Your food safety plan is your navigation map for ensuring that customers only receive safe and suitable food. It makes perfect sense that this food safety plan should be current and correct at all times, not only from a business success front but also from a food regulatory stand point. Read on to find out key points that you should consider when completing your food safety plan review.
Review in Practice
The goal of completing a food safety plan review is to ensure that your plan is current, correct, implemented and capable of meeting the requirements for safe food production. You may choose to do the entire review yourself, split it up to several colleagues or use an external technical consultant. You can do it all in one hit or schedule the review over a 12-month period. It is entirely up to you, as long as you meet the minimum food safety review or reanalysis time frames set by legislation and GFSI standard.
Frequency of Review or Reanalysis
The FDA Food Safety Modernization Act (FSMA) Preventive Controls for Human Food rule states that you must conduct a reanalysis of the food safety plan as a whole at least once every 3 years.
If you are a manufacturer based in Australia or New Zealand, the Food Standards Code mandates that a food business conducts a review of the food safety program at least annually to ensure its adequacy.
Outside of these review frequencies your plan needs to be reviewed whenever:
- There is a significant change in what happens at your facility eg. You start using allergenic ingredients that you did not previously use
- There is an unanticipated food safety problem
- A control measure or preventive control is found to be ineffective
- You become aware of new information about potential hazards associated with the food you handle.
Please refer to your applicable food safety legislation in your country of manufacture.
Food Safety Plan Review Activities
There are many activities that make up the food safety plan review process. You don’t have to do them all at once but can schedule them over a defined period. Here are a few to get you started.
1. New and Emerging Hazards
Included in your food safety plan is the documentation and assessment of all potential food safety hazards. From time to time there may be new or emerging hazards that have not been identified or assessed. Check out local and international food safety articles (including food safety alerts and recalls) to see if they impact or can impact your food business.
2. Flow process chart
The flow process chart is a pictorial representation of the actual process flow or steps in your food business. Physically checking that the documented flow chart matches the actual production flow process is a must. Walk the process and make updates as required. Make sure that you then update your hazard analysis and HACCP Plan.
3. Roles and Responsibilities
Have there been changes in staff? Have people left or have new people started in your food business? If your food safety plan documents actual employees names, you need to check that these are all current. Common documents could be the HACCP team, recall team, crisis management team, organisational chart, verification schedule, corrective action response, external contacts reporting requirements.
4. Changes to certification standards or legal requirements
If your food business maintains a GFSI recognised standard eg. SQF, BRC, FSSC22000 or any other type of certification, a complete review should be completed against the actual requirements. You may do this during the internal audit process. Make sure that you cover all areas. HACCP Mentor provides Internal Auditor training that you can access here.
5. Supplier and Raw Materials
I know that this can be a massive process, but it has to be done. Check that your suppliers are still current, they are still providing you the raw material as per your agreement, the actual raw material aligns with the documented raw material specifications and they have the applicable certifications and licences.
Additional Review Activities
I have only touched on some common food safety plan review activities – there are so many more. Help build this list and share your knowledge with the HACCP Mentor community by leaving a comment below this post.