BRC Report 189 190

Audit Report
Global Standard for Food Safety Issue 7: July 2015
1.Audit Summary
BRC Site
Company name Swani Spice Mills Pvt Ltd 4451668
Code
Site name Swani Spice Mills Pvt Ltd
Processing (Cleaning, grinding/ milling, crushing, blending, Roasting) of spices,

Scope of audit oil seed, botanicals and herbs and packing in high density polyethylene, poly-
laminated , Polywoven, kraft paper, gunny bags or corrugated cartons..
Exclusions from
NONE
scope
Justification for
NA
exclusion
Audit Finish Date 2018-04-11
Re-audit due date 2019-04-16
Voluntary modules included

Modules Result Details
FSMA Preventative
Controls and FSVP Passed
Preparedness
Choose
Choose a module
an item
Choose
Choose a module
an item
2. Audit Results
Audit result Certificated Audit grade A Audit type Announced
Previous audit grade A Previous audit date 2017-04-10
Fundamental 0
Number of non-conformities Critical 0
Major 0
Minor 07
Intertek Certification Ltd

10a Victory Park, Victory Road, Derby, DE24 8ZF, United Kingdom
F002 English Food 7 Template issue 9 28/7/2017 Page 1 Report No. 091A1304001 Auditor: Harshad Karulkar
F103-20-BRC Food Report Format
3.Company Details
Address A 189/190, MIDC, Industrial Estate, TTC, Opp Village Khairne, Thane Belapur road,
New Mumbai 400705, India
Country India Site +912241268001

Telephone
Number
Commercial Mr.Harjiv Swani Email harjiv@swanispice.com

representative
Name
Technical Mr. Vinayak Chondekar Email steamteam@swanispice.com

representative
Name
4.Company Profile
Plant size <10K sq.m No. of 51-500 No. of HACCP 1-3
(metres square) employees plans
Subcontracted processes Yes
Other certificates held FSSC 22000: 2010, Organic, SEDEX, Rainforest Alliance.
Regions exported to Europe

Asia
North America
Africa
None
Choose a region
Company registration 10013022001931

number
Major changes since last NONE

BRC audit
Company Description
Swani Corporation has been established in 1956. The group is one of the oldest exporters of Spices,
Sesame Seeds, Psyllium, and Botanicals Herbs & Foodstuff from India. Swani Spice Mills Pvt Ltd is the
present unit located in Mahape Industrial area near New Bombay. The present unit within this facility
structure is operational since 1992 & has 4005 square meters built-up area. The Processing plant uses
Buhler cleaning / grinding lines & colour sortex technology. Company also procures dried products such
as dehydrated onions & garlics, black & green pepper, senna leaves which are not processed onsite but
supplied to the customer if required. The unit also has own Laboratory for physical and analytical testing.

The Plant HACCP Certified since Jan 2004 & ISO 22000:2005 certified since September 2008. The unit
operates in 2 shifts and a work force of 125 personnel per shift. Company has produced almost 10500
tons of finished product last year. The company does not wish to disclose it’s present turnover. The
material is supplied to various markets and clients in Japan, Europe, USA, Canada, South Africa,
Australia, New Zealand & Argentina. Company has been certified to BRC since few years & is not using
BRC Logo on their product or packaging other than promotional material and visiting cards.
5.Product Characteristics
Product categories 15 - Dried food and ingredients
Category
Category
Category
Category
Category
Finished product safety rationale Products have low moisture content around 10% and are shelf
stable material at ambient temperature.
High care No High risk No Ambient high care No
Justification for area Raw material is received, handled and stored in dry form. Moisture
levels are around 10%. All material & handling area is identified as
low risk area & product is meant to be used as an ingredient to
cooking process at customers end. Processing activity comprising
of cleaning, grinding, blending or roasting activity. After packing the
finished goods are fully enclosed and not vulnerable to foreign body
or microbial contamination. Applicable areas have been identified
by the site based on HACCP principles and decision tree with
appropriate food safety controls and also as per directives from the
competent authority. Controls are in place to identify & restrict
movement of personnel and material between all areas.
Allergens handled on site Sesame

Mustard
Sulphur dioxide and Sulphites
Celery
Choose an allergen
Choose an allergen
Choose an allergen
Choose an allergen
Choose an allergen
Choose an allergen
Choose an allergen
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Choose an allergen
Choose an allergen
Choose an allergen

Product claims made e.g. IP, Organic
organic
Product recalls in last 12 Months No
Products in production at the time Cumen seed whoe lot no 930, Ground chilly Lot PO no 110917,
of the audit Corriander powder 998, Chopped chilly flakes lot no 945.
6.Audit Duration Details

On-site duration 20 man hours Duration of production 10 man hours
facility inspection
Reasons for deviation NONE

from typical or expected
audit duration
Next audit type selected Announced
Audit Duration per day

Audit Days Audit Dates Audit Start Time Audit Finish Time
1 (start date) 2018-04-09 09:30 18:00
2 2018-04-10 09:45 18:15
3 (end date) 2018-04-11 09:00 17:30
Auditor (s) number(s) Names and roles of others
Auditor Number 168088 Harshad Karulkar
Second Auditor
N/A
Number
Present at audit
Note: the most senior operations
manager on site should be listed
first and be present at both
opening & closing meetings (ref:
clause 1.1.9)
Name / Job Title Opening Meeting Site Inspection Procedure Closing Meeting
Review
Harjiv Swani - Director X X

X
Chetan Kaul – GM Operations X X X
Vinayak Chondekar – Plant X X X X
Head
Purshottam Kote – Production X X X X
Officer
Deepak Desai – Hygiene officer X X X X
Rajesh Patel – Maintenance X X X X
manager
Purshottan Kore – Production X X X
Manager
Nilesh Pawar – Maintenance X X X X
Eng
Anant Kokate – Material X X X
manager
Sonika Putto – QA Technical X X X X
manager
X
Umesh M Veedu – AM HR X X
`Kedar Kavekar – Systems X X X X
Manager

Non-Conformity Summary Sheet
Critical or Major Non Conformities Against Fundamental Requirements
No. Clause Details of non-conformity Critical or Major? Anticipated re-audit date
Critical
No. Clause Details of non-conformity Anticipated re-audit date

Major
Evidence
Proposed preventive provided
No. Clause Details of non-conformity Correction action plan (based on root document, Date reviewed Reviewed by
cause analysis) photograph,
visit/other
Minor
Evidence
provided
Details of non- Proposed preventive action plan Date Reviewed
No. Clause Correction document,
conformity (based on root cause analysis) reviewed by
photograph,
visit/other
Although label issuance is being
recorded in the register, it was not Training Record
under document control. for label control
Document
awareness and
identification for label Document identification Now onwards all the label control documentation. Harshad
1 3.2.1 control register as per for the label control is 2018-04-30
entries and return of labels will be Karulkar
the company’s system established. under document control. Appropriate Documented
was not evident. training of the concerned person is format of the label
conducted and the format is included in control.
the System.

Earlier we were doing internal audit Revised Internal
once in a year and frequency of which Audit Calendar.
has been revised to twice in a year,
additionally GMP-GHP audits are being Training record
The program of The Internal Audits will
done on monthly basis. But the internal against the BRC
internal audit is be spread out
audits are not spread throughout the Internal Audit Harshad
2 3.4.1 scheduled two times throughout the year & 2018-04-30
year due to inadequate interpretation of Clause 3.4 Karulkar
and not throughout the appropriately
the BRC clausal requirements.
year. documented.
Henceforth the internal Audit calendar
is revised and the audits are spread
across the year.
The contract with Microtrol was with

Head Office and could not be produced
during the Audit due to
miscommunication. Henceforth the
relevant contracts will be kept ready at Contract with
Contract made with
Contract made with the site. Microtrol
Microtrol by site as an Harshad
3 3.5.4.3 Microtrol is available and 2018-04-30
service provider was Karulkar
documented. To ensure the compliance of the Training Plan-E-
not evident. requirements, the training for Head mail.
Office representatives handling the
contract of such outsourced activities, is
planned on 5th of May in conversation
with the Management.
Hygiene clearance Although each maintenance activity is Training on

Hygiene clearance for
activity of maintenance followed by hygiene clearance at the Maintenance
maintenance activity
activities conducted, is shop floor, but the offline maintenance clause (4.7) for
conducted for Harshad
4 4.7.2 recorded, documented of accessories which are rectified in Maintenance 2018-04-30
Destoner screen on Karulkar
and verified by the workshop, was not covered under Team which
28th March & 30th
concerned authorized formal hygiene clearance, due to lack includes Hygiene
August for sieve was
person. of awareness. clearance and its
not recorded in the
importance is

breakdown record. conducted and its
evaluation is
conducted as well.
Training records
Record of Hygiene
Clearance
Microbiological checks As per existing routine, swabs were

as recorded to capture being taken from random points. In
cleaning performance addition to that, as a part of continual
do not reflect trends in improvement & based on the difficulty
the specific level for effective cleaning, the
harbourage points as harbourage points were identified.
identified. These Harbourage points and the Swab Test
document were still under review at the Results of
Identified harborage time of audit. Harbourage
points will be checked points.
for Microbiological load Post audit to confirm the microbiological Harshad
5 4.11.5 and recorded in the load of the harbourage points vs other Swab Results of 2018-04-30
Karulkar
same format as (Swab points, the line study was carried out. Routine Points.
Analysis Record QA- And 10 points were checked and tested
MIC-F-07) for TPC, Y&M & Coliforms. Changeover
checklist before &
The results are found to be comparable after
during this study.
Similar studies will be conducted

periodically to confirm the Harbourage
points and complete the document
review.
6 5.4.2 The most recent The Vulnerability risk Vulnerability Assessment of Coriander 2018-04-30
Vulnerability Harshad
Vulnerability risk assessment is reviewed Group is done but not been done

assessment review and completed for all separately for imported coriander Assessment Karulkar
was not completed to product groups including because we considered that it is being
reflect product groups imported coriander for covered under the above said category Risk assessment
being sourced for possible risk of because of inadequate interpretation.
possible risk of adulteration and Hence the risk associated with the Supplier’s FSSC
adulteration and substitution. imported coriander is completed and certificate.
substitution such as documented. And going further any
imported coriander. other imported material will be Training record on
assessed and documented. Vulnerability
Assessment
Although label issuing was recorded in

Training Record
Document identification the register, it was not under document
Accounting of those for label control
for the label control is control, due to lack of awareness.
labels which are extra, awareness and
established and labels
returned or damaged documentation. Harshad
7 6.2.2 which are extra/returned Now onwards all the label control 2018-04-30
after their application Karulkar
or damaged are entries and return, damaged labels are
is not reflecting on the Documented
recorded in the same recorded. Appropriate training of the
label control register. format of the label
register. concerned person is conducted and the
control.
format is included in the System.
Comments on non-conformities

Voluntary Modules Non-Conformity Summary Sheet
Critical
Major
Evidence provided
Proposed preventive action
document, Date Reviewed
No. Clause Details of non-conformity Correction plan (based on root cause
photograph, reviewed by
analysis)
visit/other

Minor
Evidence
Proposed preventive action provided
Date Reviewed
No. Clause Details of non-conformity Correction plan (based on root cause document,
reviewed by
analysis) photograph,
visit/other

FSMA Module Non-Conformity Summary Sheet
Critical
Major
Evidence provided
Proposed preventive action
document, Date Reviewed
No. Clause Details of non-conformity Correction plan (based on root cause
Minor photograph, reviewed by
analysis)
visit/other
Evidence
provided
Proposed preventive action plan (based on root
No. Clause Details of non-conformity Correction document, Date reviewed Reviewed by
cause analysis)
photograph,
visit/other

Risk Assessment of Coriander Group is Risk
Risk of radiological
Risk Assessment is done but not been done separately for assessment
hazards is not clearly
revised with the inclusion imported coriander as we considered that
documented as part
of imported coriander and it is being covered under the above said Declaration
of Imported coriander Harshad
1 117.130(a) additionally declaration category. Hence the risk associated with from the 2018-04-30
consignments Karulkar
from the supplier the imported coriander is completed and supplier
although declarations
regarding the radiological documented. And henceforth any other
supporting its safety Supplier
hazard is maintained. imported material will be assessed and
are maintained. Documents
documented.

Detailed Audit Report
1. Senior management commitment
1.1 Senior management commitment and continual improvement
Company is fully committed to the implementation of the requirements of the Global Standard for Food
Safety and to processes which facilitate continual improvement of food safety and quality management.
Adequate resources and team are provided for maintenance of quality management.
Company has established Quality and Food Safety Policy (P-01 Rev:03, dated 2013/2/2) is documented
Signed by Director Operations Mr.Harjiv Swani.
Food Safety Policy is communicated to the staff by displaying the Food Safety Policy at prominent places
in the production and administrative office entrances.
Company’s management has established 3 Objectives which are documented and communicated during
each management review meetings. These are tracked on monthly / quarterly basis and status recorded
for review. Company has established objectives such as. Minimum of 10 hours of training per employee
on food safety, Reducing customer to 50% from 22 last year. Reduce the product rework to 50% from last
year quantity of 55 tons.
Meetings are conducted each month and Management review meetings once in 6 months. Objectives are
set annually. All review meetings are attended by senior members of the team including Directors. Each
month company undertakes a HACCP review meeting which collates information pertaining to various
related issues being compiled and discussed in management review meetings. This meeting addresses
essential points such as previous MRM, review of policy & objectives, verification, system update,
changes if any, performance review, emergency situation, accidents, third and second party audits,
customer satisfaction, customer feedback complaints, incidents, review of HACCP system, resource
requirements, nonconforming material and review of existing system. Last review meeting in 7 th April
included all requirements & discussions. All details are recorded in the File no TL-F-05 Management
review meeting.
Last meeting was on 7 th April attended by 17 personnel from various departments. Demonstrable
meeting program organised regularly on monthly basis through HACCP Meetings. Last meetings were on
20.2.2018.
Food safety team includes 8 members towards implementation of food safety plan. Mr. Vinayak
Chondekar is the FSTL. Other members are from production, quality, machine room, electrical, sanitation
areas. Ref Doc: HACCP Team composition in page 26 FSMS Manual M01.
Company is approved under factory Act and FSSAI registration. All Spice industry applicable technical &
legal requirements are obtained from these bodies which monitor and ensure compliance. Company has
an original copy of BRC Food standard with them.
Recertification due date is 16 April the audit is conducted before the due date on 9 April.
The Plant Head and GM Operations & Food Safety Team leader attended the meetings.
Root causes of 7 minor non-conformities identified at the previous audit against the Standard have been
effectively addressed to prevent recurrence

F002 English Food 7 Template Issue 9 28/7/2017 Page 17 Report No. 091A1304001 Auditor: Harshad Karulkar
1.2 Organisational structure, responsibilities and management authority
Clear organisational structure and lines of communication are available to enable effective management of
product safety, legality and quality.
The Organisational chart, Responsibility and Authority of Food Safety team members are documented in
Manual. With reporting structure covering all the departments. The Managing partner and Unit manager
are the Top Management. All departments are reporting to Unit manager. The food safety, legality and
quality responsibility allocated to general Manager. Documented Organisational Chart is available in BRC
manual M-01/Annex 5. Checked Job Description for all HODs and all key positions. Their responsibilities
and authorities are defined in M-01/Annexure-05.
Company has established Roles & responsibilities for each role with their intended work profile for the core
team. This is a part of Manual as Annexure 4 and same are communicated to personnel during joining.
Company issues job profiles to all key persons each year. Could review job responsibility of Systems
Manual M-01/Annex04 effective date 1/10/2015. The deputy to this function as identified is QA Manager.
Details of non-applicable clauses with justification
Clause Justification
reference
NONE
2 The Food Safety Plan – HACCP
Documented HACCP study is available. HACCP Team is multidisciplinary that includes 08 members from
those responsible for Quality, Production, Engineering, QC, Store. The HACCP team is trained on HACCP
principles. Team Leader is Mr. Vinayak Chondhekar & Deputy identified is System Manager Kedar
Kavekar. Team has undergone BRC and haccp trainings externally.
All products and processes covered are defined in HACCP plan. Product groups managed by the
company are spices, botanicals and herbs.
The company has identified various pre-requisites. These are identified and established in terms of
various procedures in HACCP manual (documents) such as procedures for pest control, Trainings,
purchasing, Laundry services, allergen control, housekeeping and hygiene, Maintenance etc. Verified PRP
M-02 ver 03 11-2013.
Full description of the products is developed, which includes all relevant information on food safety e.g.
composition, product characteristics, preservation method, Labelling instructions origin, biological &
physical-chemical properties, packaging and delivery methods, storage & distribution requirements, shelf
life, preparation requirements before use, distribution control, labelling requirements and acceptance
criteria. Shelf life of the final product is Min 12 months. Product is stable at ambient temperature &
humidity conditions. Product is packed primary in PP bags then HDPE / Kraft paper bags. Refer to Product
Description Hulled seasame seeds 99.95% purity ver 11 dated 17dec15 Doc no SS-PS-HSS Variety o1.
All Information pertaining to update of hazard analysis is collected, maintained, documented and updated.
HACCP plan is based on the detailed study of following such as Scientific literature, Customer
requirements. Government notifications FSSAI requirements, Codex guidelines.
The intended use of all products is defined and is a part of Product description in the HACCP Manual. All
products are ingrediants to be added in products and to be fully cooked by general public before
consumption. For cooked product it is to be heated and consumed. This is part of each product

description.
Flow diagrams are constructed & they include all the processing steps within the scope. The equipment,
sequence and interaction of all steps in the operation, raw materials, ingredients, utilities in contact ,
intermediate products entering the flow, operating parameters , where reworking and recycling take place,
where end products, intermediate products, by-products and waste are released or removed.
Flow charts are documented (Cleaning: PFC-CD-04, grinding Line-01: PFC-GL-01, grinding Line-02: PFC-
GL-02) PFD for Goods receiving, Fumigation, cutting/grinding, blending, Roasting ,magnet and metal
detection, packing ( bags),inspection and dispatch,
HACCP food safety team has verified the Process flow diagrams onsite on 15.2.2018 by core team
personnel.
The HACCP food safety team has identified and recorded all the potential hazards including physical,
chemical and biological those are reasonably expected to occur at each step-in relation to product,
process and facilities which may not be controlled by existing prerequisites. This includes hazards present
in raw materials, those introduced during the process or surviving the process steps, and allergen risks. It
also takes account of the preceding and following steps in the process chain.
In hazard analysis all possible hazards (physical, chemical, biological/microbial) which need to be
prevented, eliminated or reduced to acceptable levels have been identified .Consideration has been given
to likely occurrence of hazard, severity of the effects on consumer safety, vulnerability of those exposed,
survival and multiplication of micro-organisms of concern, presence or production of toxins, chemicals or
foreign bodies, contamination of raw materials, intermediate/semi-processed product, or finished product.
A detailed step wise risk analysis conducted for each process and product. Necessary information from
competent authority has been collated and guidance taken to develop these controls.
Justification for acceptable levels of hazards is developed from Executive instructions by the competent
authority and US & EU directives as applicable.
For each hazard that requires control, control points are reviewed to identify those that are critical. This is
based on a logical approach and is facilitated by use of a decision tree.
Company has identified 1 CCP: Metal Detection as per identified sensitivities at each process step.
CCP1 at metal detection where all products passing through the cleaning or grinding lines pass through a
metal detector of identified sensitivities.
Critical limits are established based on USFDA and guided by machinery and customer requirements for
the process.
All activities are cleaning and grinding activities of spices and herbs and have one common CCP which is
metal detection at 5 identified locations in Cleaning line, grinding line 1 / 2 / 3, stripping line 1. CCP1 Metal
detection is Metal detector the sensitivity for Grinding line 1 is FE 1.5 mm, Non-Fe 1.8 mm and SS of 2.2
mm whereas in GL2, GL3, Cleaning line is Fe 1.19 mm, NFe 2.0 mm, SS 2.5 mm are identified and
monitored.
Ref Doc: List of identified CCP for each product type as a part of HACCP Manual and individual Haccp
plan forms.
Monitoring system is established for each CCP by direct visual checks on lot sizes by passing all material
through an inline metal detector.

The Food safety team has considered the control measures necessary to prevent, eliminate or reduce the
hazard to acceptable levels. Consideration is given to using more than one control measure. Justification
for acceptable levels in the finished product for each hazard is determined and documented.
Ref. Doc: CCP Plan M-01/Annex03(CD) & (GL1).
In case of deviation being found corrective actions is defined for each CCP. For CCP Metal fragments it is
re-passing and investigating source of metal. Finished goods are re-segregated and repassed through the
metal detector.
The HACCP food safety team has conducted validation for the identified CCP using data as provided by
Metal detection equipment manufacturer and in line with USFDA studies. This was last done by Sesotec
on 1-4-2018 for model no rapid various FS120. The metal detectors are also calibrated last on 8 th Dec
2017.
Appropriate records are maintained and are signed by the monitoring person. The functioning of metal
detector is checked periodically on each line by passing test pieces & recording it on daily production
report Cleaning Line PD-F-01 and GLine-01. F02 ,G line 02 -PD-F-03.
CCP records are verified for each lot & recorded lot wise. Can verify for Lot no SS/930 on the day of the
audit first at 9.15 then at 11.45 am as per frequency.
HACCP Food safety team conducts HACCP review annually or as and when required due to changes in
the processes if any such as changes in raw material, ingredients, process parameters, changes in
scientific development. HACCP review was last conducted on 12.09.2017.
reference
NONE
3. Food safety and quality management system
3.1 Food safety and quality manual

All processes and procedures to meet the requirements of this Standard has been documented to allow
consistent application, facilitate training, and support due diligence in the production of a safe product
Company has established Food safety management Apex Manual M-03 Ver 1 2018
Food Safety Management System Manual M - 01 ver 03 Rev 05 Dated 7.12.2015.
HACCP Study M-01/Annex, PRP M-02 ver 03 1-1-2013 All manuals are authorised and signed by
Managing Director.
A master list is documented and available. This describes the distribution. Refer to Master List of
distribution TL-F-02.
Procedures and work instructions are legible, unambiguous & in regional as well as English language and
sufficiently detailed. Work instructions towards GMP are also displayed at entrances. This includes

pictorial instructions.
3.2 Documentation control
Company has effective document control system to ensure that only the correct versions of documents,
including recording forms, are available and in use.
Company has established Document control procedure TL-S-S-01, Master list of documents (TL-F-02)
and records are available for verification. The method of identification is described as a part of the
procedure. Eg TL-S-01 stands for team leader and S for SOP and 01 is serial number.
Document identification for label control register as per the company’s system was not evident. One minor
NC (1) has been raised against 3.2.1.
3.3 Record completion and maintenance
Site maintains genuine records to demonstrate the effective control of product safety, legality and quality.
The Quality & HACCP Manual are implemented. Distribution of which is part of SOP and Formats for each
department. Housekeeping general cleaning procedure HK-S-01 is the SOP and records are HK-F-01 is
the house keeping checklist cleaning Div basement. Records are maintained for a period of 2 years which
over the shelf life of 1 year.
3.4 Internal audit

Company verifies the effective application of the food safety plan and the implementation of the
requirements of the Global Standard for Food Safety
Company has established an Internal audit schedule TL-F-06 Rev-01 dated 01/7/2017. Internal audit
programme & schedule is evident as per procedure. This audit schedule covers 12 different areas to be
covered in two days of a year.
The program of internal audit is scheduled two times and not throughout the year. One minor NC (2) has
been raised against 3.4.1.
There are 5 internal auditors. Internal auditor training records are available for auditors. Most of the
internal auditors have undergone trainings as a Lead Auditor.
Internal audits are conducted using an Audit observation sheet TL-F-09 is used and guidance is taken
from BRC individual clauses. Both conformity as well as nonconformity are captured. Audit conducted in
July 2017 on Production Department by systems manager has identified 10 minor NCs. These were
closed and recorded on Internal Audit Non-conformances TL-F-09. Similarly audit observations can be
seen on July 2017 towards audit of HR department.
Organisation conducts routine quality inspections to ensure factory environment is clean and maintained
appropriately. This is recorded on PRP audit checklist T-L-F-13. Equipment and production areas are
checked routinely. These are recorded in House Keeping Checklist Cleaning Division, Basement,
Processing area etc. This is done once in a month last done on 20 th March 18.
3.5 Supplier and raw material approval and performance monitoring
3.5.1 Management of suppliers of raw materials and packaging

Company has effective supplier approval and monitoring system is in place to ensure that any potential

risks from raw materials (including packaging) to the safety, authenticity, legality and quality of the final
product are understood and managed.
Company has also established a supplier approval program. All chemicals raw material and ingredients
have undergone hazard analysis and risk assessment before acceptance. This includes packaging
material, allergens, physical & chemical contamination.
Supplier approval procedure in terms of Management of Purchased material PU-S-01 & Approved vendor
list maintained. The risk assessment for raw material group and packaging material is in the form of
hazard and risk analysis.
Company has established a supplier approval system. All products are purchased from suppliers from
various centres handling and supplying spices, herb and botanicals. For initial purchases post commercial
discussion the supplier ‘s material is evaluated and checked for raw material compliance as per
specification. A purchase team comprises of management involvement towards evaluation of supplier.
This is done for 3 consecutive consignments. If material is not complying then it is rejected depending on
degree of noncompliance. If it is accepted on all 3 supplies then the suppliers are made to fill a guarantee
in the form of Supplier approval form. They are also visited by marketing department and premises
audited. Most purchases are from known suppliers having historical.
Company maintains a list of 200 plus suppliers.
All supplies are either from organic certified farms or traders which defined market yards.
All raw materials are spices, botanicals, oilseeds these sourced from farms or traders or markets.
Approved suppliers are agents coordinating directly with the source farms or markets of consolidation from
where raw material is sourced from. Information is maintained through unique sources & channels of
companies having ability to trace material to points of consolidation.
All material is accepted only as per established criteria. There are no exceptions to be followed clause
3.5.1.4 is not applicable.
3.5.2 Raw material and packaging acceptance and monitoring procedures
Controls on the acceptance of raw materials including packaging ensure that these do not compromise the
safety, legality or quality of products.
Company has established Raw material receiving criteria which are monitored for each lot by the Quality
department. This involves visual, physical and organoleptic checks.
Raw material sampling plan QA-SCH-02 is documented for 42 individual products. This comprises of
receiving tests which are visual and lab tests for specific aspects. The procedures are implemented
Records are maintained for compliance against established quality criteria of all material during
acceptance.
Ref Doc : Raw material analysis QA-F-01 & In process – Daily analysis record seed cleaning & Grinding
division.
3.5.3 Management of suppliers of services
All service providers are appropriately assessed and any risks presented to food safety, legality and
quality have been evaluated to ensure effective controls are in place.
Company utilises services of various service providers for specific activities such as ETO treatment
(Mircotol). Pest control by Pest Control M Walshe, Waste management contractor for process waste (Om
Sai) & packing material (Kedar traders) . These services are documented and contract maintained.
Transport for inward is by Suppliers themselves. Refer to Control of outsourced activities and service
providers PU-S-01.
The approval re-approval is based on quality, pricing and accuracy of service.
Service contracts are maintained for activities conducted. Contract made with Pest control operator.
Certificate is provided by Pest Control M Walshe & Microtol towards ETO treatment service provided for
closed product. Contract made with Pest relief India dated 1 April 2018 PRI/FUM/001 for raw material &
container fumigation.

3.5.4 Management of outsourced processing and packing
There is only one outsourced process step which is applicable if a customer requires the same to be
conducted which is ETO treatment of already packed finished product.Company conducts ETO treatment
for packed finished products through a service provider Microtol. All customers are aware of this process
step by provision of stickers on products and certificates of activity undertaken. Company has documented
a Control of outsourced activities and service providers TL-S-09. The service provider gives a certificate
of ETO treatment which is again cross checked by conducting internal microbial record. Certificate of
sterilisation dated 31 July 2017 for 2 types of products undergone ETO treatment being maintained for lOT
NO soss-17/18 231-1. The lot is again tested for microbial counts on 10 th July with no microbial results
#6065.
The service provider is monitored company representatives visit and audit the outsourced services
provider & monitoring records are maintained. A supplier assessment questionnaire is maintained on 12 th
Oct 2016. For activities such as Irradiation, Pest control. Certificate of service obtained from Microtol.
Company evaluates all the products on return and records are maintained by the quality department. The
lot of SS 231-1 of Nigella Seeds was tested for microbial on 10 th July 2017 found to be meeting all
microbial levels.
Contract made with Microtol by site as an service provider was not evident. One minor NC (3) has been
raised against 3.5.4.3.
3.6 Specifications
Company sources spice based products and is approved for handling these products by the competent
authority. In accordance to the requirement company has developed raw material, packaging and finished
product specifications documented.
Company has established Specifications for Raw material and finished goods. These are documented in
the form of Criteria which include raw material acceptance organoleptic and microbial standards. Ref Doc:
Finished Goods Product Specifications for individual product eg For raw material Coriander specifications
are established eg Corriander whole SS-RMS-RW-1, Coriander Seed Splits SS/RM/SAP/221 & For
finished product it is Coriander Powder product code SS-526 & Cinnamon coarse SS-PS-Cinnamon 04.
Manufacturing instructions and process specifications as well as quality criteria are established.
Ref Doc: Standard Operating procedure for individual Process Volume 2.
Specifications are agreed with customers and accordingly distributed to various personnel in the
production and quality control department.
Can evaluate a contract finalised for turmeric powder and hulled sesame seeds with customer PO 993
dated 29 March 18 where in company has accepted customers specification of prodcut. The same
information is available in terms of a sales contract.
Specifications are documented in the HACCP Manual and maintained with department heads or
communicated to customers. They are provided to customers as an agreement being part of an
agreement. Over and above this specification are reviewed for regularly. Curry powder hot was last
reviewed on 16 th Nov 2017.
3.7 Corrective and preventive actions

Company intends to use Information from identified failures in the food safety and Quality management
system to make necessary corrections and prevent recurrence.
Company has documented a Procedure of capturing nonconformities in terms of a Corrective Action
Procedure. They identify major areas in Process based inspections, customer feedback, internal audits
and Hygiene inspections. The observed Nonconformities are identified and actions to be taken are
documented a clear list of Non-conformities is identified with responsibility of various departments.
Corrective Action Procedure TL-S-10 is documented.
It defines the kind of deviations, corrections and corrective actions to be taken in case of deviation. There
has been no such occurrence were safety or legality of product has been compromised.

3.8 Control of non-conforming product
Company ensures that out-of-specification product is effectively managed to prevent release.
All raw materials if not meeting acceptance criteria or all finished products not meeting customer
specifications are defined as Non-confirming products. Company has established a documented
procedure for managing non-conforming products. They have also established quality criteria for finished
goods, identifying material / batch concerned if not meeting the criteria. Holding in isolated area,
responsibility for disposal. Responsibility defined with General Manager Operations and QA Manager.
Company provides COA which ensure that product specifications are met.
Ref Doc: Control on non-confirming product QA-S-07 & refer to Non-confirming product record QAF-08
maintained for Fennel seeds Lot no SS-915-9 on 3-4-2018 for high moisture content.
3.9 Traceability
The site can trace all raw material product lots (including packaging) from its suppliers through all stages
of processing and dispatch to its customers and vice versa. Identification of raw materials and y packaging
is incorporated in terms of system. All raw material is spices herbs and botanicals are allotted a Lot no on
the basis of running serial number. Work in process material is allotted same number along with the truck
number it is received in. Further at the finished product step SAP based final lot number is allotted. The
system is being followed for each batch of material.
Ref. Doc : SOP for Batch identification and traceability QA-S-05.
Company has conducted own testing of traceability on 15 th July 2017 for Lot SS-879 Celery seed whole
powder Lot Qty 25000 kgs this could be traced to 2 raw material Lots such as PO-110163 & PO-110123
received on 17 TH June and 8 th June of 20,000 kgs each. Balance quantity of 15,000 kgs was used
towards production of 2 lots of 14000 kg & 800 kgs with 200 kgs wastage.
During the audit Traceability was tested for Product: Chilli Powder PO 110917 for size 30 mesh received
form truck number a KA-17-C-0531 received on 5 th April and qty was 7790 kgs. This was processes in B
shift on 7 th April till 9 th April A shift total quantity handled & packed 7500 with a loss of 290 kgs.
Also tested traceability for raw material Corriander seed whole Lot PO-110007 qty 13650 kgs received on
4 th September and dispatched on 22 September with final lot ono SS-385-10 by clubbing it in 2 other lots
were mixed & 2 more consignments were exported.
Raw materials are received from farmers, traders and processing factories. Approval of suppliers has
been carried by testing 3 consecutive lots. For main products based on risk company has intiated
traceability checks of 14 suppliers. Eg Sai Agro supplying turmeric company tested the traceability where
in lot no 110796 was checked for its source to place of consolidation as Basmat mandi.
Traceability is maintained for all lots including rework which is regrinding for size, re-cleaning for improved
purity etc.
3.10 Complaint handling

Customer complaints are handled effectively and information used to reduce recurring complaint levels.
Complaints are recorded, investigated and appropriate actions taken. Quality Assurance Manager handles
complaint after receiving from H.O marketing manager. Root cause analysis is conducted and records
maintained. Ref Doc: Procedure for Handling of Customer Complaints QAS -04.
Complaint data is maintained and is analysed appropriately. Data is available with Marketing Head and
General Manager Operations. The analysis is documented and about 15 complaints have been received
in 2017 and this is has reduce to 22 in 2016. Complaints are pertaining to chemical and particle size &
foreign matter which have gone down.
3.11 Management of incidents, product withdrawal and product recall

The organisation has documented procedures to manage possible incidents. The team is located on site
all the time given the activity on site.
Company has documented an Incident Management Procedure designed to facilitate timely actions in
case of incidences and report and manage them. Have identified fire, power shutdown, Accidents, flood,
communication failure , vehicle breakdown. An incident management team is documented which
comprises of 4 persons with responsibility and communication details. Ref Doc: Management of incidents
and Emergency preparedness TL-S-06.
Company does not supply any material directly to customer only withdrawal is applicable. Company has
identified and documented a team comprising of 4 members along with their contact details,
responsibilities of actions to be taken during a situation needing withdrawal as identified. If there is any
food safety issue then recall or withdrawn can be initiated. Contact details and communication plan is for
each is available. 4 major areas for contacting customer, legal, internal traceability and overall approval to
initiate are identified. Ref Doc: Product withdrawal and Recall procedure QA-S-08.
Product mock recall is tested by the company once in a year which includes activities and timing of results.
Initiated on 19.12.2017 for Fenugreek Powder Lot No SS-267, Reply was received on next day from
Client. Details of results of test have been recorded & location and status of lots can be reconfirmed.
There has been no recall for the sites products. Clause 3.11.4 is not applicable.
3.12 Customer focus and communication
There are no customer specific policies applicable on site clause 3.12. is not applicable.
reference
All material is accepted only as per established criteria specified in the Specification file.
3.5.1.4
There are no exceptions clause 3.5.1.4 is not applicable.
3.11.4 There has been no recall for the unit clause 3.11.4 is not applicable.
3.12 There are no customer specific policies applicable on site clause 3.12. is not applicable.
4. Site standards
4.1 External standards

The site is of suitable size, location and construction, and maintained to reduce the risk of contamination
and facilitate the production of safe and legal finished products. Site is located in TTC Industrial area with
a well-defined boundary and free from any possible contamination. Site boundaries are clearly defined
boundary wall. External areas and grounds are concretised and maintained in good order.
Building fabric is of permanent nature and mostly does not allow any pest entry.
4.2 Security
Site has walled premises with entry and exit monitored through an appointed security agency. All external
persons are supervised through company personnel presence.

Company continues to control entry in the premises and has appointed a security agency NSF Security
services to control access in the premises .
Raw material and product Hazard Analysis is conducted to incorporate possible routes of contamination
during handling. Workers Movement & product flow map is established. Access to personnel is restricted
and controlled.
The security risk assessment is documented in the form of common risk assessment which also covers
security as a topic M-01/Annex 02.
All personnel have to pass through the gate and a visitor’s gate pass system is followed.
Company uses underground storage for untreated water and after treatment water is pumped to the top
floor for storage for distribution. All water opening points are locked. Process does not require use of
water.
Factory site is registered by competent government authorities such as Maharashtra Pollution Control
Board, FSSAI & Factory license no 10013022001931 valid till 22 nd May 2018 for the identified premises.
Facility is also registered with the Spice Board and hold a certificate as an exporter cert no
ML/REG/S976/2017 valid till 31.8.2020.
Maharashtra Pollution Control Board consent MPCB/SRONM-11/CONSENT/1609000196 valid till 31 st
march 2019.
4.3 Layout, product flow and segregation

The factory layout and movement of personnel is designed to allow logical flow of material. These are
complying relevant legislation by undergoing audits by competent authority and are provided an approval
for export.
Plan of site has been established and areas demarcated for handling of raw material, pre-processing,
processing, grinding Only Low risk area is identified. Ref Doc: Plant Lay out M-02 / Annexure 03.
Site plan and movement system provide designated access routes for personnel in individual sections
(Cleaning & Grinding) facility with wash rooms, hand wash stations, raw material cleaning area and
packing area. Product flow is unidirectional and equipment controlled. personnel movement is designed
for individual sections.
Ref Doc: Plant Lay out M-02 / Annexure 03.
All external visitors are made to follow company code of conduct and supervised throughout their
movement in the facility. Facility employs staff who is allotted specific and defined work. Workers are
supervised and trained in specific work instructions and potential product contamination before
commencing work. Maintenance activity is supervised. Ref Doc: Visitors Declaration TLF-10.
Movement of personnel, raw materials, packaging and waste does not compromise the safety of products.
Effective procedures are in place to minimise the risk of the contamination of raw materials,
intermediate/semi-processed products, packaging and finished products in Low risk areas.
There is no high risk area only low risk area is identified.
There is no High care area applicable on the manufacturing site. Clause 4.3.6 is not applicable.
There is no ambient high care area on the site, clause 4.3.7 is not applicable.
Premises of the area are large and sufficient working place is available taking in to consideration the
volume of the activity possible on site.
There are no temporary structures which as a part of design may allow pest harbourage. Clause 4.3.9. is
not applicable.
4.4 Building fabric, raw material handling, preparation, processing, packing and storage areas
Permanent facility with panel and frame construction has been provided designed to avoid any possible
external influence. Mostly Walls are finished and maintained to prevent accumulation of dirt or
contamination. Floors are tiles and hard to stand the demand of the process and impervious in nature. Use
of water in the process is very minimal to no use. Drainage where needed for floor wash water are
adequately sited, designed and maintained to minimise risk of product contamination and not compromise
product safety. Machinery and piping are arranged in such a way that process waste water goes directly to
drain. Only low risk areas are applicable in all premises. Ceilings and overheads are constructed, finished

and maintained to prevent the risk of product contamination. All suspended ceilings in anteroom area are
adequately controlled. Windows are sealed and exhaust fans screened.
All glass windows are filmed. Doors are maintained in good condition. All opening and chutes are kept
closed at all times to prevent entry of pest. Sufficient lighting is provided for facilitating correct operation
and other processes such of sanitation, maintenance, inspection etc. All tube lights are protected.
Exhaust fans are provided for air ventilation. Based on risk analysis only low risk areas are applicable in
the site.
4.5 Utilities – water, ice, air and other gases

Facility does not use water in any process. Air is used for movement of product in the Buhler lines used for
cleaning and grinding lines.
There is not direct use of water in processing or product contact. Sufficient quantities of water are
available and provided for hand washing. Water is analysed externally once in 12 months and once in a
year and internally once in 15 days. Water analysis report MISC-17-10-016327 dated 30.10.17 by
Geochem Laboratories for IS 10500 Standard is maintained. Internal microbiological testing is also
conducted once in a month recorded on Water Analysis record QA-MIC-F-05 last done on 15 th March 18
for coliforms. For use of water in the hand wash areas and indirect cooling of roasting lines a water
distribution plan MNT-F-37.
There is no use of non-potable water on site. Clause 4.5.3 is not applicable.
Air pressure is used for moving material which is in powdered form this is monitored. Air quality is checked
for microbial levels internally once in a quarter last done on 23 Jan 18 for 4 locations such as Vibroshifter
1 / 3 / Bin 2 and Shifter 2 for TPC, Yeast and moulds. Tis is recorded on Air sampling records QA-MIC-F-
08.
4.6 Equipment
All food contact equipment is either SS 304 or packing material such as PE lined paper or PP woven bags.
Contact material are cleaned and maintained adequately. Materials suitable for handling spice products
are provided in accordance to industry acceptance.
All equipment is made from SS and utensils are made of plastic designed and placed suitably.
Production facility equipment involves use of cleaning equipment and grinding equipment. These are
designed appropriately for spice handling by equipment manufacturer BUHLER. This involves use a
combination of SS and MS. Company conducts swab analysis for judging adequacy of the equipment at
all times. Ref Doc: Equipment swabs conducted recorded in Swab Analysis Record QA-MIC-F-07
maintained on 25 th Jan for 6 equipment & 2 hand surfaces.
4.7 Maintenance
Company has a maintenance team of 11 persons with a responsibility of keeping all important machinery
and equipment maintained. Company has documented a Preventive maintenance schedule, maintenance
system, equipment list. Daily & Monthly maintenance is conducted. Equipment are segregated as per
individual divisions. Cleaning division involves 20 major equipment, Grinding GL1 has 6, Strip Mill 6, GL2
has 6 and GL3 has 8 equipment, strip has 4 and Roasting has 4 there are 5 other utility devices which are
identified for maintenance.
Ref Doc: Preventive maintenance schedule (Monthly & Daily) cleaning division / Grinding Division MNT-
SCH-02. In addition to planned maintenance all equipment are attended whenever need arises. A
maintenance complaint register MNT-R-01 is maintained.
Hygiene clearance for maintenance activity conducted for Destoner screen on 28 th March & 30 th August
for sieve was not recorded in the breakdown record. One minor NC (4) has been raised against 4.7.2.

There were no temporary repairs found on site. All equipment related activity was appropriately
maintained. All breakdown is also attended do and recorded in Maintenance complaint register. Hygiene
clearance acceptance is recorded each time as taken from Production manager Destoner screen was
faulty on 28 th March, 30 th August sieve broken on shifter. Micronizer on GL1 was broken on 24 th march
and hygiene clearance taken.
Only low risk areas are applicable on site. There is no product contact directly with the product in any
machinery by the lubricating oil or grease. Clause 4.7.6 is not applicable.
Engineering work shops are not connected to production areas.
4.8 Staff facilities
Staff facilities comprise of staff changing and hand cleaning points provided before entry to each of the
section of cleaning section and grinding lines. Designated changing facilities are Provided before entry to
the cleaning, grinding sections with foot cover stations, lockers and Hand disinfection areas.
Storage facility is sufficient to accommodate all personal items of personnel working in respective areas.
Storage facility is of 2 types comprising of personnel items and used clothing racks.
Separate cabinets for personnel items and used clothes are provided in each entry to production area.
Only low risk area is identified and applicable for the unit. Clause 4.8.4 is not applicable.
High care area is not applicable. Clause 4.8.5. is not applicable.
Hand washing facilities are provided at entry point to production. Water at ambient temperature Is
provided; liquid soap and hand dryers are provided with advisory signs to undertaken necessary action.
Toilets are segregated and do not open directly in to the production or storage area with basins, soaps
and hand wash facility is provided. Most of them are part of changing area.
Smoking is not allowed in the campus. Clause 4.8.8 is not applicable. Company has provided designated
area in the premises for consumption of food. There is no catering and cooking on site. Clause 4.18.10 is
not applicable.
4.9 Chemical and physical product contamination control
Raw material handling, preparation, processing, packing and storage areas
Separate Storage areas are provided for managing and handling chemicals which are required to be used
on site. All raw material and ingredients have undergone hazard analysis and risk assessment before
acceptance for possible physical microbial & chemical contamination.
4.9.1 Chemical control
Storage areas are provided for managing and handling of dry and wet chemicals which are required to be
part of the processing ingredients.
All raw material and ingredients have undergone hazard analysis and risk assessment before acceptance.
Manufacturing activity does not involve addition of any chemicals, preservatives and ingredients. Raw
material is spices which undergo cleaning and grinding, roasting as applicable. Equipment or product
contact surfaces are cleaned by using dusting or air and no chemicals are added in the process at any

point except fumigation of raw material.
There is no use of strongly scented chemicals which may affect the product integrity.
Clause 4.9.1.2 is not applicable.
4.9.2 Metal control

All raw material have undergone hazard analysis and risk assessment before acceptance. Company has
established Sharp Metal Policy. Metal removal is CCP. Knives are used for opening raw material bags and
are adequately controlled. Needles are used for stitching bags and usage is monitored. Ref Doc: Needle,
Knife and scoop inventory including loose nuts and bolts are monitored and are a part of the Production
Report PDF-02 , Knives issuance is recorded as a part of Production Report Grinding Division PDF-04.
Each day one piece is issued and returned back. All packaging material being used such as bags are
staple free and only glued cartons are use. Office area is segregated from production area.
4.9.3 Glass, brittle plastic, ceramics and similar materials

Process does not use glass for packaging or in equipment’s or product contact. All the glasses on
windows, lightings etc are protected against breakage with proper lining and covering. Most glass is
windows and tube lights which is protected and monitored. A glass policy has been established to declare
the company’s policy on the use of glass and brittle policy.
Glass, wood & brittle plastic Policy P-02 is documented in the Food Safety Management System Manual.
A glass breakage procedure HK-S-07 is documented which details actions and provides instructions such
as quarantining product, cleaning, inspection , responsibility and disposal of affected material.
Ref Doc: Glass Identification Record MNT-F-04. Last checks on 17 th March 2018 identified 146 locations.
4.9.4 Products packed into glass or other brittle containers

There are no products packed in glass or brittle containers. Clause 4.9.4 is not applicable.
4.9.5 Wood
There are no products packed in glass or brittle containers. Clause 4.9.4 is not applicable.
4.10 Foreign-body detection and removal equipment
4.10.1 Foreign-body detection and removal equipment

The working ambience, surroundings, tables and equipment where material is exposed is so designed so
that possible contamination will be reduced or avoided.
All raw material and ingredients have undergone hazard analysis and risk assessment before acceptance
for physical, microbial & chemical contamination. Metal detection is an identified CCP for each batch of
products. CCP plan as a part of the CCP & OPRP Plan part of HACCP Study M-01/Annex.
Location of the metal detectors is in 5 locations. In 3 Grinding lines viz GL1,GL2 & GL3 & 1 in Cleaning
line & 1 in strip mill. In the GL1 line the sensitivity of the metal detector is Fe 1.50 mm NFe 1.80 mm SS
2.20 mm. In all other locations the sensitivities of these metal detectors are of Fe 1.19 mm, NFe 2.00 mm
SS 2.50 mm. All locations are immediately before packing of each bag.
All material is passed inline through the metal detector. If there has been detection of metal or rejection of
pouches the same is recorded and investigated. Actions to be taken are recorded. Trends of CCP
monitoring results are discussed in each management review meeting.

4.10.2 Filters and sieves
Sieves are used in the process line with sizes as per individual product and customer requirements.
Company maintains a stock of 20 meshes for individual sizes of 20 / 25 / 30 / 40 and 8.
Records of checks are maintained. Ref Doc: Production Report Grinding Division GL01. Installation of
respective sieves is a part of record keeping in the production report. Eg 20 # Mesh size on sifter no 1 in
grinding line 2 was inspected for damage on 26 th March at 7.10 am and then at 10.00 am pm for Dhania
Roast powder packed.
4.10.3 Metal detectors and X-ray equipment

The working ambience, surroundings, tables and equipment where material is exposed is so designed so
that possible contamination will be reduced or avoided.
All raw material and ingredients have undergone hazard analysis and risk assessment before acceptance
for physical, microbial & chemical contamination. Metal detection is an identified CCP for each batch of
products. CCP plan as a part of the CCP & OPRP Plan part of HACCP Study M-01/Annex.
Location of the metal detectors is in 5 locations. In 3 Grinding lines viz GL1,GL2 & GL3 & 1 in Cleaning
line & 1 in strip mill. In the GL1 line the sensitivity of the metal detector is Fe 1.50 mm NFe 1.80 mm SS
2.20 mm. In all other locations the sensitivities of these metal detectors are of Fe 1.19 mm, NFe 2.00 mm
SS 2.50 mm. All locations are immediately before packing of each bag. All material is passed inline
through the metal detector.
If there has been detection of metal or rejection of pouches the same is recorded and investigated. Actions
to be taken are recorded. Trends of CCP monitoring results are discussed in each management review
meeting.
4.10.4 Magnets
Magnets are used in many locations. Cleaning line uses 3 magnets , GL1 has 3 magnets , GL2 has 5 and
GL3 has 5 magnets , 2 magnets in Kibbling section in identified Locations .
Ref Doc : Process Flow chart for cleaning and Grinding lines. 03 Magnets in Cleaning section. Company
has its own guaze meter and conducts checks quarterly checks for all magnets.
There are totally 18 magnet locations which are checked for strengths using a calibrated gauss meter. Eg
Gauss meter D20B was calibrated on 26 Feb 2018 and used to calibrate all the 18 locations recorded on
magnet strength record eg Magnet on GL-3 Bin no 02 had an average strength 4272.
4.10.5 Optical sorting equipment

Company uses SORTEX machine Z series for removing non-material particulate matter. This is inline in
the cleaning division. Operating instructions are documented. Company passes all material through the
machine and this is verified by the Quality department before final acceptance. Ref Doc : SOP for working
of Sortex machine PD-F-03.
4.10.6 Container cleanliness – glass jars, cans and other rigid containers
There is no use of container cleaning equipment clause 4.10.6 is not applicable.
4.11 Housekeeping and hygiene

Facility handles perishable fish and fishery products. All areas are required to be cleaned using running
water followed by chlorine wash. Company ensure cleaning of various areas is effectively managed
through a team of 20 persons. Premises and equipment’s are maintained in clean and hygienic condition.
Company has documented a general cleaning procedure HK-S-01 & a specific cleaning procedure
developed for individual equipment. General cleaning is for all premises except equipment. For equipment
company has identified a procedure for Changeover in cleaning and grinding divisions for all the lines.
This is combination of effective cleaning and changeover. This removes traces of material in the lines.
This is undertaken in between 2 products so that all areas specific to production are addressed and there
is not cross contamination to the next product. Detailed instructions towards actions to be taken in
sequence for each sub section n of equipment are defined. Eg A documented cleaning schedule HK-

SCH-02 describes the actions to be taken such as applicable areas (24) frequency identified, cleaning
methods, cleaning agents, concentrations, responsible persons. Eg Window glass is cleaned on weekly
basis by both dry and wet mopping, using colin, responsible person is hygiene officer.
SOP for changeover of the product cleaning division PD-S-02 describes equipment based actions. For
each line harbourage points are identified based on risk. In Cleaning div 10 points are identified such
Indent cylinder & Elevators.
For all general surfaces cleaning the limits of acceptability is by visual checks. Company has defined
specifications for Limits of acceptance of cleaning are part of the swab analysis procedure QA-MIC-SOP-
02. There are limits defined for surface swabs, machine swabs, hand swabs, and linen in terms of
cfu/plate. For machine swabs alert limits are 10 fcu and action limits are 25 cfu. A swab analysis record
QA-MIC-F-07. The records demonstrate compliance through visual checks and microbial swab analysis
such as bagging points and LAF Hood as seen on 25 th Jan 2018 with zero CFU readings.
Various points within the equipment have been identified which are checked for effective cleaning during a
change over. These points are checked for cleaning during change over.
Cleanliness of equipment or surfaces is checked for cleaning efficiency visually most raw material is in dry
powder form having moisture ranging around 8 to 12 %. Surfaces are checked for cleaning efficiency
visually and microbial analysis is also conducted for product contact surfaces.
Company has identified line checks for each line which ensure that change over process is successful and
new product can be started. Eg House Keeping Checklist Cleaning Div HK-F-01 covering 13 areas,
checked by hygiene officer and verified by QA division.
Microbiological checks as recorded to capture cleaning performance do not reflect trends in the specific
harbourage points as identified. One minor NC (5) has been raised against 4.11.5.
Cleaning equipment for tables & contact surfaces such as brushes are used. For floor cleaning mops and
wipers are used. Equipment is stored separately in an identified extension.
4.11.7 Cleaning in place (CIP)
There is no requirement of CIP in place. Clause 4.11.7 is not applicable.
4.12 Waste / waste disposal
All waste generated is raw material dry spice products, paper & plastic based packaging material.
Company discharges dry waste in solid form which are by product from cleaning of spices, oilseeds etc.
The solid waste is disposed through a vendor Om Sainath warehouse. This company is dealer and agent
in all kinds of grains & cattle feed and plastic waste. All packaging material waste is disposed through this
vendor.
External waste collection containers and rooms housing waste facilities has been managed to minimise
risk. There is no transfer to third party for destruction of waste clause 4.12.3 is not applicable.
4.13 Management of surplus food and products for animal feed
There are no surplus products manufactured which could be sold as animal feed. Clause 4.13 is not
applicable.

4.14 Pest Control
Company has provided enclosed areas with control on entry exit points, control on site through a pest
control expert and pest catching devices. There is no major pest infestation activity noticed on site and
facility is adequately proofed and controlled to prevent an occurrence.
Company has established a pest control contract with PCMW.
Ref Doc: Contract no 18/April/MT/39 made on 05.4.2018 valid till 1 year Services undertaken are for
Fogging, General infestation & rodent control. for a period of 1 year. Services undertaken for Fogging &
General insect control and Rodent control undertaken once in 15 days, Electric Fly catchers are also
provided for fly control. The pest control agency as well as pest catching devices using electric flycatchers
and glue pads. In addition, company conducts fumigation of material lots which is lot specific activity and
not connected directly with pest control and conducted by a different service agency specialised in
undertaking it. As per industrial application there are few chemicals used for fumigation & application
inside the factory on lots of raw material.
Company staff only monitors the catches in Rodent boxes and electric fly catchers’ guidance is taken from
service provider to cover their absence. Clause 4.14.3 is not applicable.
Company maintains a map identifying 109 rodent bait stations and 26 fly catcher locations. All traps are
numbered and identified. Glue traps for rodent and electric fly killers for flying insects are being used.
Responsibility of monitoring of rodent bait stations is with the contractor and for Electric fly catchers is with
company personnel. However, there is no use of chemicals or pest control products inside the facility only
trap monitoring is practiced. Spraying is undertaken in the external areas of the buildings. This is strictly
monitored.
Bait stations are robust and secured & placed externally. No toxic compounds are used in the bait boxes
only glue pads are used. Fly-killing devices are correctly sited and operational inside the factory.
There has been no incidence of infestation found so far which needs immediate attention for additional
actions taken.Records for pest control inspections are maintained and actions as required are carried out
if recommended.
The service provider maintains a General pest control record for each section HK-F-14 for cleaning
division where specific areas are covered eg 4 areas non-production are sprayed. Rodent monitoring
records are maintained HK-F-12 where each rodent box is checked once in a day.
In cleaning division 4 main operational areas have undergone spraying and fogging. All bait stations are
monitored regularly and recorded fortnightly for all the 116 bait boxes. Details of chemicals used is
recorded on the General Pest control Record during each visit eg Chlorypyhus 180 ml used for crawling
insect activity.
Service provider gives a monthly report where in remarks and observations are provided by them to the
company. One in a year the service provider gives a survey with observations and suggests actions and
closure points.
Last such activity was on 13 th July 2017.
Results of pest control inspections are maintained for insect catches as well as rodent bait stations for
each month. Pest control operator provides a trend of observations and results for each month for rodent,
spider, lizard and crawling insect observations and this is used to plan improvements. Trend of pests
trapped in monitoring devices are maintained from 2013 to 2018 indication overall reduction. A pest o
flash records HK-F-15 captures insect catches in terms of grams of catches which is minimal.
Employees understand signs of infestation.
4.15 Storage facilities

Storage of ingredients, in-process product and finished products facilities are suitable for its purpose.
Company Stores all material in dry condition. Each section Is provided with finished goods store. There is

no temperature requirement during storage.
Packaging materials are always stored away from other raw materials and finished products in a dedicated
packaging material store placed on the first floor. Part used and obsolete packaging not found or left
onsite.
There is no requirement for temperature control, all material is stored in ambient temperature. Clause
4.15.3 is not applicable.
There is no requirement to use controlled atmosphere storage clause 4.15.4 is not applicable.
There is no external storage clause 4.15.5 is not applicable.
Correct stock rotation of raw materials, intermediate products and finished products in storage maintained.
Materials are used in the correct order in relation to their manufacturing date and within the prescribed
shelf life. There is limited storage of inputs like packing material. Products are manufactured and marketed
against Purchase orders .All products are labelled and indicate manufacturing date.
4.16 Dispatch and transport
Procedures to manage transport are in place so that dispatch of the vehicles and containers used for
transporting products from the site do not present a risk to the safety, security or quality of the products.
All raw material are received only in supplier’s covered vehicles. Condition and all finished goods are
dispatched in ambient temperature containers. Vehicle cleanliness and status is recorded prior to
unloading
Ref Doc : Raw material Analysis Report QA-ANA-F01 Celery seed lot PO no 110904 recorded on 17 th
March 2018 from Sethi sons covers vehicle truck details PB46-M-9837 in 400 bags and status of cargo
such a lot covered , Infestation , spillage , infestation , integrity checks .
All material being received and dispatched/ exported are recorded in a Inward Challan and Outward
Challan respectively which captures condition during transport, details of shipment, Packing list, Bill of
Lading and invoice for each shipment with set of documents is maintained. Dispatch details are captured
in terms of value and volume data as well as a Container Stuffing Report 6948 for Cumin seeds as can be
seen in case of CAIU 971090-O to destination KOBE covering condition-based check points. This was
loaded on 17 th Feb 2018.
All material is shipped in ambient temperature container. Clause 4.16.3 is not applicable.
Company receives raw material from suppliers vehicles loads material in transporters vehicle or shipping
line containers. All are subjected to checks of cleanliness.
Company has documented procedures for the transport of products containers for dispatch are dedicated
loads of containers. Dispatch of finished goods WH-S-06.
Transport of containers is through shipping lines, Port handling agent arranges to transfer the container
through own trailer to the port.
reference
4.3.5 High risk Area is not applicable only Low risk area is applicable.
4.3.6 High care Area is not applicable only Low & High risk area is applicable.
4.3.7 Ambient care Area is not applicable only Low risk area is applicable.

4.3.9 There are no temporary structures which as a part of design may allow pest
harbourage.
4.4.4 Only low risk area is applicable on site.
4.4.13 Based on risk analysis only low risk areas are applicable in the site.
4.5.3 All Water used in the facility is potable there is no use of non-potable water.
4.7.5
Only low risk areas are applicable on site.
4.7.6 There is no product contact directly with the product in any machinery by the lubricating
oil or grease. Clause 4.7.6 is not applicable.
4.8.4 Only low risk area is identified and applicable for the unit. Clause 4.8.4 is not
applicable.
4.8.5 High care area is not applicable on site.
4.8.8 Smoking is not allowed in the campus.
4.8.10 There is no catering and cooking on site. Clause 4.18.10 is not applicable.
4.9.1.2 There are no strongly scented or taint-forming materials used in production areas.
4.9.4 There are no products packed in glass or brittle containers.
4.10.6 There is no use of container cleaning equipment.
4.11.7 There is no requirement of CIP in place. Clause 4.11.7 is not applicable.
4.12.3 There is no transfer to third party for destruction of waste.
4.13 There are no surplus products manufactured which could be sold as animal feed.
4.14.3 Company staff only monitors the catches and does not undertake own pest control
activities clause 4.14.3 is not applicable.
4.15.4 There is no requirement to use controlled atmosphere storage clause 4.15.4 is not
applicable.

4.15.5 There is no external storage clause 4.15.5 is not applicable.
5. Product control
5.1 Product design/development

Product design and development procedures are in place & established considering guidance from
competent authority and customer requirements. Company has established SOP for Handling and
production of individual products and conducted hazard analysis to consider introduction of hazards if any
within the scope of products. Present products are Spices, Herbs, and Botanicals. New products are
blends of existing products. A procedure is developed as in Design and Development Procedure R&D-S-
01 rev on 13-8-2017 provides guidance to necessary actions when any blends need to be produced.
Company regularly conducts R&D work towards manufacture of blends of existing ground spices and this
undergoes a customer acceptance for organoleptic, physical and chemical parameters. In 2017 company
has developed 4 to 5 blends. Company has recently developed new product Curry Powder comprising of
7 individual spice-based ingredients. All recipes for blended spices are as per customer requirements.
All new products are variants of existing products and are manufactured using identical methods of
processing (cleaning & grinding & blending) without any changes to monitoring systems and parameters.
They undergo hazard analysis and approval by the HACCP team. In December Haccp team leader has
approved new product developed as per buyer’s sample eg Curry Powder developed for particular
customer from Turkey was approved by customer for recipe on 16 th Jan and reanalysed by HACCP team
and authorised on 18 th Jan by 4 key members.
Methods of processing and monitoring remain the same and do not need any additional trials or validation
to maintain the safety of the products beyond routine review of processes.
All products have a shelf life of 1 year at ambient temperature. Shelf life trials are initiated and records are
maintained. Shelf life is established based on trials, tests, industry norms and codes of practices for food
safety. Shelf life study has been initiated for Fennel Powder produced on 4 th March 2017 and study
completed on 8 th April 2018 which is the most recent study. Previously chilli powder lot no SS-230
produced on 13 th Sept 2016 was analysed and completed on 1 st Oct 2017. Checks involved parameters
such as moisture, microbiology such as TPC & Yeast mould limits. Which were compliant.
5.2 Product labelling
Product labelling is conducted as per customer requirements considering destination regulations for
products meant to be exported.
All products handled are bulk bags of not less than 20 kgs. All material is meant for reuse in processing by
the customer. Products are labelled to meet legal requirements for the designated country of use and
include information to allow the safe handling, storage, preparation and use of the product within the food
supply chain or as needed by the customer. As required by customer the label may include details of the
company or may mention only a lot number. Can verify label of Fenugreek seed whole of packing 25 kgs
production date 2.4.2018 best before 1.4.2019, Lot no SOSS 17-18/745-1 Indent no 112270 having sticker
with company name Swani Spice. Whereas also could see another label with only product name (Garlic
powder), Net wt 25 kg, prod date 6.4.2018, expiry 5.4.2019 batch no SOSS 17-18/948 & importers brand
on label. Traffic (Export) department maintains approvals as received from customer.

Since all material is bulk bags meant to be identified and used by importer the information on the bags is
pertaining to basic identification of content. The customer who imports the material provides label proofs in
line with local country requirements. The label proofs as well as customer proofs are maintained and
available with Export department maintained in the label proof file.
Products are bulk commodities and are not ready to eat products and do not make any specific claims for
a particular group of consumers. Clause 5.2.3 is not applicable.
All label formats if used are directly received from the customers there is no nomination of external printer
or party. Clause 5.2.4 is not applicable.
5.3 Management of allergens

System is in place for the management of allergenic materials which minimises the risk of allergen
contamination of products and meets legal requirements. Company handles 4 Allergens, Sesame, Celery,
Mustard & Bleached ginger which could be treated with sulphites for bleaching. An SOP for Management
of Allergens has been developed. Most products are either sold as individual or as a ingredient in a
blended product. Ref. Doc: Allergen Handling Procedure QA-S-9.
Company has identified & listed the Allergens such Sesame, Celery, Mustard & ginger for sulphite content.
Ref Doc: Allergen handling procedure QA-S-9.
All material being handled is in solid state powders. A change over procedure to handle production after
running allergen containing raw material is elaborated. Company is selling only bulk packaged product
such as 25 kg to 700 kg all customers. Company is declaring to all clients through own specifications that
company product is manufactured in a facility which handles allergens such as above.
After each run of product either allergen based or non allergen based a product changeover system is
followed. This is towards cleaning and removal of traces of earlier or already run product.
Company has conducted risk-based assessment of natural contamination as part of raw material having
traces of other allergens. In the last 1-year company has conducted reasonable amount of tests (41) to
verify raw material based allergen contamination and results are satisfactory for most material. The testing
is validated using ELISA test. This also done in finished goods almost 94 samples where in information is
collated.
Allergen Risk Assessment M-01/Annex/02(RAL) Ver 2-12-18 part of Food Safety Management System
Manual. Procedures have been established to manage allergens by identification, time segregation during
manufacture, change over procedure, restrictions on food brought onto site by visitors or contractors. The
types of allergens that are processed are sesame, sulphite containing ginger, mustard & celery. All these
allergens are received in whole form and except Sesame all the 3 are converted in to powder after
undergoing only cleaning or other operations. Mustard undergoes grinding in blends, celery is cleaned and
ground. After processing of these products semen cassia or grinding quality fenugreek seeds which are
relatively heavy material is cleaned or ground to reduce or remove traces of pre-existing allergens. This
material is only an non allergenic buffer not meant to be used or sold further only discarded. This is
acceptable by industrial standards. Ref. Doc: Allergen Handling Procedure QA-S-09.
Documented procedure is established and implemented for rework which is refining of cleaning etc.
Currently the product is packed as bulk form and sold to re-processers and does not need any warning
label. This is purely based on customer requirements. Customer is aware that material is produced is a
spice handling facility. All products are labelled for declaration of contents or allergens there is no
requirement to include a warning label. Developed by the customer and to be used by the customer.
Clause 5.3.6 is not applicable.
There is no special claim made regarding suitability of food or allergy clause 5.3.7 is not applicable.
Cleaning procedures are designed to remove or reduce contamination by allergens. After processing of
these products semen cassia or grinding quality fenugreek seeds which are relatively heavy material is
cleaned or ground to reduce or remove traces of pre-existing allergens. The process is validated and
tested using ELISA kit. On 5 th Feb 18 traces of yellow Mustard were checked in turmeric powder and the
results we done for 1 product and 3 surface samples having no traces. Similarly, this was done for sesame

seed and black mustard and results were satisfactory.
5.4 Product authenticity, claims and chain of custody

All raw materials are purchased from suppliers with whom Guarantee of supply has been established and
are also approved by competent authority as and where applicable.
Information on historical and developing threats to the supply chain which may present a risk of
adulteration or substitution of raw materials this comes from various routes such as government regulatory
body, Spices Board and other agencies such as All India Spice Exporters Forum.
Company has documented as vulnerability substitution of fraud risk assessment for source of raw
materials (M-01/Annex02) which considers possibility, likelihood and severity of vulnerability. This is kept
open for review and more raw materials as incorporated have been added in as on purchased. This was
reviewed on 7 Nov 2017 where in few raw material groups was added in.
The most recent Vulnerability risk assessment review was not completed to reflect product groups being
sourced for possible risk of adulteration and substitution such as imported coriander. One minor NC (6)
has been raised against 5.4.2.
All raw materials are agricultural produce such as spices, oil seeds and herbs which are sourced mostly in
whole form and undergo processing activity in company premises. Raw materials are analysed for
chemicals for conformity. The company’s major volume is turmeric chilli coriander cumin which is almost
60 % of volume. The other list covers almost a dozen products. The company’s vulnerability risk
assessment has identified certain spices at a risk of adulteration in the powder form. Therefore, as a
company rule all raw material are purchased in whole round natural. Company is kept informed of
developing threats of adulteration through routes of legal competent authorities.
Company also manufactures Organic Spices. The raw material is procured from a certified source and
accordingly declared.
Purchase of Organic raw material is from a single Organic material supplier which is a sister concern
based in Jalor in Rajasthan. The material is not stored on site and procured only when an order is to be
processed. Raw Material undergoes production operations and is dispatched against an identified order.
Facility maintains purchase records and process traceability of all such lots handled. This constitutes 20 %
of all material which is handled. Company has almost 10 suppliers who are certified Organic and who are
managed through a team sourcing and managing these supplies.
Company maintains sources of such supplies. For each lot sourced the material is tested for pesticide
residue over and above farm certification status. Lot no LRM/SSM/12 is clove which is tested for pesticide
residues on 27 th Jan 2018 for 127 pesticide residues. Similarly Cumin lot
SSM/JALO/ORG/CU/US/30/2017 also tested for pesticide residue. This is done for all Organic lots being
sourced.
All the farmers from whom the declared Organic material is procured their certicates are maintained. Eg
Nutmeg sourced from LRM Spices pvt ltd having cert no NPOP/ORG/SC/1511/2891 &
NOP/ORG/SC/1511/2892. And Clove sourced from Apees Organics having cert no
NPOP/ORG/SC/11707/001517.
All material deemed organic is procured only against an order and no extra material is kept on site. All lots
are handled separately at one time on one equipment to avoid possible mix up with Non-Organic material.
5.5 Product packaging
Appropriate product packaging for the intended use and are stored under conditions to prevent
contamination and minimise deterioration.
Material which is packed is spice ingredient with moistures and oil content less than 10 %. Company is
using LDPE bags and paper bags laminated and plain. All packaging material Is procured against
certificate of conformity of physical properties. Specifications are provided to the suppliers along with
purchase order.

The packaging materials are procured against their suitability for use in food as a part of declaration. List
of approved packaging material suppliers containing 9 approved vendors is available for all. Currently they
are procuring material from Krishna packers material such as primary contact liners & paper-based bags.
These are being tested by company against overall migration test against IS 9845:1998 cert IFS-
180331017 for HDPE bags, Cert no IFS-180331017 for multiwall paper bag dated 5.4.2018, LDPE liners
IFS-180331015. Contact liners are appropriate and identified by specific size and colour to prevent
accidental contamination. All plastic liners are made of PE material and declared by supplier for
compatibility with material being handled.
5.6 Product inspection and laboratory testing

5.6.1 Product inspection and testing
Microbial and organoleptic Inspection and analyses are carried out which are critical to confirm product
safety, legality and quality, using appropriate procedures, facilities and standards.
Company has established a lab undertaking organoleptic, physical and microbiological tests. This is
undertaken as a Sampling plan for all material handled. Ref Doc : Raw Material Sampling Plan QA-SCH-
02 & Quality manual. In process checks for particle size and purity for whole spices with a frequency of
once in a hour. All finished products are tested to meet various identified parameters.
Regular laboratory functioning involves sampling and testing followed by recording of microbial and
organoleptic results. Company has an in-house lab capable of conducting physical, chemical, microbial
tests which is continuously involved in test for raw material and finished product. Refer to guidance sop
Sampling QA-GEN-SOP-10 &
Sampling plan QA-SCH-02 for 43 raw material & 4 product types. All results are recorded in various
formats eg QA-ANA-F-01 for raw material QA-ANA-F-02 in seed cleaning and so on.
Company has sampled 41 specific product types and recorded to identify trends of results for various
parameters to name a few
Shelf life trials are conducted every 6 months and records are maintained. Ref Doc: Shelf life study has
been initiated for Fennel Powder produced on 4 th March 2017 and study completed on 8 th April 2018
which is the most recent study. Previously chilli powder lot no SS-230 produced on 13 th Sept 2016 was
analysed and completed on 1 st Oct 2017.
5.6.2 Laboratory testing
Only pathogen confirmation tests are undertaken by the laboratory and live strains of pathogens are not
maintained by lab.
Microbial testing laboratory is placed onsite but segregated from any direct openings to the production
areas. All movement of personnel, material, laboratory use apparel, waste disposal, access etc is
adequately controlled during approach and access.
The external laboratories are required to have accreditations against ISO 17025. Mostly nationally
approved labs are used. Geochem / TUV labs are the approved labs. Company also operates an ISO
17025 scope for certain microbial tests. For pathogens a confirmatory test is recorded on each pathogen
specific record. Eg Detection of salmonella QA-MIC-F-09B as seen for cumin seeds Lot no SS381-1 found
absent for any pathogen.
The analyses conducted in house are based on recognised standard like, AOAC or BAM. The personnel
are qualified, trained and are competent to carry out the job. The results are cross verified with external
laboratories for their reliability. Last such test was done on Nov 17 for 3 products tested for aflatoxin,
moisture, pungency, TPC, curcumin and volatile oils with 6 external labs. Internally reliability is tested for

11 parameters by 11 analysts.
5.7 Product release
Finished products are not released unless results of all agreed procedures have been achieved.
QA / technical Manager is authorised for product release after all release protocols. Company has a
product release procedure QAS-15.
reference
5.2.3 Products do not make any specific claims for a particular group of consumers.
5.2.4 All labels if used are directly received from the customers there is no nomination of
external printer or party. Clause 5.2.4 is not applicable.
5.3.6 There is no requirement to use a warning label on packs as most material is bulk
commodity. Clause 5.3.6. is not applicable.
5.3.7 There is no special claim made regarding suitability of food or allergy.
6. Process control
6.1 Control of operations
Documented procedures and work instructions are part of individual SOP to ensure the production of
consistently safe and legal product with the desired quality characteristics, in full compliance with the
HACCP food safety plan.
The company has controls over process operations. Most operations involve cleaning and grinding
activities through a BUHLER line. All operations involve cleaning of spices and grinding as per customer
requirements & sizes. Mesh sizes are the necessary controls for all products. Roasting is also conducted
for roasted material, such as coriander, fenugreek and Cumin. A standard guidance for Roasting
temperatures are documented. Ref Doc: Production Process parameters sheet & Daily Production Report
GL01.
There is time and temperature monitoring required for basic operations of cleaning and grinding. However,
for Roasting of fenugreek seed temperature identified is 170 deg C for period 3.5 hours. Other process
monitoring in cleaning section is purity levels checks and in Grinding is particle size checks.
There is no requirement to have an inline monitoring device. Only Metal detection is an inline rejection
mechanism.
Processing conditions remain same only the resultant product is monitored to meet size and purity . Size
is controlled Processing equipment such as temperature and pressure devices are calibrated once
internally as well as externally. All variations are product specific and equipment can cover the
requirements. Ref Doc : Roasting of fenugreek seed temperature identified is 170 deg C for a period 3.5

hours.
Backup power generation is provided in case of equipment failures and quality checks are undertaken to
ensure there is no contamination to products.
6.2 Labelling and pack control
Controls on product labelling activities ensure that products will be correctly labelled and coded. A
dedicated packing material store is provided and consumption is tracked.
Most packing can be bulk bags of 20 or 25 kg . All bulk bags are supplied to importers for their own use
with identification of lots. Company may provide a Lot no of own. As a minimum information such as
product name, net wt, date of packing will be displayed on each package. This is order specific as per
customer and the packaging material room allots them to the production. Only the packaging for
immediate use is available to the packaging activity. For packaging such as paper/plastic or LDPE Liners
or woven bags there is not specific requirement which may change from one packing line to the other.
Once product contracts are signed along with specifications, checks are carried out before commencing
execution of the order. This is also covering labels as identified by importers for art work checks. Most
labels are simple identification of lot sizes. Labels which were approved for Garlic powder lot no SOSS
17-18/948 totally 572 labels were printed internally. Track is maintained of damaged quantity or unused
labels if any. Precise number.
Accounting of those labels which are extra, returned or damaged after their application is not reflecting on
the label control register. One minor NC (7) has been raised against 6.2.2.
Company uses pre-approved labels / stickers on bulk bags and provides them during final packing of
material. All material is specific to Cleaning line or 3 grinding lines or roasting / kibbling lie. Packaging
material to be used is part of product specifications.
There is no online label generation or use of online vision equipment to be used. Clause 6.2.4 is not
applicable.
6.3 Quantity, weight, volume and number control

Quantity control & online packing system conforms to customer and a legal requirement in the country
where the product is produced and sold is complied.
Online checks for quantity verification including weight and grade/size checks are conducted as per the
documented procedures, regulatory and customer’s requirements. Each bag is weighed and recorded.
Records maintained in finished Product Inspection report.
The products are packed conform to the customer requirements and records maintained. There is no
requirement to meet bulk or volumetric requirement clause 6.3.2 is not applicable.
6.4 Calibration and control of measuring and monitoring devices
Company demonstrates that measuring equipment are sufficiently accurate and reliable to provide
confidence in measurement results.
The company has identified equipment used to monitor important control points such as temperature in
roasting and air pressure in cleaning and grinding line. Calibration to recognised national standard is
being followed. A list of equipment with identification code identifies 55 measuring equipment. Ref Doc:
Calibration Schedule MNT-SCH-01
All equipment is checked at a frequency of once in a 12 month which is annually. Calibration is traceable
to national standards and results are documented.
Eg weighting scale ID 111142092 calibrated on 1.04.2018 cert no SER/012/04/2018 by CAS India & Dig
temp controller Micron RD/DTC/-01 cert no CAL/1708-007 by TECHNOCAL Calibrations on 19.8.2017.
Pressure Guage CD-PG-02 by TECHNOCAL Calibrations on 19.8.2017 Cert no CAL/1708-007. There
are totally 18 magnet locations which are checked for strengths using a calibrated gauss meter. Eg Gauss

meter D20B was calibrated on 26 Feb 2018 and used to calibrate all the 18 locations recorded on magnet
strength record eg Magnet on GL-3 Bin no 02 had an average strength 4272.
Measuring equipment is being calibrated and traceable to national standards (NABL) same being recorded
on the calibration certificate of the equipment. technocal has used Master calibration equipment 447183
which is calibrated to National standards by IDEMI against national standards.
Site has quality procedures in place to record actions to be taken when the prescribed measuring devices
are found not to be operating within specified limits. There has been no such incidence.
reference
6.2.4 There is no online label generation or use of online vision equipment to be used.
6.3.2 The products are packed conform to the customer requirements and records
maintained. There is no requirement to meet bulk or volumetric requirement clause
6.3.2 is not applicable.
7. Personnel
7.1 Training: raw material handling, preparation, processing, packing and storage areas
All personnel conducting work that affects product safety, legality and quality are demonstrably competent
to carry out their activity, through training, work experience and qualification.
All Employees permanent and temporary are recruited on the basis of their experience in the seafood
industry. Personnel are trained and supervised. Organisation has documented a Training calendar QA-
TC-01 for the current year this has almost 42 topics. Topics such as GMP GHP, Personnel hygiene,
allergen awareness, policy awareness, company rules were planned in January. Similarly, the trainings
were executed such as applicable laws, HR Manual, policy, safety on 13 th & 20 th Jan for many batches.
Company rules, personal hygiene, HACCP were done on 15 th Feb.
Personnel engaged in CCP monitoring such as supervisors are trained for CCP Monitoring. Ref- Training
given on CCP awareness and various important topics on 24 Feb 2018 for 14 personnel covering
supervisory production staff. Training given by Mr. Kedar between 1730 to 1830 pm.
Company has documented competency matrix for 28 positions in the factory. For each of these a
competency requirement is document. In case of QA Executive, the required competency is PG in Food
technology, Knowledge of 2 to 4 years of experience, trainings required for BRC, FSSC, Analytical
knowledge in testing. Personnel are analysed for existing competencies and trainings are provided to
improve their capability. Executive R & D was recruited on 6 th Nov and an induction training was provided
by different departments.
Training given on allergen awareness was done on 19 Feb for totally 26 personnel.
Training is conducted and recorded on Training Record QAF-09 which covers date (19 th Feb), No of
trainees (17), name of trainer (Kedar Kavekar) their acknowledgement, topics are listed.
The company review the competencies of staff and adds in training topics as required. A training
assessment is maintained for all personnel after the training & a remark of satisfactory or unsatisfactory
result is recorded. On 27 th Aug 2017 training on HACCP, Allergen and BRC was done for 7 persons. The
evaluation resulted in measurement of responses by means of a score. All these were in a range of 21 to
24.

7.2 Personal hygiene: raw material handling, preparation, processing, packing and storage areas
Site’s personal hygiene standards have been developed to minimise the risk of product contamination
from personnel. Personnel are required to maintain personnel cleanliness and compliance. Documented
personnel hygiene policy and communicated to all the employees. Wearing of Jewellery, watches, studded
rings is prohibited. Monitoring is done for effectiveness. Ref Doc: Personnel Hygiene Practices & Entry
Procedure HK-S-06.
Hand cleaning is performed before entry to the production area using soap solution followed by
disinfection solution. Personnel are encouraged to report external cuts or injuries, personnel found to have
cuts and wounds are not allowed to work in production area. There is no use of blue coloured plaster.
Company does not allow any personnel with plaster in the production area & metal detector does need to
check a plaster sample. Clause 7.2.4 is not applicable.
Written instructions for control on use of personnel medicine are documented although company does not
allow drinking and eating in the production area.
7.3 Medical screening

All employees including new ones are required to undergo a medical check in the factory once in 12
months which is the basic legal requirement.
Company personnel are encouraged to notify in case of any diseases. All personnel are medically
checked by a Visiting Doctor annually. Ref Doc: Personnel Hygiene Practices & Entry Procedure.
All the visitors and contractors are required to complete a visitor’s declaration. Ref Doc: Visitors
Declaration TL-F-10.
Documented procedure exists in which all employees need to inform immediately to their supervisor in
case of any wounds, burns, cut as well as suffering from any diseases. Periodic checks by a visiting doctor
and annual checks are conducted for all employees Rakesh Sharma from production was checked on 29
th Jan 2018 by Dr Pradeep Mahajan and test report from Medi Check hospital laboratory is available.
7.4 Protective clothing: employees or visitors to production areas

Suitable site-issued protective clothing has been worn by employees, contractors or visitors working in or
entering production areas. Company provides protective work wear to all the employees including visitors
and contractors visiting the production and handling areas. During lunch breaks and tea breaks personnel
change in to non-production outfit while leaving production area. Documented policy is established.
Workers are provided with shirts having hoods and trousers and masks, cap and shoes. Hygiene & Quality
officers are provided with aprons, headgear, mouth mask. Shoes are provided by company for all
employees entering in the production area as appropriate.
Ref Doc: Personnel Hygiene policy P-03 in English and local language.
Suitable clothing sets are provided to all the employees on daily basis. There are no external pockets
above the waist and sewn buttons on the uniforms. Hairnets to contain all scalp hair are provided.
Company has in house laundering of all protective clothing. Effectiveness of the laundering is verified
through swab test and report maintained.
Swab analysis for apron & validation of laundry procedure, TPC and Coliform counts were monitored
before and after cleaning. Laundry Procedure HK-S-05 defines the procedure to be followed. Swab of
laundry washing effectiveness is maintained by the company and recorded on Mircotest result as
conducted on 25 Oct 2017 for 2 samples from grinding and cleaning division recorded on Swab Analysis
record QA-MIC-F07.
Internal laundry in terms of 2 washing machines is provided which conducts daily washing. Ref Doc:
Laundry Procedure HSK-05.
Only Low risk area is identified clause 7.4.5 is not applicable.
Gloves are not provided to personnel clause 7.4.6 is not applicable.
There are no items of protective clothing which may require specialised laundering clause 7.4.7 is not
applicable.

reference
7.2.3 Personnel are encouraged to report external cuts or injuries, personnel found to have
cuts and wounds are not allowed to work in production area. There is no use of blue
coloured plaster.
7.2.4 Company does not maintain sample of any metal detectable plaster as it does not
allow personnel to work near products.
7.4.7 Items of personal protective clothing that are not suitable for laundering are not
provided.

Module 8 - Traded Goods
Scope
8.1 Approval and performance monitoring of manufacturers/packers of traded food

products
8.2 Specifications
8.4 Product legality
8.5 Traceability

Module 9: Management of Food Materials for Animal Feed
Scope
9.1 Management Commitment
9.2 HACCP
9.3 Outsourced Production
9.4 Specifications
9.5 Traceability
9.6 Chemical and Physical Product Contamination Control

9.7 Labelling
9.8 Training
Module 11: Meat supply chain assurance
Scope
11.1 Traceability
11.2 Approval of meat supply chain
11.3 Raw material receipt and inspection

11.4 Management of cross-contamination between species
11.5 Product testing
11.6 Training
Module 12: AOECS Gluten-free Foods
Scope
12.1 Senior management
12.2 Management of suppliers of raw materials and packaging

12.3 Outsourced production
12.4 Specifications
12.5 Management of gluten cross-contamination
12.6 Management of incidents, product withdrawal and product recall
12.7 Labelling

Module 15 FSMA Preventive Controls Preparedness Module
Item no. Clause Module item Conforms Comments
(Y/N)
1 117.20 Handwashing areas, dressing and All areas have adequate

locker rooms, and bathrooms must lighting whose lux intensity
have adequate lighting. done on 7 th Feb 2018 for 27
different areas. Required
Y
minimum ranges from 300 to
500 lux are arrived at.
2 117.37 The water distribution system must Facility does not use water
prevent backflow from, or cross- directly in process or handling
connection between, piping systems of spices. Use of water is
that discharge waste water or sewage.
limited to hand wash stations
which are on the ground floor
Y
and flow pipes are maintained
at the external of the facility.
There is minimal chances of
any form of back flow. Only
other water is the pipe
conveying water as a cooling
medium to roaster which is a
closed loop process between
cooling tower and roaster
medium.
3 117.40 All food contact surfaces of plant All process equipment

equipment and utensils used in involving operations of
manufacturing, processing, packing, or cleaning, grinding, roasting
holding food must be corrosion
involves BUHLER lines made
resistant.
of SS304 and SS316L which
Seams on food-contact surfaces must Y
is suitable for this industrial
be smoothly bonded or maintained so purpose found to be corrosion
as to minimize accumulation of food resistance.
particles, dirt, and organic matter and
thus minimize the opportunity for
growth of microorganisms and allergen
cross-contact.
4 117.80 Ice used in contact with food must be Ice is not used in any of the
manufactured in accordance with the processes. Clause is not
good manufacturing practice (GMP) N/A applicable.
requirements of 21 CFR § 117.
5 117.110 Where defect action levels (DALs) are Company has documented
established for a food, quality control acceptance criteria for raw
operations must reduce defects to the

lowest level possible. Y material. Have also developed
specifications for each product
Defect levels rendering the food & product type to monitor
adulterated may not be reduced by
desired specification for each
mixing the food with another lot.
customer. Monitoring
mechanism is designed to
identify possible adulteration
at raw material level to ensure
this does not enter process.
Company rejects potential
material which deems to be
adulterated at the point of
receipt and does not re-use it.
Quality checks conducted in
process through sampling are
designed to identify quality
defects which are variation in
specifications. Raw material
analysis report maintained by
the company for each lot
covers monitoring of most
specifications as well those
parameters which may provide
hints of possible adulteration.
QA-ANA-F-01 for Fennel seed
Lot PO 110817.
6 117.130 (a) The hazard analysis must additionally Company has conducted
identify and evaluate the following hazard analysis for all raw
known or reasonably foreseeable material and processes
hazards, which are associated with the
conducted on site to ensure
food or facility:
safe final products are
 economic adulterants which produced this is in the form of
affect food safety Hazard Analysis M-01/Annex
 environmental pathogens 2 (GL-01). This considers
where ready-to-eat (RTE) food physical, chemical, biological
is exposed to the environment N and radiological hazards
prior to packaging and the considering purchase of raw
packaged food does not material and its processing in
receive a kill step
to final product.
 radiological hazards
 unintentional adulterants that
Further company also
affect food safety.
conducted Raw material
vulnerability risk assessment
M-01/Annex 2 which considers
adulteration, substitution and
exposure of unintentional
adulterants raw material to

such factors.
Risk of radiological hazards is

not clearly documented as part
of Imported coriander
consignments although
declarations supporting its
safety are maintained. One
minor NC has been raised
against this module.
7 117.130 (b) All identified, known, or reasonably As a part of the hazard

foreseeable hazards must be evaluated analysis company has
to determine ‘hazards that require a Y
considers all possible hazards
preventive control’ (i.e., significant
are expected to occur at the
hazards).
receipt or handling or
processing as applicable to
the products under scope such
as spices herbs and
botanicals. These are toxins,
physical and chemical
hazards, microbial
contaminants or factors which
could arise as a result of
handling the material.
8 117.135 Establish one or more preventive The Food safety team has
control(s) for each identified ‘hazard considered the control
that require a preventive control’ (i.e., measures necessary to
significant hazard) such that the control prevent, eliminate or reduce
significantly minimizes or prevents the the hazard to acceptable
food manufactured, processed, packed, levels. Consideration is given
or held by the facility from being to using more than one control
adulterated under section 402 of the measure. Justification for
Federal Food, Drug, and Cosmetic Act acceptable levels in the
or misbranded under section 403(w) of finished product for each
the Federal Food, Drug and Cosmetic hazard is determined and
Act. documented. Measures and
Y monitoring along with periodic
sampling and testing ensures
that any form of adulteration
does not take place within the
facility of the product. The
processing does not involve
any form of chemical
treatment or addition of
ingredients. For blended
products only, those material
which is produced in the
facility are used for blending.

Ref. Doc: CCP Plan M-
01/Annex03(CD) & (GL1).
9 117.139 Evaluate and update the recall and Company does not supply any
withdrawal procedure as necessary to material directly to customer
ensure it contains procedures and only withdrawal is applicable.
responsibility for the following:
Company has identified and
 notifying consignees of how to documented a team
return or dispose of recalled Y
comprising of 4 members
product along with their contact details,
 conducting effectiveness responsibilities of actions to be
checks to verify recall is taken during a situation
carried out needing withdrawal as
 appropriate disposal of identified. Responsibility to
recalled product (i.e., destroy, inform consignee lies with
divert, repurpose).
director operations. If there is
any food safety issue then
recall or withdrawn can be
initiated. However, there is no
such incident. Contact details
and communication plan is for
each is available. 4 major
areas for contacting customer,
legal, internal traceability and
overall approval to initiate are
identified. Ref Doc: Product
withdrawal and Recall
procedure QA-S-08
10 117.145 Establish monitoring activities and a Monitoring system is

written procedure for each preventive established for each CCP by
control in a manner consistent with the direct visual checks on lot
requirements of BRC section 2.10. sizes by passing all material
through an inline metal
detector. Monitoring system is
Y followed by recording such
results for each day and batch
which can be traceable.
11 117.150 Establish corrective action procedures As a part of hazard analysis

when preventive controls are not company has identified critical
implemented in a manner consistent control points which are
with the requirements of BRC sections monitored and actions in case
2.11 and 3.7. Y of a deviation is defined. For
CCP Metal fragments it is re-
Corrective action procedures must be passing and investigating
established and implemented when the source of metal. Finished
presence of a pathogen (or indicator goods are re-segregated and
organism) is detected as a part of repassed through the metal
verification activities (i.e., product detector.
testing and/or environmental Presence of microbial
contamination and pathogen

monitoring). testing are part of the routine
tests.
All finished products are tested
to meet various identified
parameters & Corrective
actions initiate if found to be
deviating during the
manufacturing process.
Regular laboratory functioning
involves sampling and testing
followed by recording of
microbial and organoleptic
results. Company has an in-
house lab capable of
conducting physical, chemical,
microbial tests which is
continuously involved in test
for raw material and finished
product. Guidance sop
Sampling QA-GEN-SOP-10 &
Sampling plan QA-SCH-02 for
43 raw material & 4 product
types. All results are recorded
in various formats eg QA-
ANA-F-01 for raw material QA-
ANA-F-02 in seed cleaning
and so on. Necessary action
pertaining to incidence of
pathogens is investigated
although this is a rare
occurrence.
12 117.160 Validate all established process Company has been

controls prior to implementation of the manufacturing the product
food safety plan, upon changes lines since some years and
requiring revalidation or within 90
has standardized the process
calendar days of the first food
through their own
production.
Y
manufacturing experience
Validate allergen, sanitation and supplement by state of the art
supply-chain controls as appropriate to tested equipment from
the nature of the hazard, control and BUHLER. Customer feedback
facility. towards setting expectation
and safety parameters is
available. Process has been
validated and quality checks
ensure that deviation of
product lines does not take
place. The controls are
focussed over physical
controls of hazards at the
processing step through metal
detectors, magnets and sieves
which are monitored for each

batch being produced.
Critical control points being

identified are validated through
the assistance from equipment
manufacturer.
This was last done by Sesotec

on 1-4-2018 for model no
rapid various FS120. The
metal detectors are also
calibrated last on 8 th Dec
2017.
Company has documented as

vulnerability substitution of
fraud risk assessment for
source of raw materials (M-
01/Annex02) which considers
possibility, likelihood and
severity of vulnerability. This is
kept open for review and more
raw materials as incorporated
have been added in as on
purchased. This was reviewed
on 7 Nov 2017 where in few
raw material groups was
added in.
Allergen handling and removal

process is validated and
tested using ELISA kit. On 5 th
Feb 18 traces of yellow
Mustard were checked in
turmeric powder and the
results we done for 1 product
and 3 surface samples having
no traces. Similarly, this was
done for sesame seed and
black mustard and results
were satisfactory.
The validated plans are signed

by team members who are
trained PCQI. Dr Sonika Putto
is also the PCQI and Quality
Technical manager.

13 117.165 (a) The PCQI (or authorized designee) All production records and
reviews the monitoring and corrective quality monitoring records are
action records within 7 days. Where an reviewed on the same day or
alternate timeframe exceeding 7 days is
maximum next day. Results of
used, the PCQI must document
monitoring if found to be
justification.
Y
deviating are discussed
immediately with the HACCP
team to ensure that
The PCQI (or their authorized compliance is achieved and
designee) reviews the verification
product is identified. All
records for all preventive controls (e.g.,
compliances or issues
calibration records, product testing,
supply-chain audits) within a
pertaining to food safety are
reasonable timeframe after the record recorded in monthly meeting.
has been created.
14 117.165 (b) Where product testing for a pathogen Company has an in-house lab
(or indicator organism) or other hazard capable of conducting
is used as a verification activity, a physical, chemical, microbial
scientifically valid and written testing tests which is continuously
procedure must identify the following: involved in test for raw
material and finished product.
 sampling procedure to include Guidance sop Sampling QA-
method, quantity, frequency, GEN-SOP-10 &
and number of samples Y Sampling plan QA-SCH-02 for
 analytical method 43 raw material & 4 product
 laboratory conducting an types. All results are recorded
analysis in various formats eg QA-
 corrective action procedure ANA-F-01 for raw material QA-
where a pathogen is detected. ANA-F-02 in seed cleaning
and so on. Pathogen testing is
part of finished product testing
along with other microbial
loads. There has not been any
incidence of positive pathogen
indication.
15 117.165 (c) Where environmental monitoring for a N/A Facility handles low risk
pathogen (or indicator organism) is products which are used as an
used as a verification activity, a ingredient to cooking
scientifically valid and written testing
operations. There are no
procedure must identify the following:
products which are consumed
 adequate number and location directly. There is no customer
of sample sites requirement to monitor
 timing and frequency of environmental pathogen
sampling monitoring. Environmental
 analytical method monitoring is not used as an
 laboratory conducting the indication of verification. The
analysis

 corrective action procedure clause is not applicable.
where a pathogen is detected.
16 117.165 Devices used to verify preventive All equipment are checked at
controls must be calibrated. a frequency of once in a 12
months which is annually.
Calibration is traceable to
national standards and results
are documented.
Eg weighting scale ID
111142092 calibrated on
1.04.2018 cert no
SER/012/04/2018 by CAS
India & Dig temp controller
Micron RD/DTC/-01 cert no
Y CAL/1708-007 by
TECHNOCAL Calibrations on
19.8.2017. Pressure Guage
CD-PG-02 by TECHNOCAL
Calibrations on 19.8.2017 Cert
no CAL/1708-007. There are
totally 18 magnet locations
which are checked for
strengths using a calibrated
gauss meter. Eg Gauss meter
D20B was calibrated on 26
Feb 2018 and used to
calibrate all the 18 locations
recorded on magnet strength
record eg Magnet on GL-3 Bin
no 02 had an average strength
4272.
17 117.180 Identify a PCQI responsible for The site has trained 4 PCQI
developing the food safety plan, who are part of the HACCP
validating preventing controls, review of Team. The responsible PCQI
records, and reanalysis of the plan.
is team leader Vinayak
Y
Chondekar who is the team
leader and Dr Sonika Putto
Document the PCQI’s training or who is also the PCQI and
qualifications via job experience. Quality Technical manager.
The training for PCQI was
done on 17 th Dec 2016
conducted by FSPCA. The
PCQI has relevant experience
to understand the process and
hazards involved.
18 117.305 All records required by 21 CFR § 117 All records bear the date and
must include: time as applicable with
Y signature of the person signing
 the date and time of the
and lot no being processed.
activity being documented
 signature/initials of individual
performing the activity or

conducting the record review
 information to identify the
facility (e.g., name and
location)
 the identity of the product and
lot code where applicable.
19 117.310 The owner, operator or agent in charge The Food Safety plan has
of the facility must sign and date the been signed by team leader
written food safety plan initially and Y Vinayak Chondekar and is
again upon any changes following
done so whenever it is
reanalysis.
reviewed. The entire HACCP
team is also comprising of top
management who are part of
the review process.
20 117.315 All documents and records relating to All the records are retained for
the food safety plan (i.e., all records a period of 2 years which one
required by 21 CFR § 117) must be Y year over the shelf life of the
retained at the facility for 2 years after
product. All records are stored
the record is created. Where records
on site.
are stored offsite, they must be
retrievable within 24 hours, with the
exception of the food safety plan, which
must remain onsite.
21 117.405 Where a hazard requiring a supply- Company has also established

chain-applied control is identified in the a supplier approval program.
hazard analysis, the receiving facility Y This is developed monitored
must establish and implement specific and implemented by the
supplier approval and verification company directly. All
activities. chemicals raw material and
ingredients have undergone
Where a hazard requiring a supply- hazard analysis and risk
chain-applied control is identified and assessment before
the control is applied by an entity other acceptance. This includes
than the receiving facility’s supplier, the packaging material, allergens,
receiving facility is responsible for physical & chemical
verifying implementation of the control. contamination.
. The risk assessment for raw
material group and packaging
material is in the form of
hazard and risk analysis.
22 117.420 Supplier approval must be documented Supplier approval procedure in
before receiving and using raw terms of Management of
materials and ingredients. Purchased material PU-S-01 &
Approved vendor list
Verification activities must be Y
maintained. Company
conducted before receiving and using
raw materials and ingredients on a maintains as approved vendor
temporary basis from unapproved supply chain control list.
suppliers.

23 117.430 One or more supplier verification Raw material testing of each
activities (as defined in 21 CFR § lot conducted internally as a
117.410(b)) must be conducted for minimum and externally as
each supplier before using raw
applicable is conducted and
materials and ingredients and Y
maintained.
periodically thereafter at an adequate
frequency.


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Audit Report

Global Standard for Food Safety Issue 7: July 2015

Site name Swani Spice Mills Pvt Ltd

Processing (Cleaning, grinding/ milling, crushing, blending, Roasting) of spices,

Audit Finish Date 2018-04-11

Re-audit due date 2019-04-16

Voluntary modules included

Previous audit grade A Previous audit date 2017-04-10

Intertek Certification Ltd

Country India Site +912241268001

Commercial Mr.Harjiv Swani Email harjiv@swanispice.com

Technical Mr. Vinayak Chondekar Email steamteam@swanispice.com

Subcontracted processes Yes

Regions exported to Europe

Company registration 10013022001931

Major changes since last NONE

Intertek Certification Ltd

High care No High risk No Ambient high care No

Allergens handled on site Sesame

Intertek Certification Ltd

Product recalls in last 12 Months No

6.Audit Duration Details

Reasons for deviation NONE

Next audit type selected Announced

Audit Duration per day

1 (start date) 2018-04-09 09:30 18:00

2 2018-04-10 09:45 18:15

3 (end date) 2018-04-11 09:00 17:30

Auditor (s) number(s) Names and roles of others

Auditor Number 168088 Harshad Karulkar

Intertek Certification Ltd

Intertek Certification Ltd

Intertek Certification Ltd

Intertek Certification Ltd

The contract with Microtrol was with

Hygiene clearance Although each maintenance activity is Training on

Intertek Certification Ltd

Microbiological checks As per existing routine, swabs were

Similar studies will be conducted

Intertek Certification Ltd

Although label issuing was recorded in

Intertek Certification Ltd

Intertek Certification Ltd

Intertek Certification Ltd

Intertek Certification Ltd

Intertek Certification Ltd

1.1 Senior management commitment and continual improvement

Intertek Certification Ltd

Details of non-applicable clauses with justification

2 The Food Safety Plan – HACCP

Intertek Certification Ltd

Intertek Certification Ltd

Details of non-applicable clauses with justification

3. Food safety and quality management system

3.1 Food safety and quality manual

Intertek Certification Ltd

3.2 Documentation control

3.3 Record completion and maintenance

3.4 Internal audit

3.5 Supplier and raw material approval and performance monitoring

3.5.1 Management of suppliers of raw materials and packaging

Intertek Certification Ltd