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Paul Harper

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U502 - Management System

Executive Summary This report concerns itself with Kerry Foods facility at Burton on Trent, specifically the ready meals production department. Kerry Foods is a diverse ingredient supplier ready meals represent an important and developing market for Kerry. Currently ready meals are supplied to a limited number of retail outlets. Ready meals production is only one element of the supply chain but is likely to be the most critical for this reason the author believes setting new standards here will have immediate benefits, these standards can then be applied to the rest of the supply chain, adding greater strength to the company, but introducing an Integrated Management System to the whole business in one fell swoop could be detrimental a phased introduction would be easier to manage. Ready Meals production area comprises 14 assembly and packaging lines supplied from three chillers operating 24/7 producing 1.4million ready meals per month, the capacity is at least twice this. The standard to be introduced ISO22000 which includes HACCP and ISO9001/4 these will be integrated with the companys' environmental management system: ISO14001.

The author has observed the operation of the current quality system and reviewed audits over a 28 day period, Hazard Analysis and Critical Control Points (HACCP) policy again reviewing audits and observing operation over a 28 day period. Benchmarked Kerrys standards against competitive suppliers, studied and analysed the various quality standards applicable to food processing and carefully noted the high health and safety requirements of the business. Further a GAP Analysis has been conducted. The author has a working knowledge of ISO14001 the environmental management system adopted by Kerrys.

He author has concluded that an Integrated Management system embracing ISO22000 ( which incorporates HACCP, ISO9001 and elements of ISO9004) and ISO14001 would have the benefit of improving standards within ready meals production leading to

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U502 - Management System

reductions in costs and waste whilst increasing efficiency and should be adopted. The GAP Analysis conducted which determined a rating of poor to average suggests that in order for Kerry Foods to improve their market position greater attention to detail and process are needed a well founded and structured management system will provide a foundation on which the business can be developed.

Paul Harper
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U502 - Management System

Introduction Kerry Foods were established in 1972 and have grown to a worldwide leading ingredients supplier. Kerry manufacture, market and distribute a vast range of food products many with familiar names: Low-Low Cheesestrings Walls Richmond Homepride Pork Farms Matthesons the leading selling specially formulated low fat cheese the UK number one selling snack food meat products including the famous Walls sausage the leading brand of Irish sausage an established brand for home baking products and cook-in sauces a range of pork based snack foods and pies a range of meat based pates and snack foods including Fridge Raiders

This proposal however concerns itself with the facility at Burton on Trent. The facility specialises in the production of ready meals, producing a range of own branded products in the form of ready meals. Currently these include Finest, Ken Hom, City Kitchen for Tesco, Morrisons own brand and Innocence Veggie Pots for Innocence. New products are currently being added including a French cuisine range and vegetarian range for a leading supermarket. The ready meals market is developing and expanding as lifestyles leave less time for meal preparation and so many of us now demand food in a hurry. If Kerry wish to develop and exploit this market they need to ensure they are in the best position to do so, with an enviable reputation for product quality and customer service.

Deming suggested a chain reaction: improve quality improved productivity costs decrease greater market share solid company structure secure working places

Paul Harper
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U502 - Management System

The author is suggesting a review of quality standards and systems together with the introduction of an Integrated Management System (IMS) will take Kerry Foods forward enabling them to become the leading ready meals supplier. This concept fits well with Kerrys mission statement: To fill the nations fridges with simply delicious food . We will achieve this through having the audacity and ambition to be the best, by continuously improving our products, standards and customer service, being innovative and delivering new products as demanded by our customers whilst caring for the environment and our communities Kerry Foods current quality policy is based on HACCP and has proved effective, Kerry Foods have an A* Rating by SAI Global. HACCP requires that all hazards are identified throughout the supply chain and that critical control points are identified to eliminate these hazards, these critical control points are regularly monitored and audited, This form of quality control is based on seven principles: Conduct hazard analyses Identify critical control points Establish critical limits for each critical control point. Establish critical control point monitoring requirements. Establish corrective actions Establish record keeping procedures. Establish procedures for ensuring the HACCP system is working as intended.

These seven principles have been used to design and implement Kerry Foods quality policy viz.: Kerry Foods recognises that its continued success depends upon its ability to satisfy its customers profitably. The company has adopted a perfect product and service philosophy as an integral part of its mission & strategy.

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U502 - Management System

The Management Team is committed to comply with the requirements of the quality management system and HACCP at all times and to continually improve its effectiveness in achieving a perfect product and service by: Responding effectively to market and customer needs working in partnership with its customers and suppliers to provide innovative exciting food ranges Effectively involving all company employees in the task of meeting and exceeding customer requirements, eliminating waste and an understanding of HACCP; Designing quality assurance into all processes, designing and implementing processes for continual improvement and innovation all activities; Motivating, coaching and educating all staff to take positive action to improve quality and the importance team participation. Continually improving performance by effective people selection, employee development, and effective organisational and strategy development.. The Company will establish quality objectives which will be reviewed alongside the requirements of HACCP by the Management Team on a regular basis to ensure progress towards specific targets.

Paul Harper
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U502 - Management System

EVALUATION World-wide, there has been a growing consumer demand for the food industry to meet strict, effective, and consistent Food Safety Standards. Current food technologies and the globalization of food production now involve a longer, more complex food chain with increased risks that include the growth of food-related illness and costly recalls. Having a standardized system for ensuring the integrity and safety of each link in the food chain is critical in order to ensure consumer protection. Until recently, there have been many different sets of standards globally, causing confusion for manufacturers and consumers. ISO22000 now provides peace of mind for suppliers, retailers, and consumers world-wide, as it demonstrates compliance in meeting the requirements of an effective, standardized, and globally recognized food safety system including. Feed production Food manufacturing Food ingredients Transportation of food Packaging of food Selling (retail or wholesale) Serving prepared food (restaurants, grocery stores) Food equipment production Food additives This standardized international food safety system, approved by the Global Food Safety Initiative (GFSI) is designed to protect the health of all consumers Provides the ability to sell product to the growing number of major national and international retail chains that require this certification

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Ensures food safety for the consumer, and reduces the risks associated with costly recalls The documented internal food safety processes that are required to receive certification provide a systematic, proactive, ongoing approach to food safety that ensures food safety standards are met and maintained. The quality system used by Kerry at present: HACCP addresses many important food safety issues because of the seven criteria set:

.1. Conduct a Hazard Analysis


Evaluate processes and identify where hazards can be introduced. Hazards can be physical (i.e. metal contamination), chemical (i.e. can a cleaning product contaminate the product, are there toxins that could contaminate the product?) or biological (at what points could bacteria or virus contaminate your product?). 2. Identify the Critical Control Points

Establish at what steps in the process can controls be applied to prevent or eliminate the hazards that have been identified? These are the critical control points. For each critical control point identify the preventive measure. How will the hazard be prevented?: Use of specific Temperature, ph, time, procedures? 3Establish Critical Limits The next step is to establish criteria for each critical control point. What criteria must be met to control the hazard at that point? Is it a minimum temperature? Are there regulatory limits that must be met for this control point? 4. Establish Monitoring Procedures

What will be measured and how? There is a need to monitor the process at the critical control point and keep records to show that the critical limits have been met. Is continuous monitoring of the control point practical? If not, how often will the measurements need to be performed to show that the process is under control? 5.Establish Corrective Actions

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Establish what actions need to be taken if a critical limit is not met. This will be identified ahead of time for each CCP. The action must make sure that no unsafe product is released. There must also be an evaluation of the process to determine the cause of the problem and an elimination of the cause. 6. Establish Record Keeping Procedures Determine what records are needed to show that the critical limits have been met, and the system is in control. Address regulatory requirements and include records from the development of the system and the operation of the system. 7.Establish Verification Procedures The HACCP plan must be validated. Once the plan is in place, ensure it is effective in preventing the hazards identified. Test the end product, verify that the controls are working as planned. Perform ongoing verification of the system. Are measuring and monitoring equipment in control? What are corrective actions showing? Are records being maintained as required? HACCP is built into the ISO 22000 Food Safety Management System (FSMS). The difference between the two systems is a broader focus in ISO 22000. The 22000 system reaches beyond the hazard analysis critical control point and also incorporates the quality management principles found in ISO 9001. Building a system to manage quality and continual improvement throughout the organization. It will reach beyond the control systems that we have discussed above and into how to plan and manage quality into the organization. This system should if applied will provide the necessary initiative to move Kerry Foods forward enabling to embrace and fulfil their ambition and objectives.

Paul Harper
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COMPARISON The concept of an integrated management system is all well and good providing that there is a compatibility within the systems chosen to build the IMS. Certainly in this instance this compatibility exists, if we compare the requirements of ISO22000 with those of ISO14001 (the environmental management system employed by Kerry) we will find certain shared principles and procedures, Kerry also operate an HACCP control system this is embraced within ISO22000 and also shares some principles and procedures with both standards. The table below allows a quick overview of these shared principles and procedures, which are discussed further in this document.

ISO22000 PROCEDURES
Document Control Recording and/retrieval Training Non-Conformance Audits Corrective Actions Preventative Actions

ISO14001 * * * * * * * * * * * * * *

HACCP * * * * * * *

* * * * * * * * * * * * * *

PRINCIPLES
Customer Focus Leadership People Involvement Process Approach System Approach Contiual Improvement Factual Approach to decision making

* *

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U502 - Management System

The above table clearly shows that there are many shared areas within the management systems this will allow integration and provide the foundation for an effective and efficient IMS. ISO22000 encompasses HACCP so although this is shown on the table we need not concern ourselves as to whether or not it is practical or possible to integrate HACCP to the IMS as this has already been effected by its incorporation in the standard. This leaves comparing ISO22000 with ISO14001. The table demonstrates a high degree of compatibility between the two standards and doubtless they can be used to create a suitable IMS for Kerrys. In the appendix is a more detailed comparison of ISO9001:2000 and ISO14001:1996, the basis of ISO22000 combines ISO9001 with HACCP we can therefore conclude the compatibility illustrated in this table will equally apply to ISO22000 with ISO14001. Because of the correspondence that exists between the two standards (ISO14001:1996 and ISO22000) benefits can be obtained which include cost savings, more efficient auditing, clear structure and cost savings. For instance if we look at the process of auditing: 1st party (internal) audits can be made more efficient one auditor being able to conduct an audit which will include HACCP, quality and waste management, this will mean a better understanding of a process, ensure the necessary safety, check on quality and that waste is being minimized and disposed of in the correct manner. When we consider 3rd party (external audits) the IMS will mean fewer audits: instead of one for HACCP and one for ISO14001 these can be conducted together and include a quality audit at the same time whereas currently separate audits are conducted for HACCP, waste and quality. Similar benefits will apply to other procedures all documents, records in one place, the same retrieval system for all etc. under the current systems three storage/record and retrieval systems are operated.

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JUSTIFICATION ISO 22000 takes a whole chain approach to food safety, providing a standard that just does not apply solely to food processors, but operates all the way from the farm to the fork including packaging and ingredient suppliers, caterers, storage & distribution facilities, chemical and machinery manufacturers and can be applied to primary producers such as farms. The ISO22000 scheme is an EN45012 accredited scheme designed to ensure safe food supply chains worldwide. ISO 22000 is designed to allow all types of organization within the food chain to implement a food safety management system (FSMS). These range from feed producers, primary producers, food manufacturers, transport and storage operators and subcontractors to retail and food service outlets together with related organizations such as producers of equipment, packaging material, cleaning agents, additives and ingredients. ISO 22000 extends the successful management system approach of the ISO 9001:2000 quality management system standard which is widely implemented in all sectors but does not itself specifically address food safety. The development of ISO 22000 was based on the assumption that the most effective food safety systems are designed, operated and continually improved within the framework of a structured management system, and incorporated into the overall management activities of the organisation.

The scheme is applicable to all parts of the food chain that wish to certify a food safety management system based on HACCP. Benefits: The scheme will combine well with other ISO standards and the BRC Food standard. It will provide 3rd party validation of the HACCP plan. Accepted by buyers

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It is supported by suppliers and retailers who wish to promote improved food safety. Kerry already operate successfully a validated HACCP (validation is by SAI Global and an A* rating has been awarded), the current environmental management system (EMS) is ISO14001, ISO22000 is now an appropriate standard for adoption by Kerry and creating an IMS (Integrated Management System) based on these standards seems a wise prudent decision which will have the benefit of moving the business forward by the efficiency savings and increased customer confidence.

SAI Global have inspectors with at least 5 years experience of ISO22000 validation, accreditation and certification and would undoubtedly be more than willing to assist Kerry Foods to make the transition providing the necessary inspections etc., throughout the process to ensure validation and appropriate certification.

If Kerry Foods adopt the suggested Integrated Management System it can expect to: 1. Save Money, this has already been discussed in the comparison section: reduced audit costs being just one element other efficiency savings will also be made these will include better control of the lean manufacturing process. Lean manufacturing is intended to reduce waste and giveaway currently whilst encouraged this element is not adequately audited or enforced the Management system of ISO9001 (ISO22000 is a combination of this standard, HACCP and other food safety requirements) will cause closer control on this element and thereby bring about further cost savings as it increases the effectiveness of the lean manufacturing process. Other efficiency savings leading to cost reduction will include better control of Just in Time ((Just in Time is a management tool designed to ensure the right material in the right place at the right time, reducing the need for inventory). The requirement of the suggested standard for preventative actions will if applied will bring about other savings for instance by improving OEE (Overall Equipment Efficiency) simply by making sure that production machinery is correctly set up and operating correctly thereby reducing line stoppages for corrective actions and repairs.

Paul Harper
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2. Creative thinking: the Integrated Management System will provide better and more in-depth information to managers, quality assessors, designers et al, the process and system approaches will cause them to see the bigger picture more clearly and together with the need for continual improvement will bring about an environment which encourages innovation. 3. Add Value: an IMS embracing these standards will be well received by suppliers and buyers improving Kerry Foods image and perceived value, demonstrating Kerry Foods are forward thinking, innovative, trustworthy and set exceptionally high standards. 4. Improved understanding and communication: the introduction of an IMS will require the cooperation of everyone from the most junior employer to Top Management as the scheme is rolled out and the training programs developed and delivered all will obtain a better understanding and the need for Quality this may cause the demise of the resentment amongst certain sectors of the business where the Quality Assurance Department is viewed with disdain and encourage the communication of issues concerning quality, safety and waste to be better directed to the appropriate department/manager. 5. Effective: one system to cover all standards reducing bureaucracy and enabling an environment where a factual approach to decision making becomes a viable option as awareness and availability of information increases. Other benefits of adopting the IMS would include: A standardized international food safety system, approved by the Global Food Safety Initiative (GFSI) designed to protect the health of all consumers Provides the ability to sell product to the growing number of major national and international retail chains that require this certification Ensures food safety for the consumer, and reduces the risks associated with costly recalls A documented internal food safety process that is required to receive certification provide a systematic, proactive, ongoing approach to food safety that ensures food safety standards are met and maintained.

Paul Harper
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U502 - Management System

CONCLUSIONS AND RECCOMENDATIONS The food supply chain on which we all rely extends farther and goes deeper than ever before. For example, a piece of fruit grown in Africa can be on grocery store shelves in Europe within 24 hours of harvest. Coffee from Asia wends its way to shops across Europe. Lamb from New Zealand is enjoyed across the UK and North America. With such a far-reaching supply chain in place, carrying such an essential product as food, having the proper security and safety measures in place is vital. A robust, independently verified food management system could make a real difference by improving Kerry Foods' flexibility, readiness and ultimate viability in the face of an everchanging risk environment. This is particularly true when set against the backdrop of current economic pressures, when there is a temptation to cut corners. Under the circumstances, the need for food safety has never been greater. Good progress has been made by the industry to date. It was concern over potential risks in the food supply chain that prompted the creation of a number of early food safety sector initiatives and standards, including HACCP and the BRC and IFS retailer driven food manufacturing standards along with EuroGAP for the pre-farm gate sector. But it was not until the publication of international food safety management system standard ISO 22000 in 2005 that there was a single standard covering the entire food supply chain. "The food safety landscape is very straight-forward," says Steve Mould, worldwide quality management systems manager at Kraft Foods. "Food safety standards need to be recognized by the GFSI but ISO 22000 could not on its own. ISO 22000 gives lists of PRP topics to consider, but because it covers the whole of the food industry, it does not include

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PRPs for each step: otherwise it would need to be the size of an encyclopaedia. Something else was needed to fill the gap and give ISO 22000 the support that was needed." Publicly Available Specification (PAS) 220 is a new complementary standard to ISO 22000. It has been designed to address the technical limitations around PRPs in ISO 22000 for the food manufacturing sector. PAS 220:2008 Prerequisite programmes on food safety for food manufacturing was developed by BSI and sponsored by Danone, Kraft Foods, Nestl and Unilever through the Confederation of the Food and Drink Industries of the EU (CIAA). Other stakeholders involved in the development process included representatives from the Food and Drink Federation (FDF), McDonald's, General Mills Europe, and certification bodies. FSSC 22000 (Food Safety System Certification 22000) is a new global food safety scheme which brings together ISO 22000 and PAS 220 certification for the food manufacturing industry. "While existing schemes have a reasonable consistency of requirements, there was no true consistency of auditing and certification," says Mould, who was also the technical author of PAS 220. "Food safety schemes on the market today tend to be owned by stakeholders in the food supply chain. By moving to an independently owned certification scheme, we saw that we would be able to minimize system and audit variations based on geography, sector and customer, and reduce barriers to trade across the chain." "An independent board comprising representatives from manufacturing, retail, consumer organizations and other international bodies is responsible for the content and management of FSSC 22000," says Cor Groenveld, chairman of the Foundation for Food Safety (FFS), the not-for-profit organization responsible for the scheme. "The scheme's independent ownership should make it attractive to all stakeholders." The scheme has been designed to meet the GFSI's benchmarking requirements and a decision by the GFSI board will take place in May 2009 as to whether FSSC 22000 is accepted as an approved certification scheme. Once the GFSI approves FSSC 22000, Paul Whitehouse, quality manager at Unilever and another member of the PAS 220 steering group, believes one impact on the food

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manufacturing industry could be cost savings and new opportunities for SMEs and niche producers. "Food safety is a destination; there are a number of routes and you choose one that best suits your organization," he says. "Given that companies are already used to working with ISO standards and are familiar with the risk and management systems based approach adopted by ISO 22000 and PAS 220, they may find it easier to align with these than with other standards." "A GFSI-approved FSSC 22000 scheme could bring more food manufacturers into the fold, as well as encouraging other interested parties along the food chain to adopt similar PRP-based approaches," says Joy Franks, the global product manager at BSI responsible for food safety. "The majority of the ISO 22000 certificates that have been issued to date come from outside the manufacturing sector," she says. "The driver was never there for manufacturers because of the PRP issues that are so central to their requirements. This has been addressed by ISO 22000 and PAS 220 . "We are heading towards a truly international food safety standard, one that covers the whole of the supply chain," says Mould. "This will make the supply chain safer. If every aspect of the food industry adopted one international standard and operated under the same management system structure, then we will have more consistency and enhanced safety throughout the supply chain. With ISO 22000 and PAS 220 coming together under FSSC 22000, we're in a position for this to happen and we may well see a revolution in the food industry." The author believes that Kerry Foods should become leaders and adopt ISO2200, PAS220 and integrate this with their EMS (environmental management system) ISO14001. With seven of the worlds leading supermarket chains already signed up to it and this sector representing 80% of Kerrys sales (sales by volume 80% of current production supplied directly to supermarkets and 20% to other outlets) it would be foolhardy not to follow their lead. Adopting the suggested IMS (integrated management system) will undoubtedly set Kerry Foods apart showing them to be innovative and really caring about standards, this will

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have a knock on effect: no doubt when buyers are looking for suppliers these will be credentials that will put Kerrys at the forefront. In order to install the suggested IMS a mountain needs to be climbed fortunately though will can do this in small manageable stages. The author first suggests that the IMS is phased in: 1st Ready meals production (high risk) this area is potentially the most dangerous for food safety issues to occur the introduction here will have an immediate beneficial effect. 2nd ingredient storage the next link in the downward chain and logically the next to adopt the new standards. 3rd Factory Kitchen another high risk area supplying the ingredient stores and production area 4th Sleeving potentially the lowest risk area but 100% within Kerrys control. 5th Goods inwards, by leaving this to last we give ourselves time to explain the changes to our suppliers and for them to adapt to any new standard we require or to find other suitable alternative suppliers if the existing prove unable to meet any new criteria. Now we need a plan of action to bring about the change: 1. Determine goals and timescale; when do we want the project to start and by when do we want to gain certification? 2. Appoint/select a project manager and create a steering team from top management 3. Steering team assigns task and food safety teams and creates Gantt chart identifying time-lines for these teams 4. Design and implement employee training Having completed these stages and communicated the change to every employer it will then be necessary to ensure compliance with all aspects of ISO22000 and ISO14001 the

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latter already exists so efforts need only be concentrated on the former. There is a requirement in ISO22000 for PRPs (prerequisite programs) these relate to such things as good hygiene practice, storage etc. All of these are covered in the standard PAS220: PAS 220:2008 specifies requirements for establishing, implementing and maintaining prerequisite programmes (PRP) to assist in controlling food safety hazards. It applies to all organizations, regardless of size or complexity. It also applies to all who are involved in the manufacturing step of the food chain and wish to implement PRP in such a way as to address the requirements specified in ISO 22000. PAS 220:2008 is not designed or intended for use in other parts of the food supply chain. Food manufacturing operations are diverse and not all of the requirements specified in this PAS apply to an individual establishment or process. PAS 220:2008 specifies detailed requirements to be considered including: a. Construction and layout of buildings and associated utilities b. Layout of premises, including workspace and employee facilities c. Supplies of air, water, energy and other utilities d. Supporting services, including waste and sewage disposal e. Suitability of equipment and its accessibility for cleaning, maintenance and preventive maintenance f. Management of purchased materials g. Measures for the prevention of cross contamination h. Cleaning and sanitizing i. Pest control j. Personnel hygiene. It also adds other aspects that are considered relevant to manufacturing operations: Rework Product recall procedures Warehousing Product information and consumer awareness Food defence, biovigilance and bioterrorism.

Paul Harper
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As such PAS220 also provides a template for the implementation of ISO22000 and therefore the basis of a suitable plan of actions. The project activities will use principles of the P-D-C-A cycle. P = Plan - Define the tasks, D = Do- Complete the tasks, C = Check - Examine the results of the tasks, A = Act - Take actions based on results of the completed tasks. Essentially we should end up with 36 key elements which will drive Kerry towards ISO22000 certification and the installation of the authors suggested IMS:

1. Demonstrate a commitment to food safety 2. .Document the organizations food safety policy 3. Support the establishment of a complete FSMS. 4. Define the scope and boundaries of FSMS. 5. Plan the establishment of the organizations FSMS. 6. Document FSMS responsibilities and authorities. 7. Appoint food safety team leader. 8. Appoint food safety team. 9. Establish food safety communication arrangements. 10.Provide the resources that your FSMS needs. 11.Provide competent food safety personnel. 12.Provide training and awareness programs. 13.Provide infrastructure and work environment. 14.Establish our prerequisite programs (PRPs). 15.Perform a food safety hazard analysis 16.Document food safety hazards. 17.Specify acceptable hazard levels. 18.Assess food safety hazards. 19.Select measures to control hazards. 20.Establish operational pre-requisite programs 21.Prepare HACCP plan

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22.Establish a product lot traceability system. 23.Develop food safety emergency procedures. 24.Identify and correct nonconforming products. 25.Evaluate data and take corrective actions 26.Control products that are potentially unsafe. 27.Control your monitoring and measuring methods. 28.Validate food safety control measures 29.Verify FSMS has been implemented. 30.Evaluate the results of verification activities. 31.Perform regular internal audits of processes. 32.Carry out food safety management reviews. 33.Document unique FSMS. 34.Control food safety management documents. 35.Control food safety management records 36.Continually update and improve the FSMS The author strongly recommends that this suggestion is adopted at the earliest opportunity and in its; entirety.

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APPENDIX HACCP Hazard analysis and critical control points a method of identifying risks within the food chain and establishing controls to monitor and eliminate those risks GAP Analysis an overview of a business which compares where they are now against where they would like to be the gap Deming W Edwards Deming 1900 1993 statistician, lecturer, author and consultant probably best known for his work in Japan from 1950 onwards where working with top management established many of the principles of modern quality management GFSI Global Food Safety Initiative designed to encourage conformity and highest standards worldwide within the food industry Lean Manufacturing a process to manage production using the minimum number of operators, maximum OEE and minimal materials whilst controlling waste Giveaway refres to the excess weight in a nominal weight product which is not charged for. Just in Time is defined as: an inventory strategy that strives to improve a business's return on investment by reducing in-process inventory and associated carrying costs.

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BRC British Retail Consortium a not for profit organisation representing 90% of British retailers. Amongst the many duties it performs it imposes manufacturing standards and checks for compliance. IFS a European food safety standard.

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