201003-201103 Renolds Report

F002: Global Standard for Food Safety Issue 5: January 2008
Audit Report
Global Standard for Food Safety Issue 5 : January 2008
Audit grade: Audit type:
A Announced 12 months
Audit result:
Certificated A
Previous audit grade:
Audit Frequency :
Company Details
BRC Site Code : 1808387
Company Name : Reynolds Site Name : National Distribution Centre Address : Britania Road, Waltham Cross, Hertfordshire Country : UK Telephone : 0845 6348293 Company Representative Name : Ian Booth Email : ian.booth@reynolds-cs.com Postcode : EN8 7RQ Fax : 0870 762 4323
Certification Body Details

Name of Certification Body : NSF-CMi Certification Auditor Number (only one - team leader) 207016 Auditor Names
Alex Howells
NSF-CMi Certification. Long Hanborough Business Park, Long Hanborough, Oxford OX29 8SJ
Issue ref NSF-CMi BRC Food RF25 Issue Date 23/03/10 Issue No 13
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Report No: A00722P
Auditor: Alex Howells
This report shall not be reproduced in part without the permission of NSF-CMi Certification
Audit Report
Audit Start Date: Re-audit Due Date: 2010-03-24 2011-03-29 Audit Finish Date: Previous Audit Date: 2010-03-24 2009-03-25
Scope Details
Product Categories Food5 5 - Fruit, vegetable and nuts
Scope of Audit The pre-packing, storage and distribution of fresh produce and the storage and distribution of ambient, chilled and frozen factored goods Exclusions from Scope None Products in production at the time of the audit Citrus products
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Key Personnel
Name/Job Title
Note: the most senior operations manager on site should be listed first and be present at both opening & closing meetings (ref: clause 1.12) Opening Meeting
Present at Audit (x)

Site Inspection Procedure Review Closing Meeting
Mike Holdsworth Finance Director Ian Booth Technical Director Louise Martlock Days Operations Manager Mike Evans Project Manager Ashley L Shift Operation Manager Russell Smith Head of HR Jim Paton Head of Operations Andrew Cutter H&S Officer Colin Baker Distribution & Planning Manager Mathew Wale Head of Procurement Dave Hilling Head of Sales Foodservice Stuart Lawson Technical Manager Marc Ellam Head of Contact Centre Nagaraju Sayamoni QA Technologist Francis Manay QA Administrator Audrey Tomkins Chilled Technical Manager Graham Shore Facilities Manager
x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x
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Company Profile
Reynolds is a family owned and run company operating out of a 140,000 sq ft National Distribution Centre at Waltham Cross (Herts.). The business specialises in the supply of fresh fruit and vegetables, salads and other short shelf life chilled products which are delivered on a daily basis nationally through its 5 U.K distribution centres. The client base compromises of many prestigious national restaurants, hotel and pub chains and also includes national and regional contract caterers, airlines and major high street brands. The Waltham Cross Depot offers its clients many different solutions from: logistics, automated electronic conveyor picking, packing, procurement and consolidation of client bespoke and stocked product lines. Reynolds has had the BRC technical standard certified at higher level /Grade A for 11 years in succession. Reynolds employs over 670 people nationally and has in excess of 170 delivery vehicles in operation every day of the week. Their motto is We do not want to be the biggest, just the best
Audit Duration Details

On-site audit duration 10 man hours
Duration of production facility audit 3 man hours Reasons for deviation from typical or expected on-site audit duration or typical site inspection duration The BRC audit was completed on one day as it is a low risk operation, with a well structured HACCP system and Quality Manual, and the company was well briefed and prepared. Has customer opted for unannounced option for subsequent audits? No
Audit Duration per day

Start time Day 1 09:00 Finish time 19:00
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F002 Global Standard for Food Safety Issue 5: January 2008
Audit Report
NON-CONFORMITY SUMMARY SHEET
List of Non Conformities

Critical or Major Non Conformities Against Fundamental Requirements
No Requirement ref. Detail of Non-Conformity Critical or Major? Anticipated Re-audit date
Critical
No Requirement ref. Detail of Non-Conformity Corrective Action Anticipated re-audit date Reviewed by
Major
No Requirement ref. Detail of Non-Conformity Corrective action taken Evidence provided Document Photograph Visit / Other Reviewed by
Minor
No Requirement ref. Detail of Non-Conformity Corrective action taken Evidence provided Document Photograph Visit/Other Reviewed by
Issue ref CMi BRC Food RF25 Issue Date 23/03/10 Issue No 13
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FOO2: Global Standard for Food Safety Issue 5: January 2008
Audit Report
Detailed Audit Report

BRC Requirement No.
REQUIREMENT
Conforms
Details
Y, N or N/A
1
1.0
FUNDAMENTAL
SENIOR MANAGEMENT COMMITMENT AND CONTINUAL IMPROVEMENT

The companys senior management shall demonstrate they are fully committed to the implementation of the requirements of the Global Standard for Food Safety. This shall include provision of adequate resources, effective communication, systems of review and actions taken to effect continual improvement. Opportunities for improvement shall be identified, implemented and fully documented. The company has an experienced senior management team led by: Chairman Managing Director Commercial Director Technical Director Head of Operations The QA Technologist and Technical Director are responsible for the day to day management of the Food Safety and Quality Management systems and reports on FS and QMS issues at senior management team meetings. Meeting minutes dated February 2010 were reviewed Continual improvements are realised through Food Safety and Quality objectives which are set annually at the management review and are monitored and their progress reviewed every month. The company has effective communication systems. The senior management team is detailed in an organisation chart referenced in clause 3.3.1. There are sufficient resources to maintain and continually improve the FS QMS. Adequate supervisory support is provided across all shifts through shift supervisors. Communication and the reporting of compliance with Global Standard requirements to senior management are achieved through management meetings and the internal audit programme.
Statement of Intent
1.1
The companys senior management shall provide the human and financial resources required to implement and improve the processes of the quality management system and the food safety plan. There shall be clear communication and reporting channels to senior management for departments responsible for monitoring compliance with the Global Standard for Food Safety. The departments shall report regularly on effective compliance.
1.2
Management meetings minutes reviewed February & March 2010 Internal Audits : See 3.5 below Management Review: See 1.7 below Quality objectives are set on an annual basis and are reviewed monthly. 1Maintain BRC 2Maintain customer service and performance levels. Food safety objectives include the person responsible and target dates Examples: 1 Provide Safe legal food 2 Foreign Body Contamination Zero Tolerance The Company is informed of food safety and legality issues by monitoring internet alert sources, regulatory authorities, etc. Issues are addressed through the technical management team at senior management meetings. The Management Review meeting was chaired by the Company Chairman. Management Review meetings take place monthly.
1.3
The companys senior management shall ensure that food safety and quality objectives are established, documented, monitored and reviewed.
1.4
1.5 1.6
The companys senior management shall ensure that there is a process to identify and address any safety or legality issue at a strategic level. The companys senior management shall take responsibility for the review process. The review process shall be undertaken at appropriate planned intervals, as a minimum annually, to ensure critical evaluation of the food safety plan and the HACCP systems suitability, adequacy and effectiveness.
Y Y Y
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1.7
1.8 1.9
The review process shall include the evaluation of: internal, second party and third party audits previous management review documents, action plans and time frames customer performance indicators, complaints and feedback incidents, corrective actions, out-ofspecification results and non-conforming materials process performance and deviation from defined parameters reviews of the HACCP-based system developments in scientific information associated with the products in scope resource requirements. Records of management reviews shall be comprehensively documented and retained. The decisions and actions agreed within the review process shall be effectively communicated to appropriate staff, and actions implemented within agreed time scales. The records shall be updated to show when actions have been completed. The company shall have the current issue of the Global Standard for Food Safety available. The company shall maintain certification to the Global Standard for Food Safety by effective timescale planning to ensure that certification does not expire (refer to Section III, paragraph 12). The most senior production or operations manager on site shall attend the opening and closing meetings of the audit for Global Standard for Food Safety certification. The companys senior management shall ensure that non-conformities identified at the previous audit against the Standard are effectively actioned.
Minutes of the Management Review meeting dated February & March 2010 were reviewed and these included all the required items.
Y Y Y Y
Minutes of the meeting, see 1.7, were available and were comprehensive. Specific actions arising from the management review meeting, see 1.7, were assigned to key members of staff and signed off when completed.
1.10 1.11
A current issue of the Global Standard for Food Safety is available on site Audit booked and completed within the scheme re-audit timescales. Audit due date 29/03/2010 Audit conducted 24/03/2010
1.12
Y Y
Senior managers attended opening and closing meetings see page 3 of report.
1.13
All non-conformances from the previous audit were effectively closed out and have not recurred at this audit.
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2
2.0
FUNDAMENTAL
THE FOOD SAFETY PLAN HACCP

The companys food safety plan shall be based on a HACCP system which shall be systematic, comprehensive, thorough, fully implemented and maintained. Codex Alimentarius HACCP principles shall be used and reference shall be made to relevant legislation, codes of practice or guidelines. The company have developed a comprehensive food safety HACCP plan, based on the principles of Codex Alimentarius. The HACCP Team is led by the Technical Manager who is trained in, and is experienced with HACCP. The most recent HACCP studies were dated 2010. The HACCP studies are fully documented and include background information of the raw materials, process flow diagrams, hazard identification, hazard analysis and appropriate control measures. Allergens are included amongst the potential hazards. CCPs have been identified, critical limits determined, monitoring frequencies and record keeping specified. Supporting PRP programmes are in place and include pest control, hygiene and maintenance programmes. HACCP is reviewed annually as part of the management review process and when there is a change to any ingredient or process. NPD procedures include a review of HACCP. Records were examined during the site inspection and the traceability exercise.
Statement of Intent
2.1
2.1.1
The HACCP Food Safety Team Codex Alimentarius Step 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 members shall have specific knowledge of HACCP and relevant knowledge of product, process and associated hazards. The HACCP food safety team shall have a designated and qualified team leader who shall be able to demonstrate competence and experience of HACCP. The multidisciplinary HACCP team is 5 people. The team includes representatives from technical, production, operations and quality.
2.1.2
Team leader: Ian Booth Experience: Very experienced in the food sector, having worked as a food safety consultant for a number of multi-national businesses. Training details: BSC Food Quality, MSC Food Quality, CCFRA HACCP, Director of SOFHT. The HACCP system is implemented and effective demonstrating competence. Training records of team members reviewed: Naaraju Sayamoni HACCP Training from the Society of Food Hygiene & Technology SOFHT. Glen Collins SOFHT HACCP Training
2.1.3
2.1.4
Records shall be maintained that demonstrate the HACCP food safety team has the required knowledge and understanding of HACCP. In the event of the company not having appropriate in-house knowledge, external expertise may be sought, but day-to-day management of the food safety system shall remain the responsibility of the company. The companys senior management shall demonstrate commitment and support to the HACCP food safety team.
Feedback from the HACCP team is included in the management meetings and the annual management review is attended by the Managing Director.
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2.2
2.2.1
Describe the Product Codex Alimentarius Step 2

The HACCP food safety team will define the specific products and/or processes that are the subject of the HACCP plan. 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. 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 of products in destination countries customer requirements.
The HACCP documentation is modular with generic reception and distribution plans. Individual process and sub processes are documented separately. Generic legislation referenced within the HACCP study: General Food Law EC 178/2002 Hygiene Laws EC 852/2004, EC 853/2004 Microbiological Criteria EC 2073/2005, EC 1475/2007 Nutrition and Labelling EC 1924/2005, EC 1925/2006
2.2.2
Allergens EC 68/2007, EC13/2000 GM EC 1829/2003, EC 1830/2003 Plastic packaging contact regulations EC 1935/2004, EC 2023/2006 GMP, EC 282/2008 Recycled plastics, EC 19/2007 Composition of plastic materials Industry specific regulations, customer requirements and codes of practice : Copies of this legislation are held. Product descriptions are adequate. Example: Fresh Fruit & Vegetables. Composition Origin of ingredients From approved suppliers Process - No processing undertaken, to be processed by customers. Packaging system - Food safe packaging material
2.2.3
A full description of the product 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, recipe) origin of ingredients physical or chemical properties that impact food safety (e.g. pH, aw) treatment and processing (e.g. heating, freezing, salting) 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 instructions for use (e.g. storage, preparation) consideration of potential misuse (e.g. storage, preparation).
Storage and distribution conditions 1-8 C Instructions for use Wash before use
2.3
2.3.1
Identify Intended Use Codex Alimentarius Step 3

The intended use of the product by the customer 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.
The intended use of the products is included in the introduction to the HACCP studies and all are intended for consumption by the general public. Vulnerable groups including infants and elderly consumers have been considered. Allergy suffers are advised on the labels that the products contain specific allergens.
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2.4
2.4.1
Construct a Process Flow Diagram Codex Alimentarius Step 4

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 materials selection through processing, storage and distribution. As a guide, this may 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 process parameters potential for process delay rework and recycling low/high risk and clean/dirty area segregation finished products, intermediate/semiprocessed products, by-products and waste. Generic flow diagrams cover raw material intake storage and distribution. Process flow diagrams available: Site Generic Flow Diagram - 20/03/10 Diagrams include: Premises plan Yes - 20/03/10
Raw Materials Yes
Sequence & Interaction of process steps Yes Process Parameters Yes Potential for process Delay Yes Segregation Yes Other elements:
2.5
2.5.1
Verify Flow Diagram Codex Alimentarius Step 5

The HACCP food safety team shall verify the accuracy of the flow diagrams by on-site audit and challenge. Daily and seasonal variations shall be considered and evaluated. Records of verified flow diagrams shall be maintained.
Flow diagrams are verified annually by site inspection by the HACCP Team 20/03/10
2.6
2.6.1
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
The HACCP food safety team shall confirm the scope of the HACCP plan and identify and record all the potential hazards that are reasonably expected to occur at each step in relation to product, process and facilities which may not be controlled by existing prerequisites. This shall include hazards present in raw materials, those introduced during the process or surviving the process steps, and allergen risks (refer to clause 5.2). It shall also take account of the preceding and following steps in the process chain. Scope of HACCP plan: The HACCP Plan aims to identify the physical, chemical and microbiological hazards present from the arrival of produce at the site to the point of despatch to the customer Hazards evaluated: Physical hazards - Splinters, Metal, Jewellery, Hair Nails, Body Fluids, Blue Plasters.
Chemical hazards Oil, Pesticides, Rodent Bait Microbiological hazards - Personal Hygiene, Allergens identified Celery and Nuts Pre- Requisites Personal Hygiene, Pest Control, Glass Control, Sickness Reporting & Medical Screening, Training, Equipment Maintenance, Site Hygiene, Product Specification, Product Recall, Control Of Non-Conformances.
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2.6.2
2.6.3
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 as a minimum: likely occurrence of hazard severity of the effects on consumer safety vulnerability of those exposed survival and multiplication of microorganisms of concern presence or production of toxins, chemicals or foreign bodies contamination of raw materials, intermediate/semi-processed product, or finished product potential for adulteration/deliberate contamination. The HACCP food safety team shall consider the control measures necessary to prevent, eliminate or reduce the hazard to acceptable levels. Consideration may be given to using more than one control measure. Justification for acceptable levels in the finished product for each hazard shall be determined and documented.
Chemical, microbiological and physical hazards are listed for each process step. Each identified hazard has been assessed for the likelihood of occurrence and the severity of its effects on consumer safety.
Records of severity / likelihood assessment are documented in the hazard analysis documents.
The hazard analysis, dated March 2010 was reviewed and included all the hazards reasonably expected to occur and their potential effects on consumer safety.
Suitable control measures for each hazard are documented. Suitable control measures are part of the prerequisite requirements programmes. Control measures:
Control measure Glass Monitoring Control measure Plaster Monitoring Pre-requisite programmes include: Personal Hygiene, Pest Control, Glass Control, Sickness Reporting & Medical Screening, Training, Equipment Maintenance, Site Hygiene, Product Specification, Product Recall, Control Of Non-Conformances
2.7
2.7.1
Determine the Critical Control Points(CCP) Codex Alimentarius Step 7, Principle 2

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. CCPs shall be those control points which are required in order to prevent, eliminate or reduce a food safety hazard to acceptable levels. 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 or later step, to provide a control measure. The HACCP studies identified controls as critical using a four question decision trees. CCP 1: Micro Contamination due to inadequate temperature control.
Records of decision trees are available with the HACCP studies and were reviewed: Records reviewed - Temperature monitoring records, validation records of refrigeration plant, service records of refrigeration plant.
2.8
2.8.1
Establish Critical Limits for each Critical Control Point Codex Alimentarius Step 8, Principle 3
For each CCP, the appropriate critical limits shall be defined in order to identify clearly if the process is in or out of control and if the identified acceptable level of the food safety hazard in the finished product is likely to be exceeded. Critical limits shall be measurable wherever possible (e.g. time, temperature, pH) and the rationale for their establishment clearly documented. The HACCP food safety team shall take into account relevant legislation or codes of practice when establishing critical limits. Any critical limits based on subjective data (such as visual inspection) shall be supported by clear guidance or examples. The HACCP food safety team shall validate each CCP. Documented evidence shall show that the control measures selected are capable of consistently controlling the hazard to the level specified by the critical limit.
Critical Limits: CCP 1: 1-8 C fridge equipment. Less than - 18C for frozen products. Critical limits conform to legislative requirements.
2.8.2
N/A Y
Not applicable there are no / details of subjective standards
2.8.3
Critical limits have been determined and agreed by the HACCP team. Critical limits are based on published data, legislative requirements, and customer requirements.
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2.9
2.9.1
Establish a Monitoring System for each Critical Control Point Codex Alimentarius Step 9, Principle 4
The HACCP food safety team shall establish a monitoring system for each CCP to ensure compliance with critical limits.
Y Y
Monitoring systems: CCP 1: Automatic temperature monitoring system in place.
2.9.2
2.9.3
Each defined CCP shall be under control. 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: online measurement offline measurement continuous measurement (e.g. thermographs) where discontinuous measurement is used, the system shall ensure that the sample taken is representative of the batch of product. Records associated with monitoring CCPs must be signed by the person responsible for the monitoring and verified, as appropriate, by an authorised person. Recorded details shall include the date and result of measurements carried out.
Monitoring systems are able to detect loss of control of CCPs in time for corrective action to be taken: Monitoring System CCP 1: Automatic temperature monitoring system in place. (Internal Audit of system)
Trained Production / QA staff are responsible for monitoring and recording the CCPs. Records are reviewed, signed and authorised by the Production / QA Manager. Examples of CCP records reviewed: CCP 1 Validation records, temperature monitoring records.
2.10
2.10.1
Establish a Corrective Action Plan Codex Alimentarius Step 10, Principle 5

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. Documented procedures shall be established and maintained for the appropriate handling of potentially unsafe products to ensure that they are not released until confirmed as suitable for release.
Corrective action to be taken when CCPs critical limits are exceeded are documented in procedures. CCP1 - Engineers will be called out (Emergency), lock down procedure will come into force. The procedure details that stock is segregated and re-inspected if required that management is informed and that records are maintained of any adjustments made and any other actions taken.
2.10.2
The company operate a Hold / Quarantine system for all non conforming products. The Technical / Quality Managers make the decisions to recheck, destroy or accept product. .
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2.11
2.11.1
Establish Verification Procedures Codex Alimentarius Step 11, Principle 6

Procedures of verification shall be established to confirm that the HACCP plan is effective. Examples of verification activities are: 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. Verification results shall be recorded and communicated to the HACCP food safety team. The HACCP Team meet to review incidents which may affect the validity of the HACCP system. Records of meetings are maintained, and were available. The most recent meeting was 15/03/10
The sites HACCP system is verified by internal audits, analysis of records and customer complaints analysis.
2.11.2
Records from the HACCP meeting 15/03/10 were reviewed. The outcome of verification activities reviewed in this meeting was satisfactory.
2.12
2.12.1
HACCP Documentation and Record Keeping Codex Alimentarius Step 12, Principle 7
Documentation and record keeping shall be sufficient to assist the company to verify that the HACCP controls are in place and maintained. Documented procedures and records were in place for each CCP and for checks on controls related to control points included within prerequisite programmes.
A review of CCP records for: Product Cabbage Production Date February 2010 was completed as part of the traceability ( see 3.9) Records were found to be satisfactory.
2.13
2.13.1
Review the HACCP Plan

The HACCP food safety team shall ensure that procedures exist to review the HACCP plan 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 or equipment change in packaging, storage or distribution conditions change in staff or management responsibilities change in consumer use developments in scientific information associated with ingredients, process or product. Appropriate changes resulting from the review shall be incorporated into the HACCP plan, fully documented and validated. Irrespective of any of the above changes, the HACCP plan will be reviewed at least annually and records shall be maintained. The company operates a formal sign off process for all new products, significant changes and new equipment, which includes sign off by the HACCP Team to verify that the consequences of any changes have been assessed and addressed. Records for HACCP review upon new product development were seen. See 5.1.1
NPD and Maintenance are members of the HACCP team and are aware of the requirements for HACCP reviews for new products, process changes and new or alterations to equipment.
2.13.2
Annual HACCP Review Date: 15/03/10
There is a formal HACCP review for each generic study. Results of these reviews are discussed in Management meetings and records are maintained.
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3.0 3.1
3.1 Statement of Intent 3.1.1
FOOD SAFETY AND QUALITY MANAGEMENT SYSTEM Food Safety and Quality Policy
The companys senior management shall develop and document a food safety and quality policy which is authorised, reviewed, signed and dated by an appropriate senior manager. The policy shall state the companys intention to meet its obligation to produce safe and legal products to the specified quality, and its responsibility to its customers. This shall include the commitment for review and continual improvement. The companys senior management shall ensure the policy is communicated to all staff involved with activities relating to product safety, legality and quality.
There is a documented food safety policy which is signed by the Managing Director 08/03/10 Issue 6. The companys senior management ensure the policy is communicated to all staff during induction training and is displayed on notice boards. The policy states the companys intention to meet its obligation to produce safe and legal products to the specified quality, and its responsibility to its customers. The policy includes commitment for review and continual improvement.
3.2
3.2 Statement of Intent
Food Safety and Quality Manual

The company shall have a food safety and quality manual which describes how the requirements of the Global Standard for Food Safety are met. These requirements shall be fully implemented, reviewed at appropriate planned intervals and improved where necessary. The food safety and quality manual shall contain an outline of working methods and practices or references to where such an outline is documented. The food safety and quality manual shall be readily available to key staff.
The Food Safety Quality Manual covers the scope of the Global Standard for Food Safety and contains the appropriate policies, procedures and work instructions.
3.2.1
Y Y
The Food Safety Quality manual indexes elements of the food safety system, HACCP, quality and operating procedures, work instructions and other documents that the Standard requires for the site infrastructure, product control, process control and personnel. The Quality Manual is available as a hard copy to appropriate managers and is available to appropriate staff from the company intranet.
3.2.2
3.3
Organisational Structure, Responsibilities and Management Authority

The company shall have a clear organisational structure and define the responsibilities, reporting relationships and job functions of those personnel whose activities affect product safety, legality and quality. The company shall have an organisation chart demonstrating the structure of the company. Documented, clearly defined responsibilities shall exist and be communicated to key staff with responsibility for product safety, legality and quality systems. The organisational structure is defined (3.3.1) within the Food Safety Quality Manual, as are the reporting relationships, responsibilities and job functions (3.3.2)
Y Y Y Y
3.3.1
Current Organisational Chart is dated 2010
3.3.2
Job Descriptions reviewed: Technical Director Technical Manger QA
3.3.3
There shall be appropriate documented arrangements in place to cover for the absence of key staff.
Deputies for key staff are defined in the job description documents.
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3.3.4
The companys senior management shall ensure a description of general duties or work instructions are in place and communicated to all staff involved with activities relating to product safety, legality and quality.
Work instructions are included in the quality manual. Those reviewed include: Temperature recording Cleaning Glass Breakage Procedures
3.3.5
The companys senior management shall have a system in place to ensure that the company is kept informed of all relevant legislative, scientific and technical developments, and industry codes of practice applicable in the country of raw material supply, production and, where known, the country where the product will be sold.
The companys system to ensure that is kept informed of all relevant legislation, industry codes of practice, technical and scientific developments includes the following sources - Homologa, Europa, FSA, NSF CMi, Scientific Food Hygiene and trade journals to include the FPJ. Products are sold in the following countries UK
3.4
Contract Review and Customer Focus

The companys senior management shall ensure that processes are in place to determine any customer requirements and expectations with regard to product safety and quality, and ensure these are fulfilled. The company shall clearly identify those individuals responsible for communication with customers and shall have an effective system for communication.
Process is in place to determine customer requirements.
3.4.1
Individuals responsible for communicating with customers: Technical: Ian Booth (Technical Director) Commercial / Sales: Paul Collins (Commercial Director) Communication with customers is via telephone and e-mails. Customer requirements and technical specifications are communicated within the company by Ian Booth and are included in management meetings.
3.4.2
3.4.3
Customer requirements relating to the development, specification, manufacture and distribution of product shall have been agreed with the customer and, where appropriate, documented and agreed prior to order fulfilment (refer to clause 3.7.2.3). Customer needs and requirements shall be reviewed on a suitable predetermined frequency. Any changes to existing agreements or contract shall be agreed, documented and communicated to appropriate departments. Performance indicators shall be established relating to customer satisfaction. These shall be communicated to appropriate staff and performance reviewed against these targets.
The method of agreement of customer requirements is through signed specifications
Sales / Account Managers are responsible for contracts with customers and their review. Requirements are reviewed x 2 per annum. Any changes to existing contracts are communicated to appropriate departments by the contracts manager and discussed in daily management and production meetings.
3.4.4
Performance indicators and responsibility: 1) Customer KPIs are monitored 2) Complaints and feedback are monitored weekly, trend analysis is conducted. 3) Management meet monthly to review performance of service. 4) Customer returns are logged Procedure. Review Mechanism: Performance indicators are discussed in management meetings.
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3.5
3.5
FUNDAMENTAL
Internal Audit
The company shall audit those systems and procedures which cover the requirements of the Global Standard for Food Safety to ensure that they are in place, appropriate and complied with.
There is a programme of internal audits of the Food Safety Quality systems carried out by the Technical department. The programme includes all process departments, and supporting maintenance, hygiene and laboratory areas as well as the supporting Quality Management System procedures and records. Audits are carried out each quarter enabling the whole system to be covered in a year. Systems and procedures are audited and the results from the audits are included on the agendas of the monthly management Review Meetings.
Statement of Intent
3.5.1
3.5.2
Internal audits shall be planned and their scope and frequency shall be established in relation to the risks associated with the activity. Audits shall be scheduled so that all aspects of the food safety and quality management system are audited at least annually. Internal audits shall be carried out by appropriately trained competent auditors, who are independent from the audited department.
The internal audit procedure is dated 2010 Audits are carried out each quarter enabling the whole system to be covered in a year.
Internal audits are carried out by : Ian Booth Third Party Auditor trained BRC issue 5 07/03/08. Other Quality and Technical representatives have received internal training from Ian Booth (Technical Director).
3.5.3
Internal audit reports shall identify and verify conformity as well as non-conformity. Results of the internal audit shall be reported to the personnel responsible for the activity audited. Corrective actions and timescales for their implementation shall be agreed. The completion of corrective action shall be verified. A record of all programmed internal audits and associated corrective actions shall be maintained.
Y Y Y Y
The internal audit report for training , completed February 2010 was reviewed. The report contained details of conformity and non conformity with requirements. The internal audit report for training, completed February 2010 was reviewed. The report contained details of corrective action, assigned responsibility, time scales and verification of effective action. Completion of corrective actions (3.5.4.) was verified on March 2010 (Ian Booth) Records reviewed: Monthly GMP audit (Various dated 2009-10 were reviewed) Audit against Global Standard v5 conducted February 2010 was reviewed. All audit reports are held by the technical department, all findings are discussed at senior management meetings.
3.5.4
3.5.5
3.5.6
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3.6
Purchasing Supplier Approval and Performance Monitoring

The company shall control all purchasing processes which are critical to product safety, legality and quality to ensure that products and services procured conform to defined requirements. The company shall have a documented supplier approval procedure and continual assessment programme in place, based on risk assessment.
Y Y
The company has written procedures for controlling purchasing. 3.6 05/01/09
Supplier Approval Procedure 3.6 2010 was reviewed. Suppliers are risk assessed and have to complete a self audit questionnaire, supply a third party audit certificate. All supply is put out to tender every 6 months the audit questionnaire goes out with the following Technical code of practice Delivery code of practice Pesticide Analysis A Traceability example Ethical Questionnaire Specifications
Supplier Approval Information reviewed for : Product / Supplier Produce supplier LFP Approved Supplier list: 2010 Supplier performance is reviewed at management review meeting. 3.6.2 These procedures shall include clear criteria for ongoing assessment and standards of performance required. Ongoing assessment may take the form of monitoring performance through the following, although this is not an exhaustive list: in-house checks certificates of analysis supplier audit as appropriate. Records of this monitoring shall be retained. The procedures shall define how exceptions are handled, e.g. the use of products or services where audit or monitoring has not been undertaken. The company shall review the performance of new suppliers against defined criteria within a specified trial period and thereafter at a specified frequency to decide the level of ongoing supplier performance monitoring.
Raw materials inspected and assessed on receipt Certificates of Analysis Certificate of Conformance Other Records reviewed: Lincolnshire Field Products BRC Certification, Assured Produce certification.
3.6.3
Y Y
Procedure to manage exceptions: In the event of an exception relating to the use of product or services where audit or monitoring has not been undertaken, the appropriate customer procedures must be followed. Criteria for performance review: Any new supplier will be assessed.
3.6.4
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3.7.1
Documentation Control
The companys senior management shall ensure that all documents, records and data critical to the management of product safety, legality and quality are in place and effectively controlled.
The company has a document control procedure Q.M 3.7, that is held within the Food Safety Quality Manual. The company operates a computer based document control system with all documents issued with an issue date and reference. . Authorisation is effectively controlled by restricted password access to create or modify documents. Documents in use were found to be the correct version cross checks were made of master copies and documents in circulation: Documents verified: Induction Temp Probe Calibration Personal Hygiene 7.3 -05/01/09 Glass Breakage 11/03/2010
3.7.1.1
All documents in use shall be properly authorised and be the correct version.
3.7.1.2
3.7.1.3
3.7.1.4
Documents shall be clearly legible, unambiguous, in appropriate languages and sufficiently detailed to enable their correct application by appropriate staff. They shall be readily accessible to relevant staff at all times. The reason for any changes or amendments to documents critical to product safety, legality or quality systems and procedures shall be recorded. A procedure shall be in place to ensure obsolete documentation is rescinded, and where necessary replaced with a revised version.
Y Y Y
Documents reviewed during the visit were found to be clearly legible. Documents were available in Russian, Latvian and Lithuanian.
Changes and amendments are recorded at the end of each document.
There is a procedure in place to rescind old documents with the technical director being overall responsible for ensuring old documents are taken out of circulation and new ones put into place. Documents are held for 3 years.
3.7.2
3.7.2 Statement of Intent
Specifications
The company shall ensure that specifications exist for raw materials including packaging, intermediate/semiprocessed and finished products (where relevant), and any product or service which could affect the integrity of the finished product. Specifications shall be adequate and accurate and shall ensure compliance with relevant safety and legislative requirements.
Specifications for raw materials, packaging materials and finished products are available. Raw material specifications reviewed Baton Swede 18/06/09 Issue 8
3.7.2.1
Specifications reviewed included allergen, microbiological and chemical data. Example Baton Swede 18/06/09 Issue 8. Savoy Cabbage -2008
3.7.2.2
Manufacturing instructions shall comply with recipes as detailed in agreed customer specifications and shall be implemented. The company shall seek formal agreement of specifications with relevant parties. Where specifications are not formally agreed then the company shall be able to demonstrate that they have taken steps to ensure formal agreement is in place. There shall be a documented procedure for the amendment and approval of specifications for all parts of the process including regul ar reviews to ensure adequacy and status. Specifications and/or their contents shall be accessible to relevant staff.
N/A Y
No recipes are used.
3.7.2.3
Specifications have been agreed formally by Reynolds and their customers. Taking in account any relevant safety or legislative requirements.
3.7.2.4
Y Y
All specifications are subject to a review.
3.7.2.5
All specifications are held in the computer based document control system; hard copies are available in the QA / Production Office and are readily available to key staff.
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Y Y Y Y Y Y
3.7.3
3.7.3 Statement of Intent 3.7.3.1
Record Completion and Maintenance

The company shall maintain genuine records to demonstrate the effective control of product safety, legality and quality. The records shall be legible, genuine, appropriately authorised and retained in good condition for an appropriate defined time period. Any alterations to records shall be authorised and justification for alteration shall be recorded. The companys senior management shall ensure that procedures are operated for the collation, review, maintenance, storage and retrieval of all records relating to product safety, legality and quality. The period of retention for records shall relate to shelf life of the product and take into account, where it is specified on the label, the possibility that shelf life may be extended by the consumer, e.g. freezing. Any legal and customer specific requirements relevant to record retention shall be taken into account. Records which demonstrate the effective control of product safety, legality and quality are maintained.
Records were reviewed throughout the assessment and were made available as requested. Record retention period is 3 years. Changes to records are authorised by the Technical Director.
3.7.3.2
3.7.3.3
There are procedures in place to collate, review, maintain, store and retrieve these records. Effective collation, storage and retrieval were challenged as part of the traceability test. The product shelf life is customer specified Record retention period is two years.
3.7.3.4
3.7.3.5
Record retention period takes in customer and legal requirements.
3.8
3.8
FUNDAMENTAL
Corrective and Preventive Action

The companys senior management shall ensure that procedures exist to record, investigate, analyse and correct the cause of non-conformity against standards, specifications and procedures which are critical to product safety, legality and quality. Corrective actions shall be accurately documented, assigning responsibility and accountability. Corrective actions shall be undertaken as soon as possible to prevent further occurrence of non-conformity. Any corrective action plan relating to food safety, legality or quality shall only be agreed by personnel who have a defined responsibility and accountability for these areas of control. The completion of corrective actions shall be monitored and recorded to ensure their effectiveness and completion within an appropriate timescale.
The procedure for the management of corrective and preventative action is 3.8 2010
Statement of Intent
3.8.1
Y Y Y Y
Corrective actions are documented effectively.
3.8.2
The timescale for management of corrective actions is typically one month. Evidence of this was seen reviewing the sites internal audits. Corrective actions for food, safety, legal or quality issues are agreed by the Technical Director and the Relevant Manager for the department concerned. The corrective actions are signed off when completed and verified by the sites technical team.
3.8.3
3.8.4
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3.9
3.9
FUNDAMENTAL
Traceability
The company shall have a system to identify and trace product lots and follow this through all raw materials (including primary and any other relevant packaging materials and processing aids), all stages of processing and the distribution of the finished product to the customer in a timely manner. The company has a system that enables the traceability of raw materials and packaging from source through processes and distribution. During the audit a traceability challenge was set involving: Product - Savoy Cabbage Intake 25/02/10 Batch Code - LFP LS0092964 LFP - 08/04 Reynolds Trace Code: 390949 Total Cases Produced 60 x 8 Savoy Cabbage
Statement of Intent
Despatch details 25/02/10 28/02/10 Production, Quality and CCP records reviewed: LFP Field Records, QC Assessment, Intake Records, Stock Records, Scale Checks, Cleaning Sheets, Glass Records, Probe Records- calibrations & verifications, despatch records. Finished product specification: Savoy Cabbage The exercise included a satisfactory mass balance check.
3.9.1
Identification of raw materials including primary and any other relevant packaging and processing aids, intermediate/semi-processed products, part-used materials, finished products and materials pending investigation, shall be adequate to ensure traceability. The company shall test the traceability system to ensure traceability can be determined from raw material to finished product and vice versa and include quantity check/mass balance (refer to glossary). This shall occur at a predetermined frequency and results shall be retained for inspection. The test shall take place at least annually. Where there is a requirement to ensure identity preservation within the supply chain, e.g. to use a logo or to make a claim to a product characteristic or attribute, appropriate controls and testing procedures shall be in place. Where rework or any reworking operation is performed, traceability shall be maintained. In addition, the company must be able to demonstrate that this does not affect the safety or legal status of the finished product, e.g. ingredient declaration, allergy information or identity preservation.
When materials arrive at the site they are given a unique code which stays with the product until despatch.
3.9.2
Finished goods are stored on pallets which are identified by pallet numbers which are detailed in despatch information to enable traceability ex-factory. Traceability undertaken by the site for raw material to finished products was conducted on Iceberg lettuce, code 9421 February 2010. Full traceability was achieved including a satisfactory mass balance in both directions. (Forward & Backwards Trace)
3.9.3
There are no IP characteristics or claims for materials or products.
NA
Traceability is maintained for work in progress and rework.
3.9.4
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3.10
Complaint Handling
The company shall have a system for the effective capture, recording and management of product complaints. All complaints shall be recorded, investigated and the results of the investigation recorded. Actions appropriate to the seriousness and frequency of the problems identified shall be carried out promptly and effectively by appropriately trained staff. Complaint data shall be analysed and used to implement ongoing improvements to product safety, legality and quality, and to avoid recurrence. This analysis shall be made available to relevant staff.
Y Y Y Y
The system for capture, recording and management of customer complaints is detailed in procedure 3.10 -2010
Complaints are investigated and records made of investigation and action taken. All complaints are investigated and summaries and reviews are discussed in management meetings. Complaints levels are constantly monitored. Data is reviewed at the management meetings and at the annual Management Review meetings where opportunities for corrective or preventative action are identified to initiate ongoing improvements.
3.10.2
3.10.3
3.11
Management of Incidents, Product Withdrawal and Product Recall

The company shall have a plan and system in place to manage incidents effectively including product withdrawal and recall procedures. The company shall have procedures designed to manage effectively incidents and potential emergency situations that impact food safety, legality or quality and have effective product withdrawal and product recall procedures in place. This may include consideration and contingency planning for business continuity and product withdrawal or recall in the event of the following, although this is not an exhaustive list: disruption to key services such as water, energy, transport, staff availability and communications events such as fire, flood or natural disaster malicious contamination or sabotage. The company shall provide written guidance to relevant staff regarding the type of event that would constitute an incident or emergency situation that impacts food safety, legality or quality and a documented reporting procedure shall be in place.
Y Y
There is a plan in place for management of incidents, recall and product withdrawal. These are detailed in procedures. See 3.11.1 and 3.11.3 Potential emergency situations and incidents that impact food safety, legality or quality are managed by procedure 3.11 - 2010 Product withdrawal and product recall processes are detailed in the 3.11 procedure, 2010 Emergency situations defined by the company: Power cut Flood Fire Bio security breach Extreme weather
3.11.2
Types of incidents that would constitute a recall are defined in a procedure and these include: Malicious Contamination Product Sabotage Attempted Extortion Glass Breakage Chemical Contamination Significant Process Deviation Blood Spillage
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Y
3.11.3
An incident management procedure shall be documented, implemented and maintained. This shall include as a minimum: identification of key personnel constituting the incident management team with clearly identified responsibilities an up-to-date list of key contacts, e.g. incident management team, emergency services, suppliers, customers, certification body, regulatory authority a communication plan including the provision of information to customers, consumers and regulatory authorities in a timely manner details of external agencies providing advice and support as necessary, e.g. expert laboratories, regulatory authority and legal expertise product withdrawal and/or recall procedures corrective action and business recovery. The procedures relating to incident reporting, product withdrawal and product recall shall be appropriate, formalised and capable of being operated at any time, and will take into account stock reconciliation, logistics, recovery, storage and disposal. The procedures shall be regularly reviewed and, if necessary, revised. The product recall and withdrawal procedures shall be regularly tested, at least annually, in a way that ensures their effective operation. Results of the test shall be retained and shall include timings of key activities. The companys senior management shall ensure that results of this test shall be used to implement improvements as necessary. In the event of a product recall, the certification body issuing the current certificate for the site against the Global Standard for Food Safety and the appropriate authority shall be informed in a timely manner.
The company has developed an incident management procedure 3.11 2010 The procedure identifies the incident management team. A list of key contacts is available, is updated annually, and is tested as part of the incident management test procedure. The key contacts include: Key site personnel Key Company personnel Customers Suppliers Distribution / Logistics Regulatory authorities Certification Body Laboratory Legal Medical Emergency services
3.11.4
Procedure for incident reporting see 3.11.3 The procedure includes accounting for all stock, recovery, storage and disposal. The effectiveness of the procedure is reviewed after each incident or test.
3.11.5
Y Y Y
The recall procedure is scheduled to be tested annually. The last test was carried out February 2010.
3.11.6
Results of product recall test are reviewed as part of the monthly management meetings. Requirement to notify the Certification Body in event of recall is detailed in the incident management procedure see 3.11.3.
3.11.7
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4.0 4.1
SITE STANDARDS External Standards

The site shall be of suitable size, location, construction and design to facilitate maintenance, prevent contamination and enable the production of safe and legal finished products. Consideration shall be given to local activities and the site environment, which may have an adverse impact on finished product integrity, and measures shall be taken to prevent contamination. Where measures have been put into place to protect the site from any potential contaminants, they shall be regularly reviewed to ensure they continue to be effective, e.g. dust or odour control. The external areas shall be maintained in good order. Where buildings are surrounded by grassed or planted areas, they shall be regularly tended and well maintained. The condition of the site shall be included within the internal audit process. Where natural drainage is inadequate, external drainage shall be installed. External traffic routes, under site control, shall be suitably surfaced and maintained in good repair to avoid contamination of the product. The building fabric shall be maintained to minimise potential for product contamination, e.g. pipe work shall be appropriately sealed to prevent pest entry, ingress of water and other contaminants.
The site is of suitable size, location and construction to permit maintenance and to allow the production of safe and legal products. The buildings are in good repair and maintained.
There are no local activities that could potentially adversely affect the products by introducing contamination to the products.
4.1.2
Y Y Y Y
The perimeter of the site is in good order. Planted areas are kept to a minimum and are well maintained. The perimeter of the site is fenced and gated. Condition of the site is checked as part of the internal audit schedule.
4.1.3
Natural drainage appeared to be adequate during the audit with no issues noted. External traffic routes were suitably surfaced and in good repair.
4.1.4
4.1.5
The building fabric was noted to be in a good condition and the factory was well proofed. GMP audits and planned maintenance inspections monitor the building.
4.2
Security
Security shall be maintained to prevent access of unauthorised persons to production and storage areas. Access to the site by employees, contractors and visitors shall be controlled and a visitor reporting system shall be in place. Staff shall be trained in site security procedures and encouraged to challenge unidentified or unknown visitors. Measures shall be in place to maintain site security and to ensure only authorised staff have access to production and storage areas via designated access points. Areas shall be assessed according to risk; sensitive or restricted areas shall be defined, clearly marked, monitored and controlled.
Y Y Y
There are measures in place to maintain site security and prevent entry to production areas. Access to the site is controlled. The site is fenced and gated, has CCTV and visitor access procedures. Visitor reporting system all visitors and contractors report and sign a log recording their arrival, read and sign agreement to comply with site personal hygiene rules and other GMPs. Visitors also complete a medical screening questionnaire if intending to visit production areas. Staff are trained in security procedures during their induction training. Senior staff are responsible for challenging unaccompanied and unauthorised people. The following control measures are in place: Visitor, driver and contractor reporting system Secure fences and locked gates Locked external doors CCTV Staff issued swipe cards Access to production areas is restricted to staff authorised to work in those areas All materials are stored within their designated storage areas inside the buildings.
4.2.2
4.2.3
4.2.4
Based on risk assessment, procedures shall be in place to ensure the secure storage of all materials including ingredients, packaging, chemicals and equipment.
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Y Y
4.2.5
Procedures shall be in place to ensure that finished product is held under secure storage and transportation conditions, e.g. tamper evident packing, contractual handling agreements. Where required by legislation, the site shall be registered with, or approved by, the appropriate authority.
Finished goods are stored in a secure area. The secure storage of finished products is included in procedures and transport company contracts.
4.2.6
The site is a registered food business. Ref Broxbourne Borough Council
4.3.1
4.3.1
FUNDAMENTAL
Layout, Product Flow and Segregation

Premises and plant shall be designed, constructed and maintained. Procedures shall be in place to control the risk of product contamination and to comply with all relevant legislation. The process flow from intake to dispatch shall be arranged to minimise the risk of product contamination.
Y Y
Premises are designed and constructed to ensure product safety. Operational procedures are in place.
Statement of Intent 4.3.1.1
4.3.1.2
4.3.1.3
4.3.1.4
4.3.1.5
4.3.1.6
4.3.1.7
4.3.1.8
4.3.1.9
Physical barriers or demonstrably effective procedures shall be in place to minimise the risk of the contamination of raw materials, intermediate/semi-processed products, packaging and finished products with particular consideration given to handling requirements for specific materials (refer to clause 5.2). Segregation shall take into account the flow of product, nature of materials, equipment, personnel, waste, airflow, air quality and utilities provision. Based on risk assessment, the cleaning of production utensils shall be carried out in segregated areas or at specific time periods separated from the production process. Premises shall allow sufficient working space and storage capacity to enable all operations to be carried out properly under safe hygienic conditions. Cleaning and inspection of areas and equipment shall be aided by the avoidance of obstructions and where appropriate the provision of adequate space. Temporary structures constructed during building work or refurbishment, etc., shall be designed and located to avoid pest harbourage and potential contamination of products. The location of all transfer points shall not compromise high-risk and low-risk segregation and practices shall be in place to minimise risk of product contamination, e.g. disinfection. Where high-risk products (refer to glossary) are manufactured, there shall be physical segregation between processing and finished product handling areas. This high risk area shall be fabricated and designed to a high standard of hygiene, and practices shall be in place to control ingredients, equipment, packaging, environment and personnel to prevent product contamination.
The process flow of product through the site is Intake Assessment Storage Order Picking/Packing Storage Despatch Physical separation is in place between production areas. Examples Nut and Celery specific holding areas are in place.
N/A N/A Y Y N/A N/A N/A
There are no specific handling requirements for the produce packed. However Whole Nuts and Celery are handled.
No cleaning of utensils is carried out by the site.
Sufficient working space is provided for all operations.
Equipment is suitably positioned to allow cleaning and inspection.
There were no temporary structures on-site
No high care or high risk operations conducted.
Not applicable there are no high risk / high care operations on site.
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N/A
4.3.1.10
In high-care areas (refer to glossary) where there is a significant risk of contamination of chilled ready to eat/heat products by pathogenic micro-organisms, the processing or handling of food in these areas shall be appropriate to minimise product contamination by such micro-organisms.
Not applicable there are no high risk / high care operations on site.
4.3.2
Fabrication Raw Material Handling, Preparation, Processing, Packing and Storage Areas
The fabrication of the site, buildings and facilities shall be suitable for the intended purpose.
The fabrication of the buildings and facilities are suitable for the intended purpose.
4.3.2.1
4.3.2.1.1
Walls
Walls shall be designed, constructed, finished and maintained to prevent the accumulation of dirt, minimise condensation and mould growth, and facilitate cleaning.
Walls are constructed of composite fridge board and were in a satisfactory condition.
4.3.2.2
4.3.2.2.1
Floors
Floors shall be designed to meet the demands of the process, and withstand cleaning materials and methods. They shall be impervious and maintained in good repair. Drainage, including drains from laboratories, where provided, shall be sited, designed and maintained to minimise risk of product contamination and not compromise product safety. Machinery and piping shall be arranged so that, wherever feasible, process waste water goes directly to drain. Where significant amounts of water are used, or direct piping to drain is not feasible, floors shall have adequate falls to cope with the flow of any water or effluent towards suitable drainage.
Floors are constructed of sealed concrete and were noted to be in good repair.
4.3.2.2.2
Suitable drainage was noted in all factory areas and no evidence was seen of water pooling. (Limited water is used by the site)
Y
Not applicable limited water is used by the site.
4.3.2.2.3
NA
4.3.2.3
4.3.2.3.1
Ceilings
Ceilings and overheads shall be designed, constructed, finished and maintained to prevent the accumulation of dirt, minimise condensation and mould growth, and facilitate cleaning. Where suspended ceilings are used, adequate access to the void shall be provided to facilitate cleaning, maintenance of utilities and inspection for pest activity.
Y NA
Ceilings are constructed from composite fridge board and are appropriately maintained. All ceilings were seen to be clean.
4.3.2.3.2
Not applicable there are no false ceilings.
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4.3.2.4
4.3.2.4.1
Windows
Where there is a risk to product, windows and roof glazing which are designed to be opened for ventilation purposes shall be adequately screened to prevent the ingress of pests. Where they pose a risk to product, glass windows shall be protected against breakage.
N/A Y
No opening windows on-site.
4.3.2.4.2
Glass windows are protected against breakage.
4.3.2.5
4.3.2.5.1
Doors
Where external doors to raw material handling, processing, packing and storage areas are opened, suitable precautions shall be taken to prevent pest ingress. Doors and dock levellers in these areas shall be close fitting or adequately proofed. Doors shall be in good condition and easy to clean, where required.
Y Y
External doors are suitably proofed to prevent pest ingress. Door discipline was observed to be satisfactory during the assessment.
4.3.2.5.2
All doors seen during the visit were found to be in a good condition and were easy to clean.
4.3.2.6
4.3.2.6.1
Lighting
Suitable and sufficient lighting shall be provided for a safe working environment, correct operation of processes, inspection of product, and effective cleaning. Where they constitute a risk to product, bulbs and strip lights, including those on electric flykiller devices, shall be adequately protected. Where full protection cannot be provided, alternative management such as wire mesh screens or monitoring procedures shall be in place.
Satisfactory protected fluorescent light tubes provide good lighting levels. All lights are included in the glass audit register. Bulbs and strip lights are suitably protected.
4.3.2.6.2
There is a glass management procedure.
4.3.2.7
4.3.2.7.1
Ventilation
Adequate ventilation and extraction shall be provided in product storage and processing environments to prevent condensation or excessive dust. Where the process requires screened or filtered air, the equipment used for this purpose shall be easily accessible and adequately maintained. Where appropriate, positive air-pressure systems shall be in place.
Y NA NA
During the site inspection it was noted that the factory storage and process areas were satisfactorily ventilated and there were no signs of condensation or excessive dust. No filtered air is required on this site.
4.3.2.7.2
4.3.2.7.3
Positive air pressure is not required.
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4.4
Utilities
All utilities to and within the production and storage areas shall be designed, constructed, maintained and monitored to control the risk of product contamination effectively. All water used as a raw material in the manufacture of processed food, the preparation of product, or for equipment or plant cleaning shall be supplied in sufficient quantity, be potable or pose no risk of contamination according to applicable legislation, either being drawn from mains supply or suitably treated according to its source. Based on risk assessment, the microbiological and chemical quality of water, steam, ice, air, compressed air or other gases that does not constitute an ingredient but comes in direct contact with food or packaging shall be regularly monitored. It shall present no risk to product safety or quality and comply with relevant legal regulations.
Y Y
All services to and within the production and storage areas are designed, constructed, maintained and monitored to control the risk of contamination. Water used within the operation is potable and drawn from mains supply. The water supply company is Thames Water.
4.4.2
The quality of water is monitored to ensure that there is no risk to product safety. External testing: Laboratory - Alcontrol UKAS 0995 & G R Micro UKAS 1206 Frequency - Annually for refrigeration system to include Legionella. Results seen 28/01/10 & 14/10/09 Company testing: Thames Water Frequency of internal tests - 2008 Samples are tested for TVC at 22 and 37 C, Coliforms, E.coli, Faecal streptococci, Pseudomonas species and Sulphite Reducing Clostridia.
4.5
Equipment
Equipment shall be suitably designed for the intended purpose and shall be used to minimise the risk of contamination of product.
Equipment is suitably designed for the intended purpose and is utilised to minimise the risk of product contamination. Equipment in use on site includes Flow wrapper, Conveyor, Netter, Refrigeration system
4.5.1
4.5.2
4.5.3
All equipment shall be properly specified before purchase, constructed of appropriate materials, be of a suitable design to ensure it can be effectively cleaned, and shall be tested and commissioned prior to use. Equipment shall be positioned to give access under, inside and around it for ease of cleaning, inspection and servicing, or where permanently sited shall be properly secured and sealed to the floor. Certificates of conformity or other evidence shall be available for equipment in direct contact with food to confirm its suitability for use, e.g. conveyor belts.
Y Y N/A
Commissioning trials are conducted prior to use.
Equipment in production areas is located to allow suitable access for cleaning and maintenance.
Not applicable product is not in direct contact with equipment. (Risk Assessment Conducted)
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4.6
Maintenance
A documented system of planned maintenance shall be in place, covering all items of equipment and plant which are critical to product safety, legality and quality. Equipment, including fixtures and fittings, shall be maintained in such condition as to minimise the risk of product contamination.
The maintenance system is paper based. The system generates maintenance activities at planned intervals which are undertaken by maintenance staff or contractors. Records are maintained of work carried out.
4.6.1
During the site inspection equipment, fixtures and fittings were observed to be appropriately maintained. No observations were made where there was a risk of product contamination. The maintenance procedure includes processes to minimise the risk of product contamination during maintenance. The planned maintenance programme on site has been established based upon a risk assessment.
4.6.2
4.6.3
When commissioning new equipment and plant, a maintenance programme shall be established and put into place based on risk assessment. The company shall ensure that the safety or legality of product is not jeopardised during maintenance and cleaning operations. In addition to any planned maintenance programme, where there is a risk of product contamination by foreign bodies arising from equipment failure, the equipment shall be inspected at predetermined intervals, inspection results documented and appropriate action taken. Where temporary repairs are made, these shall be controlled to ensure the safety or legality of product is not jeopardised. These temporary measures shall be permanently repaired as soon as practicable and within a defined timescale. Contractors involved in maintenance or repair activities shall be under the supervision of a nominated person. Maintenance work shall be followed by a documented hygiene clearance procedure, which records that product contamination hazards have been removed from machinery and equipment. On completion of any maintenance work, machinery and equipment shall be clean and free from contamination hazards. Materials used for equipment and plant maintenance and that pose a risk by direct or indirect contact with raw materials, intermediate and finished products, such as lubricating oil and paints, shall be suitable for the intended use. Engineering workshops shall be controlled to prevent contamination risks to the product, e.g. provision of swarf mats where workshops open directly into production areas.
Y Y Y
The maintenance procedure includes processes to minimise the risk of compromising product safety and legality during maintenance and cleaning. Start-up checks inspections are carried out by shift supervisors.
4.6.4
4.6.5
Temporary repairs are kept to a minimum. If required there are measures in place to ensure that they repaired as soon as possible.
4.6.6
Y Y
All work conducted by external contractors is supervised by a senior member of staff. Hygiene Clearance Procedures are in place, this ensures equipment and machinery are free from any contamination hazards once work has been completed. QAPROC-008
4.6.7
4.6.8
All lubricants used on site are food grade, with specifications being held.
4.6.9
N/A
The workshop is located away from the production area.
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4.7
Staff Facilities
Staff facilities shall be sufficient to accommodate the required number of personnel, and shall be designed and operated to minimise the risk of product contamination. Such facilities shall be maintained in good and clean condition. Designated changing facilities shall be provided for all personnel, whether staff, visitor or contractor. These shall be sited to allow direct access to the production, packing or storage areas without recourse to any external area. Where this is not possible, a risk assessment shall be carried out and procedures implemented accordingly, e.g. the provision of cleaning facilities for footwear. Storage facilities of sufficient size to accommodate all reasonable personal items shall be provided for all personnel who work in raw material handling, processing, preparation, packing and storage areas. Outdoor clothing and other personal items shall be stored separately from workwear within the changing facilities. Suitable and sufficient hand-washing facilities shall be provided at access to, and at other appropriate points within, production areas. Such hand-wash facilities shall provide as a minimum: sufficient quantity of water at an appropriate temperature liquid soap single use towels or suitably designed and located air driers appropriate instructions for use (including consideration of appropriate language). Where high-risk products (refer to glossary) are handled, the following additional requirements shall be provided: water taps with hand-free operation hand disinfection. Toilets shall be adequately segregated and shall not open directly into storage, processing or production areas. Toilets shall be provided with handwashing facilities comprising: basins with soap and water at a suitable temperature adequate hand-drying facilities advisory signs to prompt hand washing (including consideration of appropriate language). Where hand-washing facilities within toilets are the only ones provided before re-entering production, then the requirements of 4.7.4 shall apply.
Staff facilities are suitably designed and operated to ensure the minimum of risk of product contamination.
4.7.1
Changes facilities are provided for staff and visitors. The changing facilities allow direct access to the production areas.
4.7.2
Y Y Y
Lockers were of a suitable size to accommodate all personal items.
4.7.3
There was no crossover of outdoor clothing and factory work wear noted during the visit. There are hand-washing facilities at the entrance of production areas and these are supplied with hot water, liquid soap and disposable towels. There is provision for hand washing and sanitising as required within production areas.
4.7.4
4.7.5
Toilets do not open directly into production, packing or storage areas. Toilet hand wash facilities are supplied with hot water, liquid soap and disposable towels. Pictorial Wash hands signs were present within the toilet areas.
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Y
4.7.6
4.7.7
4.7.8
Designated controlled smoking areas shall be isolated from production areas to an extent that ensures smoke cannot reach the product. Where smoking is allowed under national law, sufficient extraction to the exterior of the building shall be ensured. Adequate arrangements for dealing with smokers waste shall be provided at smoking facilities, both inside and at exterior locations. Facilities shall be available, with adequate reminders, for hand washing after smoking. All food brought into manufacturing premises by staff shall be appropriately stored in a clean and hygienic state. No food shall be taken into storage, processing or production areas. Where catering facilities are provided, they shall be suitably controlled to prevent contamination of product. Where eating of food is allowed outside during breaks, this shall be in suitable designated areas with appropriate control of waste. Facilities for visitors and contractors shall be such as to enable compliance with the companys hygiene policy. Where an operation involving high-risk products (refer to glossary) exists, personnel shall enter via a specially designated changing facility, and shall follow specified procedures for applying visually distinctive clean overalls, headwear and footwear.
Smoking is only permitted in a designated area outside the factory building. Signs are present to remind smokers to wash their hands prior to reentering the production facility.
Y Y N/A Y N/A
Food was found to be appropriately stored, vending machines are in place.
Catering facilities are provided for workers at the storage hub.
4.7.9
Eating outside is not permitted.
4.7.10
Suitable facilities are provided for visitors and contractors to ensure the companys hygiene policy is not compromised. There are no high care-high risk operations conducted.
4.7.11
4.8
Chemical and Physical Product Contamination Control Raw Material Handling, Preparation, Processing, Packing and Storage Areas
Appropriate facilities and procedures shall be in place to control the risk of chemical or physical contamination of product. Procedures are in place to cover the potential risk of chemical or physical contamination identified in the HACCP Study and hazard analysis. See: 4.8.2 Chemical Controls 4.8.3 Metal Controls 4.8.4 Glass, Brittle Plastic, Ceramics Controls 4.8.5 Wood Controls 4.8.6 Other foreign body controls The HACCP and hazard analysis study included all potential contamination risks and included these in CCP and PRP programmes. Start-up checks include inspection for cleanliness and potential foreign body risks.
4.8.1
Based on risk assessment, the company shall identify, control and manage any potential risks from chemical, physical or taint contamination. This may include risks associated with the following, although this is not an exhaustive list: storage production operation or processes or machinery any maintenance or building work carried out hygiene and cleaning operations. These shall be verified through regular site audits carried out at a frequency determined by risk assessment.
Audits of potential sources of chemical and physical contamination are conducted each month. Records of the GMP audit conducted on February 2010 were reviewed
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4.8.2
4.8.2.1
Chemical Control
A chemical control procedure shall be in place which manages the use, storage and handling of non-food chemicals. This shall include as a minimum: approved purchase availability of material safety data sheets and specifications where appropriate, confirmed suitability for food use avoidance of strong scented products identification of chemicals at all times segregated and secure storage with restricted access to authorised personnel use by trained personnel only. The purchase of chemical supplies is controlled by the Approved Supplier Procedure.(4.8 -05/01/09) Safety data sheets are available and specifications confirm suitability for use in food industries.
Chemicals are securely stored Staff who handle chemicals have been trained.
4.8.3
4.8.3.1
Metal Control
There shall be a documented policy for the control of the use of sharp metal implements including knives, cutting blades on equipment, needles and wires. This shall include suitable controls both into and out of the factory, and safe disposal. Snap-off blade knives shall not be used. There is a documented knife / sharps policy.
Y Y Y Y
All knives are controlled by a documented knife register.
4.8.3.2
Snap off blades are not permitted. None were observed during the site inspection. Controls are in place to manage non-production blades. Maintenance engineers and other staff have been trained not to leave tools and machine parts on equipment, inspection and hygiene procedures following maintenance interventions to ensure these have been removed, pre-production and start up checks are in place. Staples are not permitted within the production areas and none were observed during the site inspection.
4.8.3.3
Non-production blades, equipment and tools shall not be left in a position that allows them to contaminate the product.
4.8.3.4
Where staples or other items are used which are likely to cause contamination in packaging, appropriate precautions shall be taken to minimise the risk of product contamination.
4.8.4
4.8.4.1
Glass, Brittle and Hard Plastic, Ceramics and Similar Materials

In areas where a risk assessment has identified a potential for product contamination from glass, the presence of glass shall be excluded. Where this cannot be avoided, but the risk is managed, glass shall be protected against breakage. Documented procedures for handling glass, brittle or hard plastic, ceramic or other similar materials shall be in place and implemented to ensure that necessary precautions are taken. Procedures shall include as a minimum: list of items detailing location, number, type and condition recorded checks of condition of items carried out at a specified frequency based on risk assessment details on cleaning or replacing items to minimise potential for product contamination.
All glass present within production and storage areas is protected against breakage.
4.8.4.2
The site has produced a register of all glass, brittle and similar materials. The current register is dated 2009-10 The register includes: details of location, number and type of fitting. Glass and hard plastic audits are conducted on a frequency determined by risk assessment Frequency Weekly WREC-022 Records of the last glass / hard plastic audit dated March 2010 were reviewed during the assessment. Fluorescent light tubes are replaced out of production hours.
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4.8.4.3
Based on risk assessment, documented procedures detailing the action to be taken in case of breakage of glass, brittle or hard plastic, which includes glass packaging and similar material, shall be implemented and include the following: quarantining the products and production area that were potentially affected cleaning the production area inspecting the production area and authorising to continue production changing of workwear and inspection of footwear specifying those staff authorised to carry out the above points recording the breakage incident.
There is a documented and detailed glass breakage procedure WPROC014 -22/02/10 The procedure requires that production stops, product is isolated, the area is cleaned using dedicated single use utensils, the area is inspected, authorisation is required before production can recommence, workwear is changed, footwear inspected and records completed.
4.8.5
4.8.5.1
Wood
In areas where a risk assessment has identified the potential for product contamination from wood, the use of wood shall be excluded. Where the use of wood cannot be avoided, and the risk is managed, the condition of wood shall be regularly checked to ensure it is in good condition and clean. Wooden pallets are permitted in production areas.
4.8.6
4.8.6.1
Other
Filters, sieves and magnets used for foreign body control shall be regularly inspected and properly maintained. Such activities shall be recorded and investigated. Based on risk assessment, procedures shall be implemented to minimise foreign body contamination of packaging during filling operations, e.g. covered conveyors, container inversion and foreign body removal through rinsing or air jets.
NA
There are no filters, screens or magnets within the production process.
4.8.6.2
There is no operation of this type on site.
NA
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4.9
4.9
FUNDAMENTAL
Housekeeping and Hygiene

Housekeeping and cleaning systems shall be in place which ensure appropriate standards of hygiene are maintained at all times and the risk of contamination is minimised. Housekeeping and cleaning systems are in place which ensure appropriate standards of hygiene are maintained at all times and that risk of contamination is minimised. The site operates a clean as you go policy during production hours with a full clean at the end of production. Satisfactory standards of hygiene were seen throughout the site inspection. Documented cleaning procedures are available in the factory. Methods have been developed in conjunction with the supplier of the hygiene chemicals. The cleaning methods include responsibility, areas to be cleaned, cleaning frequency, cleaning methods, materials to be used, records and verification system. Cleaning Procedures 41-53
Statement of Intent 4.9.1
4.9.2
4.9.3
Documented cleaning procedures shall be in place and maintained for the building, utilities, plant and all equipment. Cleaning procedures shall include the following information as a minimum: responsibility for cleaning item/area to be cleaned frequency of cleaning method of cleaning cleaning materials to be used cleaning records and responsibility for verification. Cleaning-in-place (CIP) facilities shall be monitored and maintained to ensure effective operation. Consideration shall be given to frequency, cycle time, temperature, chemical concentration and spray ball location and coverage. CIP shall have adequate separation from active product lines. Cleaning and housekeeping shall be carried out by trained personnel in accordance with documented procedures and records shall be maintained.
Not applicable there are no CIP operations on site.
NA
Records of all cleaning activities are retained by the site. Cleaning records for March & February 2010 were verified during the traceability exercise. All cleaning staff have received suitable training in the use of chemicals as well as the sites cleaning procedures. Examples of hygiene training records seen: Product specifications and MSDS safety data sheets were available. Specifications confirmed the chemicals are suitable for use in food production premises. Cleaning chemicals are stored in bulk containers and dosed into appropriate clean containers at the time of use by trained staff. All containers were suitably labelled. The effectiveness of cleaning is assessed visually immediately following cleaning and during the pre production start up checks. Areas requiring corrective action are re-cleaned. Records are maintained. Visual checks on the effectiveness of cleaning are conducted on a daily basis by production supervisors and QA. Documents from the day of the traceability exercise were reviewed and found to be satisfactory. Systems are in place to ensure that cleaning schedules are revalidated following the introduction of new machinery, changes to equipment or new product introduction.
4.9.4
Cleaning chemicals and equipment shall be: fit for purpose suitably identified for intended use, e.g. colour coded or labelled stored in a hygienic manner to prevent contamination.
4.9.5
The effectiveness of the cleaning and disinfection procedures shall be verified and recorded. Corrective actions shall be documented.
4.9.6
Cleaning and disinfection procedures shall be revalidated following building or maintenance work, new product introduction or changes to equipment.
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4.10
Waste/Waste Disposal
There shall be adequate systems for the collection, collation and disposal of waste material. Systems shall be in place to avoid the accumulation of waste in production areas, and shall prevent the use of unfit materials. Where appropriate, waste shall be categorised according to legislative requirements based on the intended means of disposal, segregated and collected in appropriate designated waste containers. Waste disposal shall meet legislative requirements. Where licensing is in operation for disposal of categorised waste, it shall be removed by licensed contractors and records of disposal shall be maintained and available for audit. External waste collection containers and rooms housing waste facilities shall be managed to minimise risk. These shall be: clearly identified designed for ease of use and effective cleaning well maintained to allow cleaning and where required, disinfection emptied at appropriate frequencies covered or doors kept closed as appropriate. If substandard trademarked materials are transferred to a third party for destruction or disposal, that third party shall be a specialist in secure product or waste disposal and shall provide records of material destruction or disposal.
Y Y Y
There are adequate systems in place to identify, collect, collate and dispose of waste materials.
Waste accumulation is kept to a minimum, waste is clearly identified. Dedicated cleaning staff empty the internal bins throughout each shift. Waste is segregated into: General waste Paper and board Plastic Waste is removed from site by Porters waste company, waste licence number TNE/378912/CB & Compact & Bale licence Ken 471993/CB.
4.10.2
4.10.3
4.10.4
Waste areas seen during the visit were in a suitable condition with all skips being suitably covered. Waste containers are removed on an on demand basis.
4.10.5
Procedures are in place for the handling of trademarked materials to prevent them finding their way on to the market.
4.11
Pest Control
The company shall be responsible for minimising the risk of pest infestation on the site. The company has minimised the risk of pest infestation by contracting a competent pest control organisation, has proofed doors, windows and other potential entry points and inspects all deliveries of raw materials and packaging for signs of infestation prior to accepting them on to the site. No evidence of infestation was found during the site inspection or has been reported recently. Preventative pest control on site is managed by a contracted third party who includes all areas of the site and specifies preventative measures. The company has a pest control contract with Humane pest control company. Npta 0980. The contractor makes 10 routine inspections with 2 additional biologist inspections each year.
4.11.1
A preventive pest control programme shall be maintained covering all areas of the site to minimise pest infestation. The company shall either contract the services of a competent pest control organisation, or shall have appropriately trained staff, for the regular inspection and treatment of the site to deter and eradicate infestation. The frequency of inspections shall be determined by risk assessment and shall be documented. Where the services of a pest control contractor are employed, the service contract shall be clearly defined and reflect the activities of the site.
4.11.2
A service contract is held at the front of the pest control manual detailing the frequency of visits, call outs and other details of the pest control programme. The contract includes rodents and insects, both internal and external bait boxes are used. The contract includes EFK units and pheromone traps.
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4.11.3
4.11.4
4.11.5
4.11.6
Written procedures and inspection documentation shall be maintained. This shall include as a minimum: an up-to-date, signed and authorised site plan identifying numbered pest control device locations identification of the baits and/or monitoring devices on site clearly defined responsibilities for site management and the contractor details of pest control products used and instructions for their effective use. Bait stations shall be robust, of tamper resistant construction, secured in place and appropriately located to prevent contamination risk to product. Fly-killing devices and/or pheromone traps shall be correctly sited and operational. If there is a danger of insects being expelled from any extermination device and contaminating the product, alternative systems and equipment shall be used. In the event of infestation, immediate action shall be taken to eliminate the hazard. Action shall be taken to identify, evaluate and authorise the release of any product potentially affected.
A bait plan is in place, dated 2008 reviewed 2010. Pest control devices are identified by labels on each unit and on the wall above the location. Health and Safety information is available for all materials used on site. The pest control information includes details of the contract, site visits, products used and recommendations. Safety data sheets were examined. . All bait points were robust and found to be of a tamper resistant construction and were suitably secured. No spill baits were used.
Y Y
None of the EFK and pheromone traps were noted in areas where they could potentially cause contamination. Inspection records and trend analysis were available. EFK Tube change 28/07/09 & 12/10/09 The pest control contractor is contracted to conduct follow up visits in the event of an infestation until the problem is eradicated.
Potentially affected product is identified, evaluated and released by the management. Previous 12 months records were reviewed. The last routine visit took place on 02/03/10 and was found to be satisfactory, the last biologist visit took place on 16/10/09.
4.11.7
4.11.8
Detailed records of pest control inspections, recommendations and actions taken shall be maintained. It shall be the responsibility of the company to ensure all of the relevant recommendations made by their contractor or in-house expert are carried out and monitored. The completion of corrective action shall be demonstrated by documented evidence. Results of pest control inspections shall be assessed and analysed for trends regularly, but as a minimum: in the event of an infestation annually. This shall include a catch analysis from trapping devices to identify problem areas. Any such problems shall be suitably rectified.
All documented recommendations have been actioned by the site and the pest control contractor.
Results from inspections are assessed and analysed for trends on a regular basis. Fly catch tray analysis is conducted. No problems were identified Records from 02/03/10 were verified during the visit.
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4.12
Storage and Transport

All facilities used for the storage and transportation of product, movement around the site, and dispatch of finished product shall be suitable for the purpose, maintained in good repair and in a hygienic condition. Procedures to maintain product safety and quality during storage, loading and transportation shall be developed on the basis of risk assessment and implemented accordingly. These may include as appropriate the following, although this is not an exhaustive list: controlling temperature cleaning storage areas and vehicles segregating to avoid cross contamination or taint uptake storing materials off the floor and away from walls as appropriate ensuring that vehicles such as bulk tankers are of hygienic design and designated for food use; putting in place procedures to prevent cross contamination from previous loads vehicle pre-loading and unloading inspection vehicle loading or unloading in covered bays maintaining product security and preventing damage. Where temperature control is required, the storage area or transport facility shall be capable of maintaining product temperature within specification, under minimum and maximum load and under worst case ambient temperature. Storage areas shall be dry and well ventilated.
Storage, transport and despatch areas on site were noted to be suitable and in a satisfactory condition.
4.12.1
Procedure 4.12 is in place to maintain product safety and quality during storage, loading and transportation. The procedure details:Temperature controls Cleaning and inspection protocols Segregation Taint free Storage off floor Preloading and unloading inspection Covered loading bays Product security measures Locked and sealed trailers No open sided trailers Pallets are secured to prevent movement during distribution.
4.12.2
Storage areas are dry and well ventilated. Storage areas are maintained at 1-8oC Freezer - 18C Distribution vehicles are maintained at 2 -8 oC Conditions are verified by the periodic use of data loggers.
4.12.3
4.12.4
Where temperature control is required, documented procedures shall be in place to ensure product temperature requirements are met. This shall include temperature datalogging devices which can be interrogated to confirm time/temperature conditions or a system to verify and record at predetermined frequencies the correct operation of refrigeration equipment. Where storage outside is necessary, items shall be protected from contamination and deterioration. Receipt documents and/or product identification shall facilitate correct stock rotation of goods in storage and ensure materials are used in the correct order and within the prescribed shelf life. Where the company employs third-party contractors, all the requirements specified in this section shall be clearly defined in the contract or the company shall be certificated to the Global Standard for Storage and Distribution .
Procedures are in place to ensure product temperature requirements are met. The procedure includes:_ Using data logging devices Sites temperature system was validated in 2007.
N/A Y
Not applicable no materials, packaging or process equipment are stored outside.
4.12.5
Stock rotation is managed by a FIFO system. Incoming materials are labelled with site codes which provide the basis for tracing materials through the system. Materials inspected during the site inspection were all within their Best Before dates. Examples checked Not applicable: Customer specifies and manages their own transport
4.12.6
N/A
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Y
4.12.7
4.12.8
Traceability shall be ensured during storage and transportation. There shall be a clear record of dispatch and receipt of goods and materials demonstrating that sufficient checks have been completed during the transfer of goods. Documented maintenance and hygiene procedures shall be maintained for all vehicles and equipment used for loading/unloading (e.g. hoses of silo installations). There shall be records of the measures taken.
The intake traceability mechanism: All product arriving is given a consignment number which stays with the product up until despatch.
Maintenance and hygiene procedures are in place for the companys vehicles to include calibration of the fridge units. Records of vehicle and equipment hygiene and maintenance measures were verified during the traceability exercise for that production date. Vehicle fridge calibration for WX04 XXA on the 16/04/09 was reviewed. All breakdowns are handled by Gullivers and MLC as is servicing of tractor units and fridge units.
4.12.9
Procedures shall, where appropriate, be in place in the case of vehicle or refrigeration equipment breakdown. All incidents of vehicle or refrigeration equipment breakdown shall be recorded and corrective action documented.
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5.0 5.1
PRODUCT CONTROL Product Design/Development

Product design and development procedures shall be in place to ensure manufacturing processes are capable of producing a safe and legal product. A HACCP-based study shall be part of the product design and development process. Production trials shall be carried out and thorough testing shall validate that product formulation and manufacturing processes are capable of producing a safe and legal product against the proposed shelf life. Shelf-life trials shall be undertaken using documented protocols reflecting conditions during storage and handling throughout shelf life. Results shall be recorded and retained and shall confirm compliance with relevant microbiological, chemical and organoleptic criteria. Where new products are introduced, the company shall ensure control of handling requirements for specific materials (refer to clause 5.2). Procedures shall be in place to confirm that product packaging conforms to relevant food safety legislation and specification and is suitable for its intended use. The companys senior management shall ensure that a system is in place to confirm that labelling of the product or other forms of customer information meets legislation for the designated country of use and in accordance with the appropriate product specification. Where a product is designed to enable a claim to be made to satisfy a consumer group, e.g. a nutritional claim of reduced sugar, the company shall ensure that the product formulation and production process is fully validated to meet the stated claim. The product design/development process shall be documented and effectively communicated throughout the organisation, to ensure that changes in formulation are adequately assessed for safety and legality.
NA NA NA NA
There is no programme of new product design and development on site.
There is no programme of new product design and development on site. There is no programme of new product design and development on site.
5.1.2
5.1.3
5.1.4
NA NA NA
5.1.5
5.1.6
5.1.7
NA
5.1.8
NA
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5.2
5.2
FUNDAMENTAL
Handling Requirements for Specific Materials Materials Containing Allergens and Identity-preserved Materials
Where raw materials and finished products require special procedures for handling specific materials (e.g. material containing allergens or the requirement for identity-preserved status such as Genetically Modified Organisms, assured organic status or special designated origin) these shall be in place to ensure that product safety, legality and quality are maintained. The company shall carry out risk assessment of raw materials to establish the presence and likelihood of contamination by allergens (refer to glossary). This shall include approval of raw material specifications. The company shall implement systems to specify the integrity of the raw material and compliance with specification throughout the purchasing and supply chain. The company shall identify and list allergencontaining materials handled on site. This shall include raw materials, intermediate and finished products.
The site has a documented allergen procedure QAPROC015 19/01/2010. Absence of GM material is guaranteed by the Companys purchasing policies and in statements received from suppliers in specifications and other communications
Statement of Intent
5.2.1.1
The Company has carried out a risk assessment of its raw materials.
5.2.1.2
The company has identified and listed all allergens in its raw materials, intermediate and finished products. Allergens identified: Whole nuts Celery
5.2.1.3
5.2.1.4
5.2.1.5
5.2.1.6
5.2.1.7
Risk assessment shall be carried out to identify routes of contamination and establish documented policies and procedures for handling raw materials, intermediate and finished products to ensure cross contamination is avoided. This shall include as appropriate: physical or time segregation while allergen containing materials are being stored, processed or packed use of identified, dedicated equipment for processing or cleaning all food brought onto site including that by staff. Where rework is used, or reworking operations carried out, procedures shall be implemented to minimise cross contamination from allergen-containing materials and ensure the safety, legality and quality of the finished product. Where a claim is made regarding the suitability of a food for allergy or food sensitivity sufferers, the company shall ensure that the production process is fully validated to meet the stated claim. This shall be documented. Based on risk assessment, documented equipment or area cleaning procedures shall be undertaken to remove or reduce to acceptable levels any potential cross contamination in compliance with finished product specifications. This shall include validation of cleaning methods and appropriate waste handling and spillage controls. All relevant personnel, including temporary staff and contractors, shall be appropriately trained in allergen handling procedures prior to commencing work and shall be adequately supervised throughout the working period.
Risk assessments have been carried out by Ian Booth and the results documented in the Allergen procedure and HACCP study. Raw material handling procedures include:Segregation
N/A
Not applicable there is no rework on this site.
N/A
Not applicable there are no free from claims made by the site.
N/A
No products requiring special handling procedures are packed.
Staff have been trained in handling allergens and to follow company procedures.
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Y
5.2.1.8
Any non-conformities relating to allergen control shall be included in the management review process (refer to clause 1.7) and may include, as appropriate, internal or external incidents and customer complaints such as labelling or cross-packing errors. The review process shall also consider updates or changes in allergen legislation or scientific information.
Allergen non-conformities are discussed at a senior management level as part of the management review process. See 1.7.
5.2.2
5.2.2.1
Identity-preserved Materials
Where an identity preserved claim is made, e.g. that a product is organic, or where products brought onto site may contain materials which require segregation, e.g. Genetically Modified Organisms, the company shall carry out a risk assessment of raw materials to specify the integrity of the raw material and compliance with specification throughout the purchasing and supply chain. Risk assessment shall be carried out to identify routes of contamination and establish documented policies and procedures for handling raw materials, intermediate and finished products to ensure cross contamination is avoided and that controls are in place to maintain identity preserved status. There are no identity preserved claims made.
NA
5.2.2.2
There are no identity preserved claims made.
NA
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5.3
Foreign Body Detection

The company shall have appropriate foreign body detection equipment in place and ensure its effective operation. Foreign body detection equipment shall be in place unless it can be justified as not necessary. This justification shall be documented. Detection equipment shall be situated to maximise foreign body detection within the finished product. The sensitivity of detection shall be specified and best practice applied with regard to the nature of the food, the location of the detector and any other factors influencing the sensitivity of the detector. The metal or foreign body detector shall incorporate the following based on best practice: an alarm on a belt stop system an automatic rejection device which shall either divert contaminated product out of the product flow or to a secure unit accessible only to authorised personnel in-line detectors which identify the location of the contaminant and effectively segregate the affected product. There shall be documented procedures specifying corrective and investigative action to be taken in the event of the detection of metal or a foreign body. The company shall establish and implement procedures for the operation, routine monitoring, testing and calibration of the metal or other foreign body detectors. This shall include as a minimum: frequency and sensitivity of checks authorisation of trained personnel to carry out specified tasks documentation of checks. The company shall establish and implement corrective action and reporting procedures in the event of the monitoring and testing procedure identifying any failure of the metal or foreign body detector. Action shall include a combination of isolation, quarantining and reinspection of all product produced since the last acceptance test of the metal or other foreign body detector.
N/A Y
No metal detection or other foreign body detection.
The sites HACCP study has not identified the need for foreign body detectors.
5.3.2
N/A N/A
No metal detection.
5.3.3
No metal detection.
5.3.4
N/A
No metal detection.
5.3.5
N/A
No metal detection.
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5.4
Product Packaging
Product packaging shall be appropriate for the intended use and shall be stored under conditions to minimise contamination and deterioration. Certificates of conformity or other evidence shall be available for product packaging to confirm its suitability for use.
Y Y
Packaging materials are stored in the main locked building , which is a suitable dry, dust free location.
Specifications or certificates of conformity are available for all packaging materials used by the company. Examples: Packaging specification Netting NNZ food safe declarations in place as were declarations from plastics supplier Veri-pack.
5.4.2
Where appropriate, packaging shall be stored away from raw materials and finished product. Any part-used packaging materials suitable for use shall be effectively protected before being returned to an appropriate storage area. Product contact liners (or raw material/work-in progress contact liners) shall be appropriately coloured and of sufficient gauge to prevent accidental contamination where appropriate. Where packaging materials pose a product safety risk, special handling procedures shall be in place to prevent product contamination.
Y Y N/A N/A
See 5.4 Packaging materials are stored away from finished product and raw materials. Part used packaging is re-wrapped and returned to storage. During the site inspection part used product bags were observed to be suitably protected No liners are used.
5.4.3
5.4.4
5.4.5
Not applicable there are no packaging materials which pose a risk to product safety.
5.5.1
Product Inspection and Laboratory Testing

The company shall undertake or subcontract inspection and analyses which are critical to confirm product safety, legality and quality, using appropriate procedures, facilities and standards which prevent risk to product safety. Based on risk assessment, testing and inspection schedules shall be established to ensure specified product requirements are met. Inspection and testing methods and frequency shall be documented. Test and inspection results shall be recorded and reviewed regularly to identify trends. Appropriate actions shall be implemented promptly to address any unsatisfactory results or where trends indicate unsatisfactory results. Where validation of finished product quality attributes is required, organoleptic tests shall be carried out regularly in accordance with specifications and shall be recorded. The company shall ensure that a system of ongoing shelf life assessment is in place. This shall be based on risk and shall include microbiological and sensory analysis as well as relevant chemical factors such as pH and aw . Records and results from shelf life tests shall validate the minimum shelf life period indicated on the product.
Inspection and analysis critical to product safety undertaken see details below.
5.5.1.1
Y Y N/A N/A
5.5.1.2
Finished product is tested in line with a pre-determined schedule: Pesticide Residue Testing conducted randomly through year Micro Testing is conducted monthly Suppliers must supply test results during the tendering process along with signed undertakings. System, for record keeping: All test results are held to monitor and identify any trends. Results 18/02/10 Batch 06/05 03917794 - Cucumbers No organoleptic testing is undertaken.
5.5.1.3
5.5.1.4
Customers do not specify shelf-life testing
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5.5.2
5.5.2.1
Laboratory Testing
Pathogen testing shall be subcontracted to an external laboratory or, where conducted internally, the laboratory facility shall be remote from the manufacturing site. Where routine testing laboratories are present on a manufacturing site, they shall be located, designed and operated to eliminate potential risks to product safety. Controls shall be documented, implemented and shall include consideration of the following: design and operation of drainage and ventilation systems access and security of the facility movement of laboratory personnel protective clothing arrangements processes for obtaining product samples disposal of laboratory waste. Where the company undertakes or subcontracts analyses which are critical to product safety or legality, the laboratory, or subcontractors shall have gained recognised laboratory accreditation or operate in accordance with the requirements and principles of ISO 17025. Documented justification shall be available where accredited methods are not undertaken. Procedures shall be in place to ensure reliability of laboratory results, other than those specified in 5.5.2.3. These shall include: use of recognised test methods, where available documented testing procedures ensuring staff are suitably qualified and/or trained and competent to carry out the analysis required use of a system to verify the accuracy of test results, e.g. ring or proficiency testing 1. use of appropriately calibrated and maintained equipment.
Y NA
External Lab: Eurofins UKAS 0680,
5.5.2.2
Not Applicable : No laboratory on site
5.5.2.3
The external laboratories have UKAS accreditation, certificate number 0680.
5.5.2.4
NA
Not Applicable accredited laboratory used.
5.6
Control of Non-conforming Product

The company shall ensure all out-ofspecification product is clearly identified, labelled and quarantined. Procedures for the control of non-conforming material, including rejection, acceptance by concession, or regrading for an alternative use, shall be in place and understood by all relevant staff. Decisions shall be approved by authorised staff. Corrective actions shall be implemented to avoid recurrence of non-conformance. Details of the non-conformance and action taken shall be documented. All non-conforming material shall be clearly identified and quarantined as appropriate, and handled or disposed of according to the nature of the problem and/or the specific requirements of the customer.
Y Y
All out of specification product is clearly identified, labelled and quarantined and handled according to documented procedures.
The procedure includes isolation, labelling and quarantining products in a designated area. The technical managers are responsible for the disposition or release of products.
5.6.2
Records of corrective actions arising from non conforming product included the details of the non conformance and the action taken to prevent a recurrence.
5.6.3
See 5.6.1
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5.7
Product Release
The company shall ensure that finished product is not released unless all agreed procedures have been followed. A procedure shall be in place, based on risk assessment, to ensure that only products conforming to specification are dispatched, and this shall include release by authorised staff.
Product release procedures are in place see 5.7.1.
Line supervisors and managers are responsible for the quality of products produced. Where requirements do not meet finished product specifications or customer requirements products are put on hold. The procedure includes isolation, labelling and quarantining products in a designated area.
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6.0
PROCESS CONTROL
The company shall be able to demonstrate effective control of all operations undertaken.
The company is able to demonstrate effective control of operations within the scope of evaluation. Process settings are documented in procedures / work instructions and records are maintained.
6.1
6.1
FUNDAMENTAL
Control of Operations
The company shall operate procedures that verify that the processes and equipment employed are capable of producing consistently safe and legal product with the desired quality characteristics, in full compliance with the HACCP food safety plan. A process shall ensure that all Critical Control Points and specified limits identified through HACCP are transferred into day-to-day production controls and are fully validated.
Statement of Intent
The company has procedures that verify that the processes and equipment are capable of producing consistently safe and legal product with the desired quality characteristics.
6.1.1
The CCPs identified in the HACCP study are incorporated into the daily production control records, and these are completed by production staff and verified by QA. See 2.9.1. For example CCP1 Continuous temperature monitoring is undertaken. Records for CCPs were reviewed as part of the traceability exercise see 3.9. Validation of CCPs is included in the annual HACCP review see 2.8.3. No process monitoring undertaken, however the temperature of the fridge is monitored daily.
6.1.2
6.1.3
Process monitoring such as temperature, time, pressure and chemical properties shall be established and adequately controlled to ensure that product is produced within the required process specification. Process monitoring shall be carried out by trained staff and shall be documented. In circumstances where process parameters are controlled by in-line monitoring devices, these shall be linked to a suitable failure alert system that is routinely tested. In the case of equipment failure or deviation of the process from specification, procedures shall be in place to establish the safety status of the product, prior to release. Corrective action shall be taken in the event of deviation of process from specification. This shall be recorded. Procedures shall be in place to ensure that products are packed into the correct packaging and correctly labelled with due consideration given to product changeover. In the event of changes to product formulation, processing methods, equipment or packaging, monitoring of the specified process shall be re-established based on HACCP.
N/A N/A N/A Y Y

Y
No process monitoring undertaken
6.1.4
No process parameters being controlled.
6.1.5
Procedures are in place in the event of equipment failure.
6.1.6
Corrective action taken when a parameter falls out of specification is logged on the relevant process control document. A procedure for label checking is in place to ensure that product is packed into the correct packaging.
6.1.7
6.1.8
Changes to product formulation, processing methods, equipment and packaging are correctly managed to ensure that changes do not compromise product safety, legality and quality.
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6.2
Quantity Weight, Volume and Number Control

The company shall operate a quantity control system which conforms to legal requirements and additional industry sector codes or specified customer requirement in the country where the product is sold. The frequency and methodology of quantity checking shall meet the requirements of appropriate legislation governing quantity verification. Where the quantity of the product is not governed by legislative requirements (e.g. bulk quantity), the product must conform to customer requirements.
The company operates a quantity control system which takes into account customer requirements, industry codes of practice and legal requirements.
6.2.1
Y N/A
Products are packed by count and minimum weight. Manual checks are made by QCs at despatch and during packing.
6.2.2
Not applicable no bulk products handled by the site.
6.3
Calibration and Control of Measuring and Monitoring Devices

Measuring equipment used to monitor CCPs and product safety and legality shall be identified. The identified measuring equipment shall be calibrated to a recognised national or international standard. Where a traceable calibration is not possible, the company shall demonstrate the basis by which standardisation is carried out. The company has identified measuring equipment used to monitor critical control points, product safety and legality. The identified measuring equipment is calibrated to a recognised national standard. QAPROC007 Issue 3 Scale Calibration Procedure Scales are calibrated externally annually by Avon Scales (UK Weighing Federation no - 226425) Scale No 76576 Date: 19/02/10
6.3.1
6.3.2
6.3.3
The company shall identify measuring equipment used to monitor CCPs and product safety and legality. This shall include as a minimum: a documented list of equipment equipment identified and marked in accordance with requirements (e.g. numbered, calibration due date). All identified measuring devices shall be checked and where necessary adjusted: at a predetermined frequency, based on risk assessment by trained staff to a defined method traceable to a recognised national or international standard where possible. Results shall be documented. The prescribed measuring and monitoring devices shall be: prevented from adjustment by unauthorised staff protected from damage, deterioration or misuse.
Scales are also verified internally using certificated weights Reference No Cert date 3374 22/02/10 Hand held temperature probes are verified against a calibrated reference thermometer (ETI UKAS 0601) Reference No Cert date R0001 -16/02/10 03988 01/07/09 Test Caps 04/03/10 The central temperature monitoring system is calibrated on an annual basis. A list of identified measuring equipment used to monitor CCPs, product safety and legality is in place. Equipment is identified and marked with a reference number and calibration due dates.
Records of all calibration checks and associated actions are maintained.
Measuring and monitoring equipment is protected from damage, deterioration or misuse.
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Y
6.3.4
Procedures shall be in place to record actions taken when the prescribed measuring and monitoring devices are found not to be operating within specified limits.
The procedure to record actions taken when the prescribed measuring and monitoring devices are found not to be operating within specified limits is in place. Technical and production managers are informed and the significance of the observation reviewed and its effect on products already packed. Non conformance procedures are enacted where required.
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7.0 7.1
7.1
FUNDAMENTAL
PERSONNEL Training Raw Material Handling, Preparation, Processing, Packing and Storage Areas
The company shall ensure that personnel performing work that affects product safety, legality and quality are demonstrably competent to carry out their activity, through training, work experience or qualification. All relevant personnel, including temporary staff and contractors, shall be appropriately trained prior to commencing work and adequately supervised throughout the working period.
Statement of Intent 7.1.1
The company ensures that all employees are adequately trained, instructed and supervised, staff are able to demonstrate competency to conduct their activities.
Induction training records were verified during the visit for: Name Stuart Lawson Technical Manager Shift Operations Manager A programme of food hygiene is in place. Staff hygiene Medical Questionnaire Food Safety Refrigeration Monitoring Procedures for training and monitoring staff engaged in CCP activities is in place. CCP training records reviewed: CCP Person 1 Operations Team
7.1.2
Where personnel are engaged in activities relating to Critical Control Points, relevant training and documented monitoring procedures shall be in place.
7.1.3
7.1.4
7.1.5
The company shall put in place documented programmes covering the training needs of relevant personnel. These shall include as a minimum: identifying the necessary competencies for specific roles providing training or other action to ensure staff have the necessary competencies reviewing and auditing the implementation and effectiveness of training and competency of the trainer consideration of the delivery of training in the appropriate language of trainees. Records of all training shall be available. This shall include as a minimum: name of trainee and confirmation of attendance date and duration of training title or course contents as appropriate training provider. The company shall routinely review the competencies of staff and provide relevant training as appropriate. This may be in the form of training, refresher training, coaching, mentoring or on-the-job experience.
There are training programmes in place that cover all employees. These procedures include: Competency Identification Yes Training in competencies Yes Review and audit of effectiveness Yes Delivery of Training Yes
Training records include: Named of trainee Yes Date of Training Yes Duration of Training Yes Course Content Yes Training Provider : Yes Method for review of Competency: reviewed as part of the management review meetings conducted.
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7.2
Access and Movement of Personnel

The company shall ensure that access and movement of personnel, visitors and contractors shall not compromise product safety. There shall be a plan of the site which defines access points for personnel, travel routes and staff facilities. If it is necessary to allow access through production areas, designated walkways shall be provided that ensure there is adequate segregation from materials. All facilities shall be designed and positioned, where possible, so that movement of personnel is by simple, logical routes. Contractors and visitors, including drivers, shall be made aware of all procedures for access to premises and the requirements of the areas they are visiting, with special reference to hazards and potential product contamination.
Y Y Y Y Y
Access to the site is controlled so that product safety is not compromised. All visitors and contractors have to report in when they arrive on site and are all required to complete a medical screening questionnaire if visiting production or storage areas. A site plan dated, 2010, is in place showing the various personnel and travel routes. Where product is exposed or there is a potential risk to materials of foreign body contamination, the access through production areas is by designated walkways to ensure there is adequate segregation from products and raw materials. Staff facilities are of a suitable standard and are located to facilitate logical movement of staff entering production and storage areas. Contractors and visitors are all required to complete a medical screening questionnaire prior to entering production areas as well as reading and signing to comply with the sites GMP and personal hygiene rules. All visitors and contractors are supervised whilst on site.
7.2.2
7.2.3
7.2.4
7.3
Personal Hygiene Raw Materials Handling, Preparation, Processing, Packing and Storage Areas
The companys personal hygiene standards shall be documented and adopted by all personnel, including contractors and visitors to the production facility. These standards shall be formulated with due regard to risk of product contamination. The requirements for personal hygiene shall be documented and communicated to all personnel. Compliance with the requirements shall be checked regularly. Based on risk assessment, the company shall document its jewellery policy. Watches shall not be worn. Jewellery shall not be worn, with the exception of a plain wedding ring, a wedding wristband and sleeper earrings (continuous loop). Rings and studs in exposed parts of the body, such as noses, tongues and eyebrows, shall not be worn. Hand cleaning shall be performed at a frequency that is appropriate, based on risk assessment. There are documented standards for personal hygiene for employees, visitors and contractors.
Company personal hygiene rules are in place.
7.3.1
Y Y Y
7.3.2
The site personal hygiene rules are communicated to staff by means of induction training, refresher training and notice boards. Internal and external audits are used to monitor compliance with requirements. The jewellery policy is included in the company personal hygiene rules see 7.3. Jewellery and watches are not worn, with the exception of a plain wedding ring and sleeper earrings. No evidence of non compliance observed during the factory inspection.
7.3.3
7.3.4
Hand cleaning is documented within the hygiene policy. All staff are required to wash their hands when entering the factory and after using the toilets. No evidence of non compliance observed during the factory inspection.
7.3.5
7.3.6
Fingernails shall be kept short, clean and unvarnished. False fingernails shall not be permitted. Where visitors cannot comply, suitable control procedures shall be in place, e.g. non-handling of product, use of gloves. Excessive perfume or aftershave shall not be worn. Smoking (where permitted under law), eating and drinking shall only be permitted in designated areas segregated from foodhandling and storage areas.
Y Y Y
Documented in the personal hygiene policy - fingernails are kept short and unvarnished, false nails are not permitted. No evidence of non compliance observed during the factory inspection.
Documented in the personal hygiene policy - excessive perfume or aftershave is not permitted. No evidence of non compliance observed during the factory inspection. Smoking is only permitted outside in the purpose built shelter. Eating and drinking is only permitted in the canteen. No evidence of non compliance observed during the factory inspection.
7.3.7
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Y
7.3.8
7.3.9
All cuts and grazes on exposed skin shall be covered by an appropriately coloured plaster different from the product colour (preferably blue) and containing a metal detectable strip where metal detection/X-ray equipment is in use. These shall be company issued and monitored. Where appropriate, in addition to the plaster, a finger stall shall be worn. A sample from each batch of plasters shall be successfully tested through a metal detector and records shall be kept. Procedures shall be in place to control the use of personal medicines to minimise the risk of contamination.
Cuts and grazes on exposed skin are covered by detectable blue metal strip plasters that are issued and monitored. Fingerstalls are available.
NA Y
Not applicable no metal detection in place.
7.3.10
The procedures for the control of personal medicines is included in the company personal hygiene rules see 7.3. Personal medicines are not permitted in production areas. No evidence of non compliance observed during the factory inspection.
7.4
Medical Screening
The company shall ensure that medical screening procedures are in place for all employees, contractors or visitors who will be working in or visiting areas where product safety could be compromised. Medical screening procedures are in place for all employees and visitors, where product safety could be compromised.
Employees are required to complete a medical questionnaire prior to starting work. See 7.3 Company personal hygiene rules All employees are notified of the requirements to report sickness during their induction training. This includes reporting sickness when returning to work and sickness during holidays. See 7.3 Company personal hygiene rules Visitors complete a questionnaire which is checked by an appropriate manager before being permitted to enter production or storage areas. See 7.2.4 See 7.3 Company personal hygiene rules See 7.2.4 Visitors and contractors undergo medical screening before entering the raw material, preparation, processing, packing and storage areas.
7.4.1
7.4.2
7.4.3
The company shall have a procedure for the notification by employees, including temporary employees, of any relevant infections, disease or condition with which they may have been in contact or be suffering from. Where there may be risk to product safety, visitors and contractors shall be required to complete a health questionnaire prior to entering the raw material, preparation, processing, packing and storage areas. Where appropriate, these persons shall undergo medical screening before permission is granted. There shall be written and communicated procedures for employees, including temporary employees, contractors and visitors, on action to be taken in the case of infectious disease from which they may be suffering or have been in contact. Particular consideration should be given where product safety may be compromised. Expert medical advice shall be sought where required.
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7.5
Protective Clothing Employees or Visitors to Production Areas

Suitable company issued protective clothing shall be worn by employees, contractors or visitors working in or entering production areas. Based on risk assessment, the company shall document and communicate to all employees, contractors or visitors the rules regarding the wearing and changing of protective clothing in specified work areas, e.g. high-risk and lowrisk areas. This shall also include policies for wearing of protective clothing away from the production environment, e.g. removal before entering toilets, use of canteen and smoking areas. Protective clothing shall be available that is: provided in sufficient numbers for each employee of suitable design to prevent contamination of the product (as a minimum contain no external pockets or sewn on buttons). Clean and dirty clothing shall be segregated and controlled to prevent cross contamination. Laundering of protective clothing shall take place in-house using defined and verified criteria to validate the effectiveness of the laundering process, or by an approved contracted and audited laundry. The effectiveness of cleaning shall be monitored. Washing of workwear by the employee is exceptional but shall be deemed acceptable where, based on a detailed risk assessment, it can be confirmed there is no risk to product safety. Detailed procedures shall be in place to ensure the effectiveness of the laundering process. Where there is the risk of contamination, smoking and eating while wearing protective clothing shall not be permitted. All scalp hair shall be fully contained to prevent product contamination. Based on risk assessment, snoods for beards and moustaches shall be worn to prevent product contamination. Suitable footwear shall be worn within the production environment. If gloves are used, they shall be replaced regularly. Where appropriate, gloves shall be suitable for food use; of a disposable type; of a distinctive colour (blue where possible) be intact, and not shed loose fibres. For operations involving high-risk products (refer to glossary) all visibly distinctive protective clothing (including footwear) shall be applied when entering, and removed when leaving, the high risk area and stored in a designated changing area.
Y Y
Protective clothing provided for staff includes:mobcap, beard snood, coat, shoes. Visitors / contractors are provided with a mob cap, coat and appropriate PPE safety equipment. Rules for the wearing of protective clothing have been developed. The rules are detailed in the companys personal hygiene rules see 7.3 Staff are not permitted to wear protective clothing outside the building, when visiting the toilets and when eating food. See 7.5.5.
7.5.2
Workwear was seen to be of suitable design to prevent contamination of the product.
7.5.3
Y Y
Clean and dirty clothing is suitably segregated.
7.5.4
Protective clothing is laundered by personnel.
7.5.5
Y Y Y Y Y NA
Protective clothing is removed prior to eating, smoking or using toilet facilities. Staff are required to wear company issued hats.
7.5.6
7.5.7
Beard snoods are provided.
7.5.8
Footwear worn on site is suitable for the environment.
7.5.9
Gloves when worn are replaced regularly and are suitable for food use.
7.5.10
Not Applicable Site is not High Risk
Page 51 of 51
Report No: A00722P

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F002: Global Standard for Food Safety Issue 5: January 2008

Audit grade: Audit type:

Previous audit grade:

Certification Body Details

Report No: A00722P

Auditor: Alex Howells

F002: Global Standard for Food Safety Issue 5: January 2008

Report No: A00722P

Auditor: Alex Howells

F002: Global Standard for Food Safety Issue 5: January 2008

Present at Audit (x)

Report No: A00722P

Auditor: Alex Howells

F002: Global Standard for Food Safety Issue 5: January 2008

Audit Duration Details

Audit Duration per day

Report No: A00722P

Auditor: Alex Howells

F002 Global Standard for Food Safety Issue 5: January 2008

NON-CONFORMITY SUMMARY SHEET

List of Non Conformities

Report No: A00722P

Auditor: Alex Howells

FOO2: Global Standard for Food Safety Issue 5: January 2008

Detailed Audit Report

SENIOR MANAGEMENT COMMITMENT AND CONTINUAL IMPROVEMENT

Report No: A00722P

Auditor: Alex Howells

FOO2: Global Standard for Food Safety Issue 5: January 2008

Report No: A00722P

Auditor: Alex Howells

FOO2: Global Standard for Food Safety Issue 5: January 2008

THE FOOD SAFETY PLAN HACCP

The HACCP Food Safety Team Codex Alimentarius Step 1

Report No: A00722P

Auditor: Alex Howells

FOO2: Global Standard for Food Safety Issue 5: January 2008

Describe the Product Codex Alimentarius Step 2

Identify Intended Use Codex Alimentarius Step 3

Report No: A00722P

Auditor: Alex Howells

FOO2: Global Standard for Food Safety Issue 5: January 2008

Construct a Process Flow Diagram Codex Alimentarius Step 4

Raw Materials Yes

Verify Flow Diagram Codex Alimentarius Step 5

Report No: A00722P

Auditor: Alex Howells

FOO2: Global Standard for Food Safety Issue 5: January 2008

Determine the Critical Control Points(CCP) Codex Alimentarius Step 7, Principle 2

Not applicable there are no / details of subjective standards

Report No: A00722P

Auditor: Alex Howells

FOO2: Global Standard for Food Safety Issue 5: January 2008

Monitoring systems: CCP 1: Automatic temperature monitoring system in place.

Establish a Corrective Action Plan Codex Alimentarius Step 10, Principle 5

Report No: A00722P

Auditor: Alex Howells

FOO2: Global Standard for Food Safety Issue 5: January 2008

Establish Verification Procedures Codex Alimentarius Step 11, Principle 6

Review the HACCP Plan

Annual HACCP Review Date: 15/03/10

Report No: A00722P