees move from one preparation area from which they can carry contamination to another preparations area or where employees handle different products in succession where there is risk of cross contamination from one to the next. Additional PPE must be removed and hands must be washed once production and cleaning are completed and before entering the new area or before starting the next task. o Suitable PPE must be worn when cleaning equipment or areas which pose a potential contamination risk o The PPE must be disposable or washed prior to moving to another work area/task
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Production- fully separate and designated production /packing lines is the most effective segregation but where this isn’t possible, effective controls must be in place for example, production run planning, correct use of WIP and effective validated cleaning. o Where product capacity and/or production volume cannot justify separate area/production lines/equipment etc. this will result in a risk of cross contamination of one material with an un-specified ingredient/component. A matrix identifying all the products to be manufactured on the equipment must be cross referenced to those which may be a source of contamination. This will identify the run order and the means of scheduled separation and cleaning between the processes involved in manufacturing these products.<br>Where sieves are used for dry powdered materials the site must ensure that sieves are either dedicated or, where this is not possible, receive a fully validated clean between uses and verification is in place to ensure that cleaning takes place according to the validated procedure. o Where full separation and dedicated lines and equipment are in place, it is still important to have a segregation system in the event that full separation isn’t possible such as a breakdown in equipment, part of the establishment in closed, an increased production run and so on. There must be a documented contingency procedure that is followed in cases such as this to prevent cross contamination to lines equipment and areas that are normally completely separate.
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Control of non-conforming products o Rework must be risk assessed in the same way as all other materials used in order to determine whether the rework itself could pose a contamination risk. o Where rework is permitted and used the final product must meet the Tesco specification. o Rejects and returns shall be clearly identifiable, labelled and stored in a quarantined location to control stock movement in case there is any risk of contamination. If the reject or returns present a risk of contamination these shall continue to be held in a dedicated and segregated area to prevent contamination of other products until they are removed from the site. o Where a product is contaminated or there is reason to suspect it has been contaminated, the product must not be released to Tesco without documented approval from the Tesco Technical contact.
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Accidental contamination Immediately after a spillage where there is a risk of product contamination the site must ensure the following, although this is not an exhaustive list: o Stop production (when relevant)<br>o Control the spillage and restrict personnel movement in and out of the area to limit access to those required and authorised personnel (for example, supervisor, staff responsible for clean-up) o Quarantine all potentially affected raw material, work in progress, finished product, equipment and utensils o Use dedicated cleaning equipment and personal protective equipment to clear the spillage and any affected equipment, utensils, PPE etc. o The cleaning and removal of the spillage must be inspected and signed off by an authorised person o Carry out risk assessment of the incident to determine actions needed and whether the quarantined product is safe and fit for use, whether it needs to be further processed or whether it should be destroyed o Records of the above procedure must be kept
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6.3 Cleaning and verification Time separation with effective cleaning between production runs is the most common form of segregation control employed by manufacturing sites. Therefore where production equipment or lines are not dedicated to specific products, cleaning is critical to achieving product safety, legality and quality. Before any method of cleaning is implemented it must first be validated, with documented evidence that the control has been designed effectively. Ongoing verification and monitoring must be in place to ensure that the validated cleaning is carried out correctly and continues to be effective. Machinery and equipment must be subjected to a full and thorough inspection as part of the risk assessment in order to identify any key inspection points (where traces of residue could remain due to limited access for cleaning). This must take into account parts of machinery that are hard to reach and clean as worst-case scenarios, for example, dead legs of pipes, complex moving parts of machinery etc. Documented procedures must be in place that includes instructions on how to strip equipment down for cleaning, which equipment, utensils and cleaning products should be used and how often/when cleaning is needed, for example is cleaning to be carried out after every batch, immediately following production of batches that can be a source of contamination to subsequent batches and so on. These must include both equipment cleaned in situ and those cleaned in wash rooms/manually. Cleaning in situ must not pose the risk of spreading contamination from one line/piece of equipment/area to another. Adequate supervision and verification checks must be in place to ensure cleaning is always carried out at times specified in the documented procedure and consistently completed to the standard required, which has been validated as effective. The frequency of these checks must be determined by risk assessment. A review of cleaning resource must be regularly conducted to ensure there is enough time to clean to the required standard between production runs.<br> Where it is not practical to clean pipe work between production changeover, purging will be the principal control for ensuring any potential cross contamination is avoided. Where this does occur a detailed and documented risk assessment must be conducted in order to determine how much product is required to be pushed through, to purge effectively. All controls and procedures surrounding the purging and rejecting process must be documented and recorded as evidence that it has taken place for every relevant production run<br> Deep cleaning and changeover cleaning procedures, as well as associated swabbing, must be validated as effective. Once controls have been validated, ongoing verification (for example, visual inspection, sampling etc.) must be in place to monitor their continued effectiveness. Whenever the process or product changes, the validation must be reviewed. Validation of controls must be reviewed at a frequency based on a risk assessment but at a minimum annually to make sure the controls in place remain effective and appropriate to control the hazards and risks identified
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6.4 Finished product Labelling All finished products must only contain products or ingredients that are listed on the product label, with all allergens in food highlighted in bold in the ingredients list, and in the agreed Tesco Specification. For further information and guidance on allergen labelling, please refer to the Tesco Food Labelling Standard, document 20457.
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Storage and release A risk assessment must be completed to make sure that the finished product storage conditions are appropriate to prevent cross contamination from products that contain ingredients that could be a contaminant for other products, for example, allergens which are declared in one product but not intended to be in another and therefore not declared Finished products that pose any risk of contamination to other products must be appropriately packaged, and segregated in clearly identified separate areas where possible.Controls required for the storage of finished products shall be applied to any third party storage facilities used by the site.
Morrisons Technical Policy for the Prevention of Meat Species Cross-Contamination and Adulteration 12th August 2015 v3
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1) Identification All meat species intentionally present in raw materials, work in progress and finished products should be identified and, where necessary, clearly labelled.
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2) Adulteration / Cross contamination All meat species adulteration / cross contamination risks should be identified including: • Raw material deliveries contaminated with undeclared meat species • Meat species contaminating ingredients, work in progress, rework and finished products which do not normally contain these meat species. • Cross contamination from food handlers and food waste
Morrisons Stage 2: Risk Assessment
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Once all risks have been identified, a risk assessment should be carried out to include the following elements: - Ingredient supplier risk assessment – an assessment of each ingredient or raw material which contains meat should be made, understanding what other meat species the supplier is handling and what controls they have in place to eliminate the risk of adulteration or cross contamination (refer to Appendix).
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Process flow – a detailed diagram showing flow of ingredients, and raw materials through the entire factory process and indicating areas of concern e.g. Raw material storage – is segregation adequate between species? - Flow of people and waste should also be considered.
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Risk Assessment- A risk assessment approach should be applied to each raw material and each process step to decide on appropriate controls to be adopted in the prevention of meat species adulteration or cross contamination. The models in the Appendix should be used in the approach to risk assessment of adulteration or cross contamination.<br>Multi Species Slaughterhouses/Cutting plants and sites handling meat from different countries of origin will, on a risk basis, have a higher risk rating.
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Control Measures – All indentified risks must be assessed to enable measures to be introduced to control them.
Morrisons Stage 3: Manufacturing Standards and Controls
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3.1Raw Material Suppliers / Vendor assurance Documented procedures shall be in place to ensure that all meat raw material suppliers are approved prior to use. An Approved Supplier List (ASL) for all supplied meat ingredients / raw materials shall be maintained. The basis for approval shall be clearly defined and documented with appropriate written authorisation by competent person at the manufacturing site. All raw material suppliers shall be subjected to a formal risk assessment. This risk assessment shall be fully documented (see Appendix). All meat supplying sites on the Approved Supplier List should be audited and approved by a suitably trained and technically competent person nominated by the manufacturing site. These approval audits should include traceability exercises for meat species back to point of slaughter. Full details shall be maintained of all Approved Supplier’s supplying sites on the Approved Supplier List. This should include the nature of their business, their location and all relevant suppliers of meat into the Approved Supplier. Consideration should be given to complications of cutting plants buying from multiple suppliers who in turn may handle more than one meat species. The Distribution chain, including cold stores, should be documented and risk assessed to ensure effective arrangements are in place to eliminate adulteration and/or unauthorised re-labeling opportunities. All meat raw materials shall be traceable back to specified licensed (identified by health mark/establishment number) abattoir source. There shall be a defined process for new raw material site approval based on risk assessment.<br>There should be standardised packaging/label colours from suppliers to identify meat species where possible. • Regular traceability challenges (with frequency defined by risk rating) for suppliers shall be conducted to a specific response time to verify authenticity of material and the supplier’s ASL. • Signed raw material specifications shall be maintained for every meat containing ingredient. The specification should be signed, dated and document controlled by both the raw material supplier and the Morrisons supplier. • All meat raw material specifications shall be reviewed on an annual basis.
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3.2 MCreate Specifications • Up to date versions of MCreate specifications shall be maintained at all times and accessible to the manufacturing site. • The Ingredients / Compounds section of the Morrisons MCreate specification shall be completed accurately and in full, listing all relevant Approved Suppliers of the meat ingredient in question. Approved Supplier Lists by attachment for meat ingredients are not acceptable. • The status of the meat ingredient supplier should be indicated e.g. slaughterhouse/cutting plant with health mark/establishment number where applicable. • There shall be no deviation from any parameter on the Morrisons MCreate specification without the written approval of the relevant Morrisons Technical Manager.
Morrisons 3.3 Manufacturing Site Requirements
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3.3.1 General • Vertically integrated businesses present the lowest risk to meat species adulteration. • Single meat species factories present the lowest risk to meat species cross contamination. Failing this, single meat species production areas, single species production campaigns segregated by an appropriate time period and species dedicated production lines and preparation equipment should be employed where practical to minimise cross contamination risk. • Sufficient time should be built into production schedules to allow for product changeovers in meat species and appropriate hygiene and inspection activities to take place.
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3.3.2 Intake • Detailed intake procedures should be in place for receipt of all raw materials. These procedures shall be available to intake staff. The procedure shall include all of the following: visual inspection against documented standards, availability and assessment of accompanying documentation e.g. health documentation, certificates of conformance/ analysis and product sampling protocols. • Documented intake checks should take place for all ingredients / raw materials with documented visual inspection.<br>• Up to date product specifications with photographs for all supplied meat containing raw materials should be available for reference within the goods in area. • All meat raw material deliveries shall be verified to confirm that the supplier is on the Approved Supplier List. Records of relevant health mark information from both abattoir and cutting plant should be recorded and logged. The Approved Supplier List should be available within the goods in area. • All ingredient / raw material packaging should be clean, intact and undamaged. • Intake staff responsible for receipt of raw material shall be suitably trained in relevant procedures. Specific training of all intake staff for meat cut/species identification should take place. • Positive release for frozen meat ingredients should occur based on visual defrost checks and testing where appropriate. • All crate/case labelling should clearly indicate meat species by name. • Intake records shall document all checks for meat species. • Any cross contamination risks on delivery vehicles (especially mixed loads of different species) should be considered. • Any raw materials contaminated in any way or not detailed on the site’s Approved Supplier List shall be rejected. • Systems shall be in place to prevent possible meat species contamination at raw material receipt (e.g. cleaning of temperature probes and units or sampling equipment after use).
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3.3.3 Storage • Raw materials containing meat species shall be stored in clearly defined and suitably segregated locations selected to avoid cross-contamination of materials that contain other meat species. Consideration should be given to manage the risk from raw materials stored above other raw materials in racking. • If frozen blocks of meat are to be defrosted, the potential for contamination through drip loss shall be considered. • The integrity of packaging and containers used for raw materials must be maintained in order to prevent potential loss of their contents or ingress of cross contaminating materials. • All raw materials and work in progress shall be clearly identified with a relevant traceability code as well as details of meat species. • Any dry ingredients of meat origin handled by the site shall be suitably controlled so as not to pose a possible contamination risk. • Colour coded storage and material handling systems should be considered where this increases the security of meat species identification and segregation. • Storage containers for decanted raw materials, work in progress and re-work shall be hygienically designed, well maintained, dedicated to this purpose and clearly labelled. • Any off-site storage of meat containing raw materials shall conform to the same requirements.
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3.3.4 Processing of Meat Species<br>All production processes should be subject to risk assessment and documented controls introduced to avoid cross-contamination of meat species, for example: • Permanent or temporary physical segregation measures including staff and equipment. • Dedicated process areas and equipment where applicable. • Time segregation followed by verified cleaning where dedicated lines/processing equipment is not available. • Scheduling of production to minimise the potential for meat species cross- contamination. • Ensuring that any use of re-work is subject to formal controls, defined within the agreed Morrisons specification and does not introduce additional meat species contamination (either through the ingredients it contains or cross-contamination) to the product formulation.
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Typical examples of factory control measures include: i) De-boxing • Separate de-boxing tables and cutting boards for separate meat species should be used unless appropriate cleaning validation can demonstrate this is not required. • Clean downs shall be followed by documented checks of their effectiveness. • Awareness training for staff – these are key personnel as they handle all meats being used. • Decanting into pre-checked containers. • Clean down at shift change to ensure no confusion on what has been on tables.
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ii) Work In Progress • Should be fully covered when not in use. • Species specific coloured trays/tray liners/tote bin covers/dolav liners and labels should be used where appropriate. • Where trays/crates are used each tray/crate should be labelled/identified with meat species and traceability information. • Storage areas shall be adequately segregated where appropriate.
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iii) Mincing/ Mixing / Bowl Chopping / Slicing / Dicing • Machinery should be species dedicated wherever practicable. • All equipment should be fully stripped down to key component parts for inspections between species including worm removal (mincers) and harp/dicer grid /blade (dicers/slicers) wherever practicable. • Equipment cleaning between species should be documented and verified visually and using suitable testing where appropriate.<br>• Species dedicated plates/spacers should be used – including segregated controlled storage of these parts. • Use of species dedicated knives should be considered with appropriate hygiene and demonstrable change of knives between species. • De-gristler pipework should be dismantled and cleaned between species. • All meat from de-gristlers should be removed from production areas before new species are introduced. • All equipment seals should be removed. • All equipment used for dismantling/assembly should be included in hygiene checks. • All equipment/utensils used for fat analysis should be cleaned / inspected. • Particular attention must be paid to difficult to clean areas – where necessary, provision shall be made for suitable lighting/torches and gantries to permit effective inspection. • Particular attention should be paid to gas cooling injection ports/nozzles on injection mincers/ mixers, doors, bearings and seals, mixing paddles (rotate to ensure all surfaces are clean), knives, dust / gas extracts, hoppers, pipework
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iv) Conveyors • Conveyor systems should be capable of being cleaned down effectively between species. • Rapid release belts should be utilised to assist clean downs between species.
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v) Utensils • Colour coded utensils should be utilised where possible. • Suitable cleaning equipment in good hygienic condition should be utilised for clean downs.
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vi) Rework • Rework shall only be used within products where its use has been specifically defined within a finished product specification. • Rework shall remain fully traceable back to specific batches and shall be used on a like for like basis.
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3.4 Cleaning and Hygiene Effective cleaning to a clearly documented, verified procedure is critical in avoiding meat species cross contamination. The following points should be considered: • Documented cleaning procedures and programmes shall be in place to ensure that all equipment and utensils used within production and storage areas are suitably cleaned when moving from one species to another.<br>• When changing meat species, a full deep clean (to key component parts) shall be undertaken and its effectiveness verified by inspection and sign off. • Cleaning procedures shall detail the cleaning method (including clear instructions on how equipment is to be dismantled), chemicals to be used (including concentration) and the equipment to be used. • The efficacy of the cleaning processes (including tray washer equipment) required for meat species control shall be validated by identifying key inspection points and undertaking ATP swabbing or other means for detecting protein/DNA residues. • The efficacy of cleaning undertaken between products containing different meat species should be validated on each production line. Such validation shall consider ‘worst case’ conditions and be performed on product taken from the line immediately after cleaning has been carried out and production resumed. Where the product is subject to processing e.g thermal sterilisation that results in significant degradation of DNA, consideration shall be given to testing product prior to this processing stage. • The ongoing effectiveness of such cleaning processes shall be verified by inspecting such points after cleaning and ensuring they are ‘visually and physically clean’ before the equipment is returned to service. ATP/protein swabbing should be undertaken on a risk assessed basis to verify that the cleaning operation has removed all meat species residues. • The cleaning of all shared equipment should be considered e.g. mincers, mixers etc. • Personnel (including contractors) who undertake cleaning activities should have full, documented training in meat species controls. • High pressure washers may spread meat species by splashing and should be avoided wherever possible. • Transfer of meat species through shared cleaning equipment such as tray washers. • Identification and disposal of waste containing meat. • Cleaning equipment design to ensure it is suitable for cleaning difficult to clean equipment e.g. pipes/nozzles. • Suitability of cleaning chemicals to ensure they are capable of removing high levels of meat protein and fat residues. • Removal of seals to facilitate cleaning. • Cleaning schedules to have higher level of approval (supervisor, line manager) to ensure all Key Inspection points are covered. Consideration should be given to difficult to access/inspect areas e.g. rear of mincers. • Use of ATP/Protein swabbing to positively release equipment back to production after cleaning. Such checks should be conducted by personnel who are not themselves engaged in the cleaning tasks that require verification. • Maintaining cleaning records that confirm all cleaning operations have been completed in accordance with the cleaning schedules
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3.5 Finished Product Packaging • Product packaging used on lines may potentially be a source of meat species contamination particularly if the same trays/films etc can be used for more than one product and should be considered as part of the risk assessment.<br>• Removal/disposal of packaging must be incorporated in product change over procedures and checks where appropriate
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3.6 Traceability • The site shall have a suitably robust traceability system which allows raw materials and work in progress to be clearly identified throughout the production process. • The site’s forward and backward traceability system shall be tested to verify effectiveness at least twice per year. The traceability exercises shall include a mass balance reconciliation and shall demonstrate full traceability to abattoir source within a 4 hour time period. The traceability challenges shall incorporate products where specific origin/provenance and/or assurance claims are made.
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3.7 Personnel and Training (including staff, visitors and contractors) • All relevant staff should have full, recorded training in meat species awareness, meat species identification where appropriate and site management procedures. • Staff with responsibility for assessing raw material specifications for meat species risk and subsequently inputting information onto the Morrisons MCreate specification should have attended appropriate training in order to perform this task effectively. • Appropriate personal hygiene and protective clothing procedures should be in place to prevent personnel becoming vectors of meat species cross-contamination. • Where hand washing and changing/disposal of protective clothing is necessary to prevent meat species transfer from one production run to another, there should be formal systems to ensure that these disciplines are routinely applied and effective. Particular attention should be paid to use of safety gloves/ chainmail gloves/ chain aprons where appropriate hygiene can be difficult due to the complex construction of these items
Morrisons Stage 4: Validation and verification
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The effectiveness of all process control measures should be validated prior to implementation. Verification activities should be conducted at intervals determined by risk assessment to confirm the on-going effectiveness of these measures, including: • Meat species surveillance testing of raw materials, work in progress and finished product to ensure the absence of any adulterant or unacceptable cross contamination based on risk assessment (see Appendix). • Swabbing product contact surfaces after cleaning to demonstrate the removal of meat species residues.<br>• Auditing personnel and processes for adherence to meat species control procedures
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4.1 Laboratory testing and methods • Any laboratory commissioned for meat species testing should be ISO/IEC 17025 accredited. • The polymerase chain reaction (PCR) forms the basis of nearly all DNA analyses undertaken to identify the presence or absence of particular species within a food product. Real-time PCR methods are available to determine the presence of meat species on a ‘semi-quantitative’ basis. In many cases, testing will consider a variety of species that may be present in the sample, either legitimately or by reason of contamination/adulteration. Positive results may be verified by DNA sequencing. • There are a number of commercial Enzyme-Linked Immunosorbent Assay (ELISA) test kits available for the detection of specific species in meat products. Use of these test kits is acceptable so long as they are sufficiently sensitive for the intended application and laboratories can demonstrate competence in their usage. • Care must be taken to ensure that the test method employed is suitable for the material being tested. Physical and thermal processing of meat products can result in significant DNA degradation thereby compromising the ability of DNA-based methods to detect targeted meat species. ELISA methods are dependent on protein-specific antibodies and thermal/physical damage to these proteins may prevent them from being detected. There may be cross reactivity with non-target meats species or other artefacts. The limit of detection may not be suitable for low levels of meat. • The limit of detection of methods employed for validating the efficacy of cleaning processes through testing ‘worst case’ products shall be capable of detecting the presence of 0.1% meat species in the product on a w/w basis. • Test method used for verification purposes should, as a minimum, be capable of determining 1% meat species in the product on a w/w basis. Where other meat species present adulteration or cross contamination risks, the method should be capable of determining these on at least 1% w/w meat basis. • The need for finished product and raw material speciation testing should be determined by risk assessment. The risk assessment should consider the potential for deliberate adulteration and cross contamination. The risk assessment methodology defined in the Appendix should be applied and shall determine the nature and frequency of speciation testing of meat raw materials and finished products. • Testing shall consider ‘worst case scenarios’ e.g. sampling product manufactured immediately after another product that contains a meat species not present in the recipe of the first product.
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4.2 Internal Audits • The site shall have a documented programme for integrity and traceability audits. • Regular internal audits should be conducted at a frequency defined by risk assessment against the contents of this Policy as part of the supplier’s Quality Management System • Any non conformities arising from these audits shall be communicated to the senior management on site for review and corrective action.
Morrisons 5.0 Corrective Action
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• Suppliers should ensure effective corrective action is taken should any area of non-compliance with this Policy be identified.<br>• • • In the event that the meat species status of a Morrisons product is compromised in any way, the relevant Morrisons Technical Manager should be informed immediately by telephone. In the event that the Technical Manager is not available, or the incident occurs out of hours, the Morrisons Technical Out of Hours telephone number (0845 611 5338) should be used. All incidents resulting in the need to effect withdrawal or public recall of a product owing to compromised meat species status should be subject to a supplier formal investigation. The report of this investigation, confirming the specific corrective action to be taken to address the root cause of the incident, should be submitted to the relevant Morrisons Technical Manager
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