ISO 9001 Quality Manuals

Posts Tagged ‘Corrective Action Plans’

Food safety legislation changed on 1 January 2006. Regulation 852/2004 (EC) of the European Parliament and Council on the Hygiene of Food Stuffs now applies to all food businesses except primary producers. The Food Hygiene (England) Regulations 2006 has also come into force.
On the 29 April 2004, the European Parliament and the Council issued Regulation (EC) No 852/2004 on the hygiene of foodstuffs.
Article 5 states that: Food business operators shall put into place, implement and maintain a permanent procedure based on the principles of hazard analysis critical control points (HACCP). The HACCP principles referred to above consist of the following:
• Identifying any hazards that must be prevented, eliminated or reduced to acceptable levels
• Identifying the critical control points at the step or steps at which control is essential to prevent or eliminate a hazard or to reduce it to acceptable levels
• Establishing critical limits at critical control points that separate acceptability from unacceptability for the prevention, elimination or reduction of identified hazards
• Establishing and implementing effective monitoring procedures at critical control points
• Establishing corrective actions when monitoring indicates that a critical control point is not under control
• Establishing procedures, which shall be carried out regularly, to verify that the measures outlined in the above paragraphs
• Establishing documents and records commensurate with the nature and size of the food business to demonstrate the effective application of the measures outlined in the above paragraphs
When any modification is made in the product, process, or any step, food business operators shall review the procedure and make the necessary changes to it.

There are many different ways that companies go about formulating their HACCP plans but there are a few fundamentals:

Knowledgeable Staff
Staff involved in Hazard assessment should have a thorough knowledge of the process, what happens and what is likely to go wrong. In addition to this they need to have some understanding of food safety. This is where training is important; the HACCP team need to understand the range of potential hazards that can affect the process and how to assess the significance of these hazards. In addition the team leader should have expertise knowledge in acceptable standards for critical limits, suitable monitoring procedures and appropriate corrective actions.

Practical HACCP System
Many systems are over burdening in the amount of paper generated and how the analysis follows through. It can easier to use software based systems these days provided they are designed by people who understand food safety systems rather than being software writers.
We have designed a simple HACCP system that enables all of the Hazard Analysis and Critical Control Point Assessment documents to be held in one file we call the HACCP Calculator
Appropriate Monitoring Procedures, Records and Operator Training
While HACCP plans are being formulated sensible and appropriate procedures need to be established that are easy for the person carrying out the task to follow. Records need to be as simple as possible so that it is quite clear when a critical control point has been breached and the procedure should stipulate the corrective action required. It is then essential to train operators so that they thoroughly understand the procedures, how to complete the records, what the critical limits are and what corrective action to take.
Monitoring at critical control points should take into consideration the quantity of product likely to be affective and the risk. For instance if you only check something once a day you may have to quarantine a whole day’s production.

I have been involved in many projects to improve product quality and reduce food complaint levels. One of the best tools for indicating where action for improvement needs to be applied is by analysing your complaint data appropriately.
Whilst you can identify faults in your factory your customers are your 100% inspection service so respect their feedback. Whilst all of your customers will not complain when they find a problem so you will not capture all of your product faults you will however identify trends.
The first step is to collate all of your complaint data. Your data should then be categorised by product type, complaint type and size. Analysing complaints by numbers alone will not give you a real picture of your performance. What you need to know is the proportion of complaints you are getting for each product. By far the most practical way of doing this is by using the sales volumes to calculate the proportion of complaints you get for each product. Some people use weight or volume such as complaints per tonne or 1000 Litres. My preference is to use complaints per million units.
So you analyse your complaint data product type, complaint type and size per million units. From this data you can easily spot the worst performing product lines.
You should then analyse the results for the worst performing products:
Are they all the same size?
Are they produced on the same filling machine/production line?
Is it the same type of complaint?
The answers to these questions will generate your corrective action plans. If products with the highest complaint levels are all the same size it could be a particular problem with that size of packaging. If it is all the same type of complaint then why are some product lines worse than others? If product from one particular production line is generating the highest number of complaints per million units then there must be a reason for this, it needs investigating. You should compare product performance and if there are significant differences you should ask the question why? At this point complaint trends are useful. For example when I worked with fresh pasteurised milk sour complaints were higher in larger sized containers. The reason for this was not related to the quality of the product but the fact they took longer to consume and spent more time in and out of the fridge. Such products would be targeted for improvement projects as opposed to corrective action to remedy a problem area.
A few words of caution though, your analysis needs to take into consideration the comparative value of the products and the market. People are more likely to complain about higher value products. Also some retail customers are much better at reporting complaints from customers to the extent that I used to get 10 times the complaint levels from one particular retailer compared to another for exactly the same product.
My last tip the more data you analyse the better. In the past I have analysed 3 years worth of data. Why? It gives a year on year performance so you can see if things have been improving or deteriorating and also it shows any effects of seasonality. For example it is not reasonable to compare summer levels of “off” complaints on a fresh product with winter levels. This is why in the UK I would compare August complaint performance with the complaint levels for August in the previous year.
Try out a sample annual analyser for free by clicking on the link below:
http://iso9001manual.com/analyser.php