This time around we look at some of the major changes to the Site Standards Section. This change was driven by the need to ensure that certification bodies spend more time in the factory and more time assessing housekeeping controls. Many in the industry support this as a sensible measure of the true food safety status of food factories:
Section 4 – Site Standards
Site security has attained greater significance with the global spread of the Standard and particularly where products are exported to the United States. A documented risk assessment of security arrangements is now included (4.2.1) to ensure security risks are adequately addressed. In practice this means you must consider each area of your facility, externally and internally, access and movement routes and areas in which food products, equipment, plant and chemicals are stored. Consider how easy it would be for an intruder to gain access to these areas. What current safeguards do you have – is the actual site secured by means of fences / gates, are all appropriate doors locked, is signage apparent, are monitoring systems such as CCTV used, are areas always manned or are they empty for periods of a time?
High risk/high care – The Standard has attempted to clarify the where high risk and/or high care areas are required by introducing a decision tree and new guideline. The intention is to ensure a consistent interpretation. The requirements for high risk areas were always strict of course, but the requirements for high care areas have been increased particularly with respect to changing facilities (4.8.4) and segregation between high care and low risk areas (4.3.5). This reflects the protection which needs to be provided to high care products to control the risk from pathogens. In both cases risk assessment forms an integral part of satisfying the clauses. For high risk areas clause 4.4.13 requires that they shall be provided with sufficient changes of filtered air, with filter specification and frequency of air changes documented.
The lay out product flow and segregation (4.3) section has been extended by the requirement for a site plan showing different risk zones (4.3.1) and incorporation of process and staff flows (4.3.2). There should be clearly identified risk zones for enclosed product, low risk product, high care product and high risk product. This assists the organisation of process flow, identification of potential cross contamination points and appropriate levels of processing environment control – it should dictate and direct the implementation of pre-requisite programmes and the level at which they need to be implemented. Clearly the cleaning of a high care area with open product should be at more depth and more frequent that the cleaning of an enclosed product storage / warehouse area.
Building Fabric (4.4) has been condensed but the expectation of sites is unchanged from Issue 5.
In recognition of the risk that water contamination can play in product safety a plan of the water system is now required (4.5.2). This is to be used in defining water sampling points and identifying areas where water may require treatment. A plan of water drainage is also required for high care or high risk areas to verify that there is no risk from drainage flow.
Within Staff Facilities (4.8) the requirements for both high care (4.8.4) and high risk (4.8.5) changing facilities are now more detailed to ensure a consistent approach and reflect established industry best practise.
The management of the risks to products of chemical and physical contamination (4.9) and methods for detection and removal of foreign material (4.10) has always had a high priority within the Standard. Within Issue 6 these requirements have been extended considerably to try to ensure a consistent approach. In particular the clauses reflect the management of risks from different materials and the different technologies available for removal of contamination. Included now are specific sections on managing products packaged into brittle containers. The controls demanded are in place to prevent physical contamination of product from glass and brittle materials caused by breakage, and consequent clean down of production lines in which brittle containers are used. There are also clauses in place for the management of filters and sieves, X ray detection equipment, magnets and optical sorters as detection devices. The clauses require, where appropriate to the system employed, procedures for verifying operating effectiveness, integrity and inspection checks. Depending on the type of production undertaken some requirements may not apply.
Housekeeping and Hygiene (4.11) is an area that was identified from the initial consultation as requiring greater emphasis and an area where most variability occurred on customer audits of certificated sites. Accordingly audits will generally incorporate observation of line-change cleaning and may require dismantling of equipment for inspection where this does not adversely affect production. Cleaning standards are now required to be defined and validated to be appropriate for the particular risk (4.11.2). The new clause 4.11.3 expects resources and the planning of cleaning to take account of the cleaning of equipment which is only acceptable outside of production periods. New more detailed requirements have also been introduced to cover Cleaning in Place (CIP) systems (4.11.6) where these are used in liquid processing plants e.g. Dairies.
In recognition of increasing legal requirements on the use of “waste” food for Animal feed a new requirement (4.12.3) has been added to ensure products for animal feed are handled correctly.
The Pest control section has been revised to provide greater clarity on the expectations of a site where pest control is undertaken by the site (4.13.2). There is a new requirement for in depth pest control surveys (4.13.8) typically quarterly in addition to the routine pest control measures to provide an overview of the pest control programme.
The requirements for Storage (4.14) and for Dispatch and Transport (4.15) have been separated into two sections and more details have been added to the management of dispatch and vehicle checks. Off-site storage facilities owned by the company must now be included in the audit or specifically excluded where these are within 50 Km of the main site. This is to ensure products are not at risk when stored.