Introduction
These Good Manufacturing Practices directly support the Quality
Management Standard by providing technical guidance to all sites.
Good Manufacturing Practices (GMP), the fundamentals for quality and food
safety, are the foundation for our manufacturing and distribution operations.
For successful implementation of these GMP, management commitment is
critical as well as continual reinforcement of these requirements.
Actions shall be taken to eliminate root causes of GMP non-compliance.
GMP 01 to 10 are those requirements needed to meet CS Manufacturing Best
Practice (MBP) level 2.
GMP 11 Warehousing, Distribution and Transport are those requirements
needed to meet CS MBP level 3.
TheseGMP are applicable to all food ingredient and packaging stores and
warehouses, manufacturing operations, finished goods warehouses and
transport.
A scientific team has produced these GMP based on experience and global
standards including:
1. Codex Alimentarius Commission – Recommended International Code of
Practice-General Principles of Food Hygiene;
2. National Food Processors Association – Supplier Audits For Excellence
(NFPA-SAFE); and
3. British Retail Consortium (BRC) Global Standard.
Index
Page
GMP GMP and Food Safety Training 6
01 GMP Induction Requirements
GMP On Going Training Requirements
Training Documentation Requirements
GMP Basic Hygiene – Personnel 7
02 General Requirements
Medical Requirements
Protective Clothing
Hand Washing
No Smoking Policy
Responsibilities of personnel entering food handling areas
GMP Prevention of Physical Contamination 11
03 Prevention and control of Physical Contaminant Sources
General Requirements
Metal
Glass, Ceramics, Porcelain and other hard brittle materials
Wood
Detection and Removal of Physical Contaminants
General Requirements Metal Detectors Sieves Magnets
Electronic Inspection/Sorting Manual
Inspection/Sorting
GMP Factory Housekeeping 17
04 General Requirements
The 4S Process – Sort
The 4S Process – Set in Order
The 4S Process – Shine
The 4S Process – Standardise
GMP Cleaning 19
05 Cleaning Schedules
Management of Cleaning
Cleaning Methods
Cleaning Records
Cleaning Equipment
Control of Cleaning Chemicals
GMP Infestation and Pest Management 22
06 General Requirements
Prevention of Infestation and Exclusion of Pests
Monitoring and Pest Control General Requirements Insects
Rodents Birds Inspections Treatments and Control of
GMP 01 GMP and Food Safety Training
Management Goal: Only individuals who are competent in GMP and
food safety appropriate to their position can enter and work in our
manufacturing, packing and storage areas.
1.1 GMP Induction Requirements
1.1.1 All personnel including temporary and contract staff shall
receive induction training in good manufacturing practices and
food safety appropriate to their position.
1.1.2 All personnel employed in food handling areas shall receive
induction training in the following areas:
• GMP 02 Basic Hygiene – Personnel
• GMP 03 Prevention of Physical Contamination
• GMP 04 Factory Housekeeping
• GMP 05 Cleaning
• GMP 06 Infestation and Pest Management
• GMP 07 Buildings
• GMP 08 Staff Facilities
• GMP 09 Plant and Equipment
• Food safety (HACCP Code of Practice)
• GLP as appropriate
1.1.3 This training shall be completed before personnel commence
work.
1.2 GMP On Going Training Requirements
1.2.1 On going training in GMP and food safety shall be provided as
part of a planned and managed program for all personnel,
including temporary and contract staff.
This training shall assure effectiveness of GMP application and
will address:
• Changes in technology and products
• Updates to CS GMP
• Changes in regulations
1.2.2 GMP and Food Safety refresher training shall be completed no
less than every three years.
1.3 Training Documentation Requirements
1.3.1 Training records shall be kept for all personnel to include details
of training received, date, result and the trainer’s name.
1.3.2 The effectiveness of training shall be regularly reviewed. Where
appropriate, the content material, method of training and the
trainer’s techniques shall be revised.
GMP 02: Basic Hygiene – Personnel
Food Safety Hazards and Quality Risks: personnel can cause -
microbiological/disease transmission
- foreign matter e.g. hair, wound dressings, medications, jewellery
Management Goal: all personnel are fully trained and consistently
apply good basic hygiene.
Requirements for personal hygiene facilities are detailed in GMP08
Staff Facilities.
2.1 General Requirements
2.1.1 All employees shall maintain a high standard of personal
hygiene.
2.1.2 Staff recruitment shall be conditional on personal cleanliness.
2.1.3 Agreement with the site personal hygiene rules shall be a
condition of employment.
2.1.4 Visitors, tourists and contractors shall be subject to the site
rules for personal hygiene.
Tourists are at a site for recreational purposes, the company
does not specifically invite them and they are predominantly
fee paying.
2.1.5 Personal hygiene rules shall be issued during site induction
training and shall be clearly documented and displayed at
relevant locations on site.
2.2 Medical Requirements
2.2.1 Appropriate medical screening/checking shall be a condition of
employment for those employed in food handling roles and
required of everyone entering food handling areas.
2.2.2 Medical conditions that may lead to food contamination or the
spread of disease (e.g. diarrhoea, vomiting or food borne
infections, skin infections, ear/eye/eyelid infections) by the food
handler or someone that they have been in close contact with
shall be reported to an appropriate manager/supervisor before
entering the workplace.
2.2.3 Reporting of medical conditions that may lead to food
contamination or the spread of disease shall be included in the
employment contract for those employed in food handling
areas.
2.2.4 Suitable controls e.g. health check questionnaire shall be in
place for all visitors entering manufacturing, packing and
storage areas.
2.2.5 Access to manufacturing areas shall not be permitted to personnel who have
reported illness until medical clearance has been given by an appropriate
authority.
2.2.6 Blue coloured, waterproof, metal detectable first aid dressings
shall be provided for use in manufacturing, packing and storage
areas.
2.2.7 All skin related problems shall be adequately covered. The
covering shall provide a waterproof barrier between the skin
condition and any product or product contact surface.
2.2.8 The site shall have a policy to manage the use of personal
medication in the manufacturing environment. Personal
medication shall not be permitted in food handling areas unless
medically necessary and formally approved by site
management.
2.3 Protective Clothing
2.3.1 Company issued protective clothing conforming to the following
requirements shall be provided for all personnel entering food
handling areas.
This includes protective clothing, hair coverings, gloves and
footwear.
• Protective clothing shall cover all personal clothing above the
knee, cover up to the neck and up to the wrist and be fastened
at all times.
• There shall be no external pockets.
• There shall be no buttons or easily removed fastenings.
Ideally use metal poppers/snaps.
• All head hair shall be completely covered. This includes facial
hair to be covered by beard covers/snoods.
• Earplugs should be joined, brightly coloured and be metal
detectable where appropriate.
• Gloves shall be appropriate for the purpose
• Company issue protective shoes shall be worn.
2.3.2 Dedicated protective clothing shall be provided and used by
personnel working in areas where cross contamination potential
exists e.g. laboratories, allergen-free areas, effluent plant. This
protective clothing shall be visually identifiable to its designated
area e.g. colour coding. Appropriate changing procedures shall
be implemented.
2.3.3 All protective clothing shall be cleaned regularly, maintained in
good condition and replaced when required.
2.3.4 Disposable protective items (e.g. gloves, head coverings and
snoods), where used, shall be replaced as often as necessary to
maintain function and cleanliness.
2.3.5 Procedures for wearing protective clothing shall be
implemented to minimise the potential for product
contamination (e.g. head covering put on first and removed
last).
2.3.6 One-piece overalls (work wear) shall be removed prior to entering the toilet.
Requirements for Confectionery, Food and Gum Factories
2.3.7 Company issued protective clothing, including shoes shall not
be removed from site or taken home.
2.3.8 Home laundry is not acceptable.
Suitable, professional laundering facilities shall be provided
and managed either by the site or by an approved external
contractor. Minimum wash temperature 750C.
Requirements for Beverage Factories
2.3.9 Factories that currently meet or are working towards the
requirements of 2.3.7 and 2.3.8 shall continue.
2.3.10 All other beverage factories shall implement procedures to
assure the risk associated with home laundering is minimised.
All company issued protective clothing, including shoes shall
be kept clean.
2.4 Hand Washing
2.4.1 Everybody shall thoroughly wash their hands:
• On entry to all manufacturing areas.
• Before commencing work.
• At an appropriate frequency during the day in the place of
work.
• After handling raw, unprocessed ingredients, e.g. milk, cocoa
beans.
• After handling allergens or allergen containing products.
• After cleaning and sanitising plant or equipment.
• When hands are soiled.
• After eating and drinking or sensory tasting.
• After visiting the toilets.
• After handling refuse and rubbish.
• After coughing or sneezing.
• After smoking.
2.4.2 Potable water shall be used for hand washing in food
processing, handling, packaging and storage areas; provided
on demand at adequate temperature (greater than 45ºC) and
pressure.
2.4.3 Non-perfumed, liquid bactericidal soap shall be provided at all
hand wash stations.
2.5 No Smoking Policy
2.5.1 Smoking, the use of snuff and the chewing of tobacco shall be
prohibited in all manufacturing, packing and storage areas.
2.5.2 The carrying of smoking materials, snuff and chewing tobacco shall be
prohibited in all manufacturing, packaging, storage and warehouse areas.
2.5.3 Clear signs shall be displayed:
• To display the “NO SMOKING” Policy.
• To define the specific areas where smoking is permitted.
These areas shall be kept clean and tidy.
• To direct personnel to wash their hands on leaving the specific
smoking areas
• To display reminders e.g. ‘No Smoking Permitted”
2.5.4 Smoking, the use of snuff and the chewing of tobacco shall only
be permitted in designated areas.
2.6 Responsibilities of personnel entering food handling areas
2.6.1 No jewellery or watches shall be worn except one plain wedding
ring or band.
One emergency ‘Medic-Alert’ tag necklace may be worn with
management authorisation but shall be kept inside clothing.
2.6.2 No hair slides/hair clips shall be worn.
2.6.3 Finger nails shall be short and clean. False nails, nail extensions
and nail polish shall not be worn. Finger nails shall not be bitten.
2.6.4 False eye lashes shall not be worn.
2.6.5 Strong fragrances, e.g. strong perfumes and lotions, shall not be
used.
2.6.6 Food and drink (including chewing gum) shall not be consumed
in food handling or changing areas. Permitted exceptions are
the provision of water for personal welfare (in approved
locations and areas) and product tasting for quality control
purposes. Exceptions shall take place in designated areas and
be formally managed to minimise the potential for product
contamination.
GMP 03: Prevention of Physical Contamination
Food Safety and Quality Risks:
Contamination of product with harmful physical contaminants:
- metal fragments especially hard and sharp e.g. detached nuts and
bolts, misuse of metal rejected product, damaged tools, build up
of metal on magnets, metal shavings (swarf), weld splatter,
staples
- glass, ceramics, porcelain and other hard brittle materials
- hard plastic e.g. from metal detection test pieces, pens
- wood e.g. from wooden pallets, wooden handled utensils
Contamination of product with objectionable physical contaminants:
e.g.
- flexible plastic, string and paper from ingredient bags
- broom bristles
- external environment (flaking paint, dust, dirt)
- conveyor belt fibres and rubber seal parts
- lubricating oil and grease
- fingernails and hair
- wound dressings (e.g. elasto/sticking plasters)
Management Goal: all sources of potential physical contamination have
been identified and eliminated. Where it is not possible to eliminate,
control and monitoring systems are in place and working.
3.1 Prevention and Control of Physical Contaminant Sources
3.1.1 General Requirements
3.1.1.1 Ingredients shall be specified to be free of physical
contaminants/foreign matter e.g. metal, glass, stones, string
etc.
3.1.1.2 Ingredients shall be received in non-glass packaging. Where
this is not possible e.g. some chemicals then the glass shall
be protected to prevent shattering in the event of breakage
e.g. plastic shroud.
3.1.1.3 Ingredients shall be stored in closed/sealed, clean
containers/original packaging when not being used.
3.1.1.4 Following any ingredient sampling all containers shall be
resealed properly and clearly labelled as having been
sampled/resealed and not tampered with.
3.1.1.5 Food and packaging materials shall be stored off the floor and
not be in direct contact with walls to prevent:
• Contamination of the outer packaging from floor contact
• Damage.
3.1.1.6 Part used or unused packaging shall be adequately protected from
contamination.
3.1.1.7 Following any sampling of packaging it shall be resealed
properly and clearly labelled as having been
sampled/resealed and not tampered with.
3.1.1.8 All trays, bins etc. of unwrapped product, WIP, rework shall
be covered.
3.1.1.9 Food containers shall only be used for food products.
3.1.1.10 Pre-formed packaging containers (e.g. bottles or cans) shall
be rotated 360 degrees and rinsed with treated water or
ionised air at an appropriate pressure prior to filling.
3.1.1.11 Production machinery and conveyors shall be covered where
there is potential for product contamination. Covers shall be
easily removable for cleaning.
3.1.1.12 Process vessels shall be closed/covered when not in use.
3.1.1.13 Intake pipes into bulk tanks and storage vessels shall have a
captive blanking cap.
3.1.1.14 All open-ended pipework (including loading points for bulk
silos, dispensing points for bulk containers and flexi-hoses)
shall be capped when not in use. Capping devices shall be
stored securely and in a manner to prevent contamination
when not in use.
3.1.1.15 Maintenance practices shall include accounting for all loose
items including metal parts during preventive/breakdown
maintenance.
3.1.1.16 Only one-piece, metal detectable, company issued pens shall
be used in exposed product handling areas.
3.1.1.17 Only robust, company issued knives shall be used for
opening ingredient bags.
3.1.1.18 Knives shall not be the snap-off bladed type, nor have
wooden handles. If the handles are not metal they should
contain metallic components to assist in detection if
damaged.
3.1.1.19 Knives used in manufacturing, packing and storage areas
shall, where appropriate, be attached and secured to a chain
so that if dropped they will not fall onto any surface or into
any process vessel.
3.1.1.20 Knives, utensils and tools shall be subject to regular
inspection to allow replacement prior to undue wear and
potential breakage.
3.1.1.21 Tools and equipment that contain bristles e.g. brooms shall be well
maintained and replaced at an appropriate frequency before the bristles fall
out. Where the bristles are used on food contact surfaces or for food contact
the bristles shall be of a contrasting colour to the food so that they are
visibly detectable.
3.1.1.22 Buildings, facilities and equipment shall be well maintained
and clean, as per the requirements of GMP 04, GMP05,
GMP07, GMP08 and GMP09 to prevent contaminants e.g.
flaking paint, dust and dirt, conveyor belt fibres, rubber seal
parts.
3.1.1.23 Sources of physical contaminants from personnel shall be
controlled as per the requirements of GMP02 Basic Hygiene –
Personnel.
3.1.2 Metal
3. 1.2.1 Paper clips, staples, drawing pins, and other extraneous
small metal items shall be prohibited from manufacturing,
packing and storage areas. Any proposed new items shall be
subject to a risk assessment.
3. 1.2.2 Can openers used in manufacturing environments shall be
maintained to minimise the potential for generation of metal
fragments.
3. 1.2.3 Maintenance personnel shall ensure production machinery
metal wear parts are correctly adjusted, all fixings are
secure and places where insecure metal parts might fall into
product are reduced to a minimum.
3. 1.2.4 All maintenance and construction work in exposed product
handling areas that create metal fragments e.g. drilling,
cutting of metal, welding shall have control procedures in
place to ensure that areas where maintenance is taking
place are screened, or work takes place out of
manufacturing hours and areas cleaned on completion. All
tools and debris shall be removed on completion of
maintenance work.
3.1.3 Glass, Ceramics, Porcelain and other hard/brittle materials
3.1.3.1 Glass, ceramics, porcelain and other hard/brittle materials
shall be minimized within the manufacturing, packing and
storage areas.
3.1.3.2 Ideally, with the exception of light fittings and glass
packaging on glass bottling lines there should be no glass
items anywhere in the manufacturing, packing and storage
areas.
3.1.3.3 Covered lights or shatterproof glass lamps shall be used in
food handling areas. See GMP 07 Buildings, for lighting
requirements.
3.1.3.4 Where glass does exist procedures will be in place to prevent contamination
and deal with any incidents. Where substantial risks do exist, replacement
should be sought. In process glass e.g. flow meter gauges/sight glasses etc.
where if broken would contaminate the product, shall be eliminated.
3.1.3.5 Glass Register:
All glass (with the exception of glass packaging on glass
bottling lines) in the manufacturing, storage and warehouse
environment shall be risk assessed and, if considered to be
allowable, listed on a register.
3.1.3.6 Regular inspections shall be carried out at an appropriate
frequency (based upon a risk assessment) to confirm
integrity of the items on the list.
Appropriate corrective actions shall be taken in the event
glass loss or breakage is found.
3.1.3.7 The glass register list shall be kept up to date to reflect any
changes.
3.1.3.8 Glass breakage procedures shall be in place for managing
the breakage of glass.
3.1.3.9 For all food and beverage factories the procedure for
managing the breakage of glass shall include:
• Immediate notification and reporting of glass breakage.
• Requirements for stopping the production line (where
appropriate).
• Identification and isolation of all potentially affected
product and segregation of potential contamination zones.
• Glass clearance and disposal requirements.
• Glass clearance equipment shall be dedicated.
• Pre-restart cleaning and checking requirements.
• Restart shall be authorized.
• Requirements for record keeping.
• Samples of broken glass shall be clearly labelled and
retained for future identification purposes.
3.1.3.10 For beverage factories with glass bottling lines the
procedure for managing the breakage of glass packaging
e.g. burst bottles /capper collapse shall include:
• Glass clearance requirements.
• Broken glass (cullet) handling and disposal.
• Details of the glass packaging to be discarded ‘either side’
of the break.
3.1.4 Wood
3.1.4.1 The use of wood for utensils and tools shall be prohibited in
product handling areas.
3.1.4.2 The use of wood in manufacturing, packing and storage areas is not
permitted but there are exceptions for existing infrastructures that includes
existing major equipment e.g. wooden cooling tunnels, wooden floors and
roofing timbers etc.
3.1.4.3 The use of plastic/metal pallets in the manufacturing areas is
preferred. Plastic/metal pallets are highly recommended in
areas where products are exposed.
3.1.4.4 When introducing/using wooden pallets in the manufacturing
areas controls shall be in place to avoid cross contamination
from wood splinters and prevent the introduction of
preservatives, paint, pesticides, and microbial contamination
(due to wet pallets).
3.2 Detection and Removal of Physical contaminants
3.2.1 General Requirements
3.2.1.1 All devices for detecting and removing physical contaminants
shall be appropriately designed and installed on line to
maximise their effectiveness.
3.2.1.2 The frequency of checks carried out on devices to ensure
optimum operation shall be determined through risk
assessment and shall be appropriate to the product line
speed. Where appropriate, calibration procedures shall be
maintained.
3.2.1.3 Equipment shall be routinely monitored to confirm operation
to the required standard.
3.2.1.4 Any reject material shall be isolated and controlled to prevent
product re-contamination. The rejected product shall be
disposed of safely. Root cause of contamination shall be
addressed.
3.2.2 Metal Detectors
3.2.2.1 Equipment designed to detect and reject metal shall be
located at the most effective but technically feasible step in
the process.
3.2.2.2 Metal detectors, where technically feasible, shall be capable
of detecting ferrous, non-ferrous and stainless steel metals.
3.2.2.3 Operating limits shall be established for metal detectors.
Where the metal detector is identified as a Critical Control
Point (CCP) the limits shall be the criteria that separate safe
from unsafe.
3.2.2.4 Metal detector operation shall be checked regularly at the
appropriate line/product flow speed.
3.2.2.5 Metal detectors shall be associated with a rejection
mechanism that is correctly synchronised to reject the
contaminated product.
3.2.2.6 Rejected product shall be directed into a locked container.
FoodIssue 02 Issue Date: November 2005 Page 16 of 44
3.2.3 Sieves
3.2.3.1 Based on a risk assessment of the process, sieves shall be of
the smallest practicable mesh size. Metal sieve meshes shall
be metal detectable.
3.2.3.2 Sieves shall be subject to routine cleaning and integrity
checks. Both activities shall be recorded. Sieves that are
damaged or broken shall not be used.
3.2.3.3 Sieve meshes/screens shall be stored securely to prevent
damage when not in use.
3.2.4 Magnets
3.2.4.1 Magnets, where used, shall be subject to routine strength
checks. These procedures and their results shall be recorded.
3.2.4.2 Magnets shall be checked and cleaned routinely at an
appropriate frequency.
3.2.5 Electronic inspection/sorting
3.2.5.1 Appropriate electronic inspection/sorting equipment shall be
installed and operating correctly, according to the Cadbury
Schweppes requirement.
Examples:
-all confectionery products shall pass through a working metal
detector. The metal detector shall be located as near to the
end of the production line as possible, ideally on wrapped
product.
-all washed returnable glass bottles shall pass through empty
bottle inspection.
3.2.5.2 Where electronic inspection/sorting equipment is associated
with a rejection device the reject mechanism shall be
routinely monitored to confirm it is synchronised correctly to
reject the contaminated product.
3.2.6 Manual Sorting and Inspection
3.2.6.1 Manual sorting and inspection shall be carried out under well-
lit conditions, against a background that contrasts in colour
with the product and the potential contaminant.
GMP 04 Factory Housekeeping
Food Safety Hazards and Quality Risks:
- microbiological contamination
- foreign matter/product carryover/taint/allergen carryover
- infestation and damage by insects, rodents and birds
Management Goal: to have a functional, visually organised workplace.
4.1 General Requirements
4.1.1 The 4S process (Sort, Set in Order, Shine and Standardise) shall
be applied to all manufacturing, packing, storage and ancillary
areas (including waste handling areas).
4.2 The 4S Process – Sort
4.2.1 All unnecessary items shall be removed from the
manufacturing, packing, storage and ancillary areas (including
waste handling areas).
4.2.2 This sorting principle shall be applied to everything, including
production equipment, tools, ingredients, packaging, WIP,
rework and finished products.
4.3 The 4S Process – Set in Order
4.3.1 All necessary items shall be arranged so that they are easy to
find and to put away.
4.3.2 All necessary items shall be arranged and stored to ensure they
are:
• Readily available when required by the user.
• Maintained in a clean condition.
• Protected from damage.
• Sufficiently secure to prevent inappropriate or inadvertent
use.
4.3.3 All necessary items shall be returned to their designated
storage location when not in use.
4.3.4 All necessary items shall be stored off the floor and away from
walls to allow for cleaning, prevent pest harbourage and to
allow inspection for pest activity.
4.3.5 Incompatible materials, e.g. high risk/ low risk, food materials/
packaging material, quarantined/standard products, shall be
stored sufficiently separated to prevent contamination, taint or
soiling.
4.3.6 Storage conditions shall be maintained to minimise product
deterioration and to prevent the growth of micro-organisms.
4.3.7 An effective stock rotation system shall be in place to ensure raw materials and
products are used on the basis of ‘First Expiry, First Out’ (FEFO). The system
shall ensure that the first expiry stock is the first out.
4.3.8 Stock levels of raw materials and products shall be effectively
managed to prevent excessive quantities being held on site
and to ensure use within a reasonable time.
4.3.9 Stock levels of non-food items shall be effectively managed to
prevent excessive quantities being held on site.
4.3.10 All materials and products shall be clearly identifiable at all
times.
4.3.11 A system shall be in place to ensure the status of materials is
evident at any time e.g. available for use, quarantined,
restricted use etc.
4.3.12 Dispensing equipment e.g. scoops and spatulas shall be
dedicated to specific ingredients where appropriate.
4.3.13 Waste shall not be permitted to accumulate in storage and
manufacturing areas and shall be clearly segregated from
product.
4.3.14 External waste containers and compactors shall be managed
in a manner as to minimise the risk of creating food safety
hazards.
4.4 The 4S Process – Shine
4.4.1 The requirements for Shine are detailed in GMP05 Cleaning.
4.4.2 Cleaning and organising shall be part of the daily work habits
for all personnel i.e. a ‘Clean and Organise As You Go’
philosophy is evident.
4.4.3 Root causes of dust and dirt in the workplace shall be
addressed.
4.4.4 The factory environment shall be inspected on a regular basis
for leaking valves and dripping ceilings. Root causes of leaks
and drips shall be addressed.
4.5 The 4S Process – Standardise
4.5.1 Regular (at least monthly) audits shall be used to maintain
Sort, Shine and Set in Order i.e. to maintain cleanliness and
orderliness.
4.5.2 Audits shall be used to determine compliance with the
requirements of this GMP, the effectiveness of the measures
taken and to identify opportunities for improvement.
4.5.3 Records of compliance and effective corrective action resulting
from audit non-conformances shall be maintained. Corrective
actions shall address root causes.
GMP 05 Cleaning
Food Safety Hazards and Quality Risks: poor or incorrect cleaning can
affect product causing
- microbiological contamination
- residue carryover
- product taints
- chemical contamination leading to mouth and gastrointestinal tract
burning
- allergen cross contamination
- pest contamination
Management Goal: a cleaning plan is in place and working that assures
all cleaning is effective and cleanliness standards are met.
5.1 Cleaning Schedules
5.1.1 The site shall establish and maintain formal cleaning schedules
for the internal and external factory environment, storage
areas, process equipment and associated ancillary areas
(including waste handling areas, drains and overhead
structures).
5.1.2 Cleaning schedules shall include:
• Cleaning methods
• Frequency (daily, weekly, monthly etc.)
• Responsibilities
5.2 Management of Cleaning
5.2.1 Cleaning activities shall be planned and managed.
5.2.2 Adequate resources shall be allocated to cleaning activities.
5.2.3 Cleaning shall form part of the manufacturing schedule to
ensure sufficient time is allocated for the completion of the
required tasks.
5.2.4 Personnel involved in chemical handling/preparation and
cleaning activities shall be adequately trained and supervised to
ensure satisfactory completion of the task.
5.2.5 The site, buildings and equipment shall be maintained in a
suitably clean condition at all times.
5.2.6 The manufacturing, packing, storage and ancillary areas
(including waste handling areas, drains and overhead
structures) shall be free of dirt, dust and cobwebs.
5.2.7 Cleaning shall be part of the daily work habits for all personnel
i.e. a ‘Clean As You Go’ philosophy is evident.
5.2.8 Root causes of dust and dirt in the workplace shall be
addressed.
5.2.9 Satisfactory completion of cleaning shall be verified using
appropriate methods. Verification methods may include:
• Visual inspection
• Testing to confirm removal of cleaning chemical residues
• Swabbing using conventional microbiological swabs or rapid
methods e.g. swabbing based on ATP bioluminescence
technology.
5.2.10 Where there is potential for product contamination resulting
from a failure to clean correctly, the results of verification shall
be used to confirm cleanliness before using the equipment.
5.2.11 Cleaning schedules and methods shall be reviewed at an
appropriate frequency to confirm continued suitability.
5.2.12 Regular audits of hygiene and cleaning standards shall take
place.
5.2.13 Formal hand back procedures shall be in place to ensure that
all plant, equipment etc. is effectively cleaned and the
cleaning is verified prior to the commencement of
manufacturing following maintenance work.
5.3 Cleaning Methods
5.3.1 Requirements for cleaning shall be detailed in documented
cleaning instructions, which shall be maintained as current and
readily available to personnel involved in cleaning.
Instructions shall include:
• Frequency of cleaning
• Equipment disassembly and re-assembly instructions
• Cleaning methodology
• Cleaning equipment and tools to be used, including
instructions for care and maintenance
• Cleaning chemicals and concentration
• Contact times and temperatures
• Critical Inspection points
• Environmental, health and safety requirements as per the CS
Environmental, Health and Safety Standards.
5.3.2 Cleaning methods shall be validated, where appropriate,
including validation and approval of any automatic dosing
systems used on site.
5.3.3 Cleaning chemicals shall be alternated/rotated where
microbiological resistance to sanitisers/disinfectant products
may develop over time.
5.3.4 Potable water shall be used for the cleaning of all product
contact surfaces.
5.3.5 “Clean” tools, utensils and equipment shall be stored and segregated from
“dirty” tools, utensils and equipment to prevent re-soiling and contamination.
5.3.6 Cleaning of utensils and portable equipment shall be adequately
segregated from manufacturing activities.
5.3.7 Ingredients, packaging and food products shall be protected to
prevent contamination during cleaning activities.
5.4 Cleaning Records
5.4.1 Cleaning activities shall be fully and accurately recorded,
including all critical cleaning steps, results of verification, name
and date.
5.4.2 Where heat is part of a clean in place (CIP) process suitable
temperature recording devices will be part of the design (e.g.
chart recorders) and records shall be kept.
5.4.3 Cleaning records shall be reviewed and authorised by
supervisory personnel.
5.4.4 Cleaning records shall be retained for the same period as
manufacturing records.
5.5 Cleaning Equipment
5.5.1 Cleaning equipment shall be suitable for its intended use and
capable of being adequately cleaned and maintained.
5.5.2 All cleaning equipment (including floor scrubbers and vacuum
cleaners) shall be subject to the same cleaning requirements as
production equipment.
5.5.3 Cleaning equipment shall be stored in a clean condition and in
an appropriate manner to minimise the potential for
deterioration and contamination.
5.5.4 Cleaning equipment used for the following areas shall be colour
coded and/or distinguishable, dedicated to the allocated tasks
and stored separately from cleaning equipment used for other
tasks.
• Product contact surfaces
• Allergen handling (as appropriate)
• Non product contact surfaces
• Toilet facilities
5.6 Control of Cleaning Chemicals
5.6.1 All cleaning chemicals shall be approved for use in food and
beverage industries and shall be suitable for the intended
application.
5.6.2 Cleaning chemicals shall be used in accordance with the
manufacturer’s instructions.
5.6.3 All cleaning chemicals shall be accurately labelled and stored
securely.
GMP 06 Infestation and Pest Management
Major Pest Groups: rodents, flying and crawling insects (including
larvae), spiders, birds, other vertebrates.
Food Safety Hazards and Quality Risks: carriers of microbiological
contamination (including disease & viruses), potential physical
contaminant, damage of building structure, destruction of stored
goods.
Management Goal: To have a pest free environment.
6.1 General Requirements
6.1.1 There shall be an on-site employee accountable for pest
management.
6.1.2 Responsibility for pest management shall be defined,
documented and communicated to site personnel.
6.1.3 The pest management program shall include any off-site areas
under the control of site management.
6.1.4 Pest control specialists shall have proven experience, training
and appropriate qualifications.
6.1.5 Prevention of pest infestation and exclusion of pests shall be
the primary objective of pest management.
6.1.6 Pest infestation is unacceptable and the objectives of pest
control shall be to get rid of any infestation, and monitoring to
provide an early warning of developing problems.
6.1.7 No material shall be accepted if it is known, or is found to be
infested.
6.1.8 Materials more susceptible to pest infestation shall be inspected
(preferably off site) for signs of infestation.
6.1.9 Any infestation on site shall be addressed immediately. Infested material shall
not be used in manufacturing operations and shall be removed from the
manufacturing/storage facility. Infestations of building structures, surfaces and
machinery shall be treated, cleaned and sanitised. Manufacturing shall not re-
commence until the effectiveness of infestation cleaning has been confirmed by
inspection.
6.2 Prevention of Infestation and Exclusion of Pests
6.2.1 A clear zone (0.5 m) to prevent pest harbourage shall be
maintained on the external perimeter of all walls.
6.2.2 Buildings shall be designed and maintained to prevent entry
of pests and eliminate pest harbourages. See GMP 07
Buildings for requirements.
6.2.3 External doors shall be closed when not in use.
6.2.4 External doors required to be open for ventilation shall be
screened and the screens shall be closed when not in use.
6.2.5 A clear zone (0.5 m) to prevent pest harbourage shall be
maintained on the internal perimeter of all the walls in
manufacturing and storage areas.
6.2.6 The site external and internal environment, storage facilities,
equipment and associated ancillary areas (including waste
handling areas, drainage and overheads) shall be kept clean
and free of product accumulations to prevent pest infestation.
See requirements for Cleaning GMP 05.
6.3 Monitoring and Pest Control
6.3.1 General Requirements
6.3.1.1 The location of all traps, bait stations and UV Electronic Fly
Killers (EFK) shall be decided by the pest control specialist.
The location and design of bait stations should not create a
risk of cross contamination to the product stream.
6.3.1.2 All traps, bait stations and UV EFK shall be numbered.
6.3.2 Insects
6.3.2.1 Insect traps shall be specified by the pest control specialist
and maintained in good condition.
6.3.2.2 Pheromone trap lures shall be changed monthly and moth
catches shall be recorded.
6.3.2.3 U.V. Light Traps (Electric Fly Killers – EFKs) catch trays shall
be emptied regularly. The species and quantities shall be
recorded. The ultra-violet light source shall be replaced at
least annually in the Spring.
6.3.2.4 If additional lighting is to be installed the pest control specialist shall be
consulted for the impact on current EFKs. Where necessary either light source
shall be relocated.
6.3.3 Rodents
6.3.3.1 Rodent traps and bait stations shall be specified by the pest
control specialist and maintained in good condition. They shall
be secure and tamper resistant. Poisons, including toxic
rodent bait shall not be applied inside food manufacturing
areas.
6.3.3.2 All rodent bait stations shall be fixed in position.
6.3.3.3 External bait stations shall be positioned to keep pests away
from building entrances.
6.3.3.4 Bait stations shall be inspected at a frequency sufficient to
ensure the effectiveness of the bait.
6.3.4 Birds
6.3.4.1 The feeding of birds on site shall be prohibited.
6.3.4.2 The pest control specialist shall specify controls for bird
activity and bird infestation.
See GMP07 Buildings for structural methods to prevent birds
perching and nesting.
6.3.5 Inspections
6.3.5.1 The site shall be inspected at least twelve (12) times per year
to ensure no pest infestations have arisen or to take
appropriate actions if they have. This shall include checking
for bird activity.
6.3.5.2 Traps, bait boxes and UV EFK shall be inspected at least
twelve (12) times per year or more frequently if necessary.
6.3.5.3 If pest activity is found or reported appropriate action shall be
taken and there shall be three “clear” follow-up inspections.
6.3.6 Treatments and Control of Chemicals
6.3.6.1 Application of pesticides shall be according to documented
procedures, not create a risk of cross contamination to the
product stream and be performed by a certified applicator.
6.3.6.2 All chemicals used for pest control shall be approved for use
in food and drink industries in the country of use and the
country(s) in which product shall be sold.
6.3.6.3 All chemicals used for pest control measures, shall be accurately labelled and
stored securely away from raw materials.
6.3.7 Record Keeping
6.3.7.1 An accurate location drawing/map of all traps, bait stations,
UV EFK shall be maintained.
6.3.7.2 Records of site inspections shall include observations and a
summary of all actions taken.
6.3.7.3 Inspection records for all traps, bait boxes and UV EFK’s that
include catches and pest activity shall be maintained.
6.3.7.4 Records of sightings shall be maintained.
6.3.7.5 Records of pesticide usage shall include trade name, active
ingredient, quantity used, areas treated and date(s) of
treatment.
6.3.7.6 Material Safety Data Sheets (MSDS) shall be available for
pesticides applied or used.
6.4 Pest Control Contract
The pest control contract shall include:
6.4.1 Company policy towards infestation highlighting areas that
have a zero tolerance i.e. evidence of infestation will halt
manufacturing.
6.4.2 Geographical scope of contract coverage including any off-site
areas.
6.4.3 Pest species to be included in the contract including specific
criteria relating to the time period in which eradication or
control is expected to be achieved.
e.g. Rodents – eradication 42 days
6.4.4 Frequency of service visits including: - routine inspections
- follow-up inspections when pest activity is found or reported
- call out visits when a problem arises.
6.4.5 Assessment of levels of pest activity to establish the
effectiveness of proofing and to generate appropriate
corrective action.
6.4.6 Minimum pest control qualification or technical experience of
service personnel.
6.4.7 Pesticides approved for use on site.
6.4.8 Records to be maintained.
GMP 07: Buildings
Food Safety Hazards and Quality Risks: poor design and maintenance
of buildings can cause - microbiological contamination e.g. leaking
valves, dripping ceilings - foreign matter/tainting of product e.g. flaking
paint, poor ventilation - infestation and damage by insects, rodents
and birds.
Management Goal: provide a clean, secure working environment, and
to minimise the risk of product spoilage and product damage or
contamination from buildings.
7.1 General Requirements
Responsibility for design and maintenance of buildings shall be
defined, documented and communicated to site personnel.
7.2 Exterior
FoodIssue Building
02 Issue Date:and Site Requirements
November 2005 Page 27 of 44
7.3 Building Layout Requirements
7.3.1 The process flow from receiving to shipping shall be designed
to prevent contamination.
7.3.2 Building design shall allow for clear segregation between
raw/unprocessed materials and processed/finished products.
Consideration shall be given to control of allergens.
7.3.3 There shall be separate access points for personnel, goods
received and product shipping.
7.3.4 Building layout shall allow sufficient working and storage
space to allow all operations to be carried out under hygienic
conditions.
7.3.5 Equipment wash facilities shall be readily accessible and
present no contamination risk to the product.
7.3.6 Routes for product shall flow from raw materials through
processing to warehouses with minimal potential for
backtracking or crossover in all new builds.
7.4 Building Standards
7.4.1 General Requirements
7.4.1.1 Buildings shall be weatherproof, structurally sound and
constructed from materials that are appropriate for the
purpose of intended use.
7.4.1.2 Buildings and overhead structures shall be well maintained.
7.4.1.3 Openings in the building structure e.g. for pipe work, cable
runs, trunking or equipment shall be fully sealed.
7.4.1.4 Buildings shall be constructed to minimise potential pest entry
and harbourage. Where buildings are susceptible to rodent
entry, the building structure shall be suitably reinforced at
known or likely points of entry.
7.4.1.5 Local pest issues/threats shall be taken into consideration in
designing/refurbishing buildings for food manufacturing.
7.4.1.6 Void spaces above, below or adjoining ceilings/floors/walls
shall be accessible for inspection and pest treatment.
7.4.1.7 All internal building surfaces in materials handling,
manufacturing and packing areas shall be suitable, non-toxic,
odour-free, impervious and easily cleaned.
7.4.1.8 The use of wood in manufacturing, packing and storage areas is not permitted
but there are exceptions for existing infrastructures that include existing major
equipment e.g. wooden cooling tunnels,
wooden floors and roofing timbers.
7.4.1.9 In new builds, wall/floor junctions, corners and structural
supports shall be coved.
7.4.2 Walls
7.4.2.1 Walls shall be light coloured.
7.4.2.2 Walls shall be designed to prevent dirt harbourage.
7.4.2.3 Cavity walls or walls constructed from layers of soft materials
should be avoided because they are potential pest
harbourages.
7.4.2.4 Where wall-cladding materials are used, installation shall
ensure good contact with the underlying wall and all joints
(including expansion joints) shall be fully sealed.
7.4.2.5 Protective guards shall be fitted where wall/structural damage
may occur.
7.4.3 Floors and Walkways
7.4.3.1 Floors shall be sufficiently robust to withstand the working
activities and be absent from damage.
7.4.3.2 Mezzanine floors/walkways, stairs and cross-conveyor bridges
shall be constructed from suitable materials, sealed and have
adequate side walls to contain any contamination.
7.4.3.3 Floors shall be installed and managed to prevent the presence
of standing water
7.4.3.4 Floors shall be installed with adequate slope and run direct to
drain. Where high and low risk areas exist, slope must run
from high to low risk.
7.4.4 Ceilings and Overheads
7.4.4.1 Ceilings and overhead structures shall be designed and
constructed to prevent accumulation of dirt and to facilitate
access for cleaning.
7.4.4.2 Ceilings and overhead structures shall be free of excessive dust, dirt and
cobwebs.
7.4.5 Windows
7.4.5.1 For new builds there shall be no windows in manufacturing,
packing or storage areas.
7.4.5.2 Window glass shall be protected to retain fragments in the
event of breakage (e.g. adhesive plastic film).
7.4.5.3 Windows and skylights not required for ventilation shall be
non-opening or sealed shut.
7.4.5.4 Windows required for ventilation shall be screened against
flying insect entry. This proofing shall be non-opening or
sealed shut.
7.4.6 Doors
7.4.6.1 Doors shall be close fitting and adequately proofed to prevent
pest entry.
7.4.6.2 Other than for emergency purposes only, external doors shall
not open directly into manufacturing, packing and storage
areas.
7.4.6.3 External doors e.g. goods receipt, goods shipping in regular
use shall be automatically operated or self-closing.
7.4.6.4 Where doors are required to be opened for ventilation
purposes, screening shall be in place to prevent pest entry.
7.4.6.5 Gaps around dock levelling platforms shall be adequately
proofed to prevent pest entry.
7.4.7 Ventilation Requirements
7.4.7.1 Adequate ventilation shall be provided to minimise
condensation or excessive dust and prevent mould growth.
7.4.7.2 Ventilation systems shall be designed so that air moves from
"clean” to “dirty" areas and is not drawn back into clean
manufacturing areas.
7.4.7.3 Air filters shall be changed at an appropriate frequency to
ensure their efficacy and so that they do not become a source
of contamination. Special requirements apply to positively
pressurised and filtered aseptic rooms.
7.4.7.4 Ventilation shall ensure products are protected from flavour
tainting when volatile flavour components are present in the
atmosphere (e.g. mint in confectionery).
7.4.7.5 All vents that can be opened shall be screened to prevent pest entry.
7.4.8 Lighting
7.4.8.1 Lighting levels shall ensure that product, process and
manufacturing monitoring and inspection activities can be
performed effectively.
7.4.8.2 All lights, including those in ancillary areas and Electric Fly
Killer (EFK) units, shall be shatterproof or protected by a
cover to retain any breakages.
7.4.8.3 If additional lighting is to be installed the pest control
specialist shall be consulted for the impact on current EFKs.
Where necessary either light source shall be relocated.
7.4.8.4 Lights shall be positioned so that they do not create a
breakage contamination hazard during lifting operations
involving fork lift trucks (FLT).
7.4.8.5 Replacement of lights in manufacturing areas shall be done
using a strict glass handling procedure and if possible
outside manufacturing hours.
7.4.9 Drainage
7.4.9.1 Drains shall be of an adequate size for the purpose, free
flowing and fitted with traps to prevent problems with
backflow and odours. Where high and low risk areas exist,
drains must run from high to low risk.
7.4.9.2 Where gully drains are covered, the covers shall be easily
removable for cleaning. Open drains from laboratories shall
not pass through manufacturing areas.
7.4.9.3 Drains shall be accessible for cleaning and maintenance.
7.4.9.4 The siting of equipment shall not interfere with drainage.
Fixed machinery shall not be positioned directly over a drain.
7.4.10 Services
7.4.10.1 Potable water shall be provided for all
product/manufacturing related activities, including hand
washing and cleaning product contact surfaces; provided on
demand at an adequate temperature and pressure.
7.4.10.2 Steam and ice that come into contact with product shall
meet potable water standards.
7.4.10.3 Cabletrays (wireways) in which cables are secured with close
fitting ties shall not be used in dusty environments because
they cannot be kept clean.
7.4.10.4 Electrical control panels shall be either fitted to walls, or mounted away
from the wall to allow access for inspection and cleaning.
7.4.10.5 Waste handling areas shall be adequately designed and kept
clean.
7.4.11 Equipment Wash Facilities
7.4.11.1 An adequate number of equipment wash areas shall be
provided at appropriate locations.
7.4.11.2 Equipment wash areas shall be designed to prevent cleaned
equipment becoming re-soiled.
7.4.11.3 Separate sinks/basins shall be provided for equipment wash
and hand washing.
7.4.11.4 Where hoses are provided, the water pressure at the point of
discharge shall prevent atomisation. Where applicable,
facilities shall be provided to prevent hose nozzles coming
into contact with the floor.
7.4.11.5 For new builds, equipment wash areas shall be accessible
without having to exit the building.
GMP 08: Staff Facilities
Food Safety Hazards and Quality Risks: poor design and maintenance
of staff facilities can cause - microbiological/disease transmission
- foreign matter e.g. personnel meals/drinks
Management Goal: provide clean, hygienic personnel facilities and to
minimise the risk of product spoilage or contamination from personnel.
8. 1 Toilets
8.1.1 Toilets shall be of hygienic design and provided in accordance
with statutory requirements and be adequately ventilated.
8.1.2 Toilets shall not open directly into product handling or storage
areas.
8.1.3 Toilets/washrooms shall be fitted with self closing doors.
8.1.4 One-piece overalls (work wear) shall be removed prior to
entering the toilet. Facilities to handle work wear must be
provided.
8.2 Hand Wash Facilities
8.2.1 Hand wash facilities shall be of hygienic design and provided
in accordance with statutory requirements.
8.2.2 Wash-hand basins shall have non-hand operated water supply.
8.2.3 Hand washing water shall be provided on demand at an
adequate temperature (great than 450C) and pressure.
Separate hot and cold hand operated taps are not acceptable.
8.2.4 An adequate number of liquid soap dispensers, shall be
provided at all hand wash stations (see GMP 02 for soap
requirements).
8.2.5 Clean re-usable reel fed roller towels or paper towels for hand
drying and waste receptacles shall be provided (if the waste
receptacles are lidded, the lid shall be foot operated).
8.2.6 Hand washing facilities shall be provided at the entrance to all
food handling areas.
8.2.7 Hand washing facilities shall be adequate for the volume of
personnel entering at peak times e.g. start of shift/end of
breaks.
8.2.8 Hand washing facilities shall be located so that, personnel are
guided to walk past them on entering the food handling areas.
8.2.9 Additional hand washing or sanitizing facilities shall be
provided as appropriate, at workstations.
8.2.10 Hand basins shall be used exclusively for hand washing. Where in
close proximity to equipment-wash sinks, wash-hand basins shall be
protected by distance and/or screening and shall not be used for
cleaning equipment.
8.2.11 Notices reminding staff of hand washing requirements must be
posted in each toilet, cubicle (stalls), by the urinal area, in
break/canteen areas and on every entrance door to the
manufacturing area.
8.3 Staff Changing Facilities
8.3.1 A cupboard or locker shall be provided for the secure storage
of personal items. Personal clothing needs to be segregated
from company issued protective clothing. Lockers shall be
clear of the floor to facilitate cleaning and have a sloping top.
8.3.2 Where high-risk operations exist there will be additional
designated changing facilities for donning of appropriate
company issued protective clothing.
Where company issued protective clothing, including shoes shall not
be removed from site or taken home:
8.3.3 Designated changing facilities shall be provided prior to entry
to manufacturing and packing areas and where appropriate
storage areas for the donning of company issued protective
clothing that meets the requirements of GMP 02 Basic Hygiene
– Personnel.
8.3.4 Where appropriate changing facilities will be sited to allow
personnel access to manufacturing, packing and storage areas
without passing via external areas.
8.4 Canteen/Catering Facilities
8.4.1 Facilities shall be provided for personnel for taking meals and
refreshment, either in a canteen or designated area away from
manufacturing and storage operations.
8.4.2 Where it is necessary to provide drinks in manufacturing
areas, water drinking fountains shall be installed in a
designated area away from manufacturing activities.
Appropriate bins shall be provided for the disposal of paper
cups.
8.4.3 Canteens, catering facilities and break rooms shall be
maintained to a hygienic standard.
8.4.4 Break rooms located in manufacturing areas shall not be used
for preparing or taking meals and refreshments, other than
water from drinking fountains. Appropriate bins shall be
provided for the disposal of paper cups.
GMP 09: Plant and Equipment
Food Safety Hazards and Quality Risks: poor design and maintenance
of equipment can cause - microbiological contamination e.g. leaking
water jackets - foreign matter/tainting of product e.g. flaking paint
Management Goal: to minimise the risk of product spoilage and
product damage or contamination from plant and equipment.
9.1 General Requirements
9.1.1 All process plant and machinery used shall be suitable for its
intended use and capable of being adequately cleaned and
maintained.
9.1.2 Machinery, equipment, pipelines, holding vessels, tanks and
silos shall be designed to prevent the accumulation and
retention of product and debris and shall, where appropriate, be
free draining/emptying.
9.1.3 Product contact surfaces shall be smooth and impervious, and
materials used shall not pose a risk of product contamination or
tainting.
9.1.4 Machine guarding shall be designed to minimise collection of
dust and debris, be easy to inspect, clean, open and close and
shall facilitate easy access to the equipment.
9.1.5 Process and manufacturing equipment and machinery shall be
installed off the ground and with sufficient distance away from
walls and other equipment to allow proper cleaning.
9.1.6 All hoses, taps, cross-connections or similar sources of possible
contamination of the water supply shall be equipped with anti-
backflow devices.
9.1.7 The design of plant and equipment shall be evaluated as part of
a HACCP study to confirm it does not create food safety risks.
GMP 101 Allergen2 Management
Food Safety Hazards and Quality Risks: - product incorrectly containing
allergenic materials
- incorrect labelling of product for the presence/absence of allergens
Management Goal: allergen risks as defined in the CS global lists 3 are
clearly understood and actively managed.
10.1 Allergen Management Objectives
10.1.1 The site objectives for allergen management shall be clearly
defined and communicated to all personnel and contractors.
Visitors and tourists shall be made aware of any specific site
objectives that relate to them.
The site shall:
10.1.2 Maintain knowledge on what allergens are handled by the site
through access to current, up to date information from
suppliers on what ingredients including processing aids,
packaging4 and food products contain an allergen.
10.1.3 Where a decision has been made during the IPM process that it
is unavoidable to introduce allergens that are not already
present on site through activities such as new product
development, new ingredients, new packaging and new food
products, the introduction of allergens shall be managed.
10.1.4 Ensure personnel understand risks to allergen sensitive
consumers and appropriate precautionary measures to avoid
allergen cross contact.
10.1.5 Correctly label products for the presence of allergens in
accordance with local legislation and/or standards set out by
CS Global Regulatory Affairs.
10.1.6 Take all reasonable care to minimise cross contact when using
shared processing equipment to handle/manufacture
ingredients and products that contain an allergen and those
that do not.
10.1.7 Avoid cross contact when ingredients and products that
contain an allergen and those that do not are
handled/manufactured in close proximity, but NOT on shared
processing equipment.
10.1.8 Avoid cross contact between CS ingredients/products used or
manufactured on site and allergens that could be introduced
from other sources e.g. food in site canteens, staff shops,
vending machines or brought to site by personnel.
10.1.9 Where approval has been given to produce and label products
as “free from X allergen(s)”, they shall be manufactured and
packed strictly in accordance with the requirements set out by
CS.
10.2 HACCP and Risk Assessment
10.2.1 The HACCP system shall meet the requirements of the
Cadbury Schweppes HACCP Code of Practice.
10.2.2 The scope of the entire HACCP system shall include allergen
hazards.
10.2.3 For the risk assessment of allergens the HACCP team shall
include personnel that are:
• aware of the CS List of allergens and intolerances.
• have knowledge of the specific allergens relevant to their
ingredients, packaging, processing aids and food products.
• have training in appropriate precautionary measures to
avoid allergen cross contact.
• have knowledge of allergen regulations of markets where the
products are distributed.
10.2.4 For the risk assessment, the HACCP team shall use up to date
information from suppliers as to what ingredients, packaging,
processing aids and food products contain an allergen.
10.2.5 Where the HACCP study identifies allergen hazards, those
hazards shall be controlled, prevented or eliminated to achieve
the site objectives for allergen management.
10.2.6 Consideration shall be given to the risk of cross contact
between those ingredients and products that contain an
allergen and those that do not by reviewing the flow of all
materials (ingredients, packaging, product and rework) from
the moment they are received at the manufacturing site,
through storage, manufacturing, packing, finished product
holding, and shipping. The personnel flow shall also be
reviewed by considering employee movement through the
site, including change rooms, washrooms and lunchrooms. The
location of hand wash facilities should also be considered.
Measures shall be taken to control, prevent or eliminate any
identified risk of cross contact.
10.2.7 The HACCP team shall communicate the output of the HACCP study to
Regulatory Affairs and Marketing who will determine the impact on labelling
and marketing.
10.3 Control and Prevention of Cross Contact
10.3.1 Processing aids that do not contain an allergen or do not
originate from sources that contain an allergen are preferred.
10.3.2 Oils that contain an allergen e.g. peanut oil shall not be used
as a lubricant.
10.3.3 Best practice is to rework composite products e.g. blended
concentrates, panned gums, chocolate coated products,
where a component of the product contains an allergen into
the same product i.e. like into like.
10.3.4 All reasonable precautions shall be taken during cleaning to
minimise cross contact, thereby demonstrating due diligence.
Cleaning shall NOT be considered an appropriate control
measure to avoid cross contact, unless the cleaning method
has been scientifically validated and approved for use by
your regional representative on the CS Allergen Working
Group. Evidence shall be available to show that the validation
was scientifically based.
10.3.5 Satisfactory completion of cleaning shall be verified using
appropriate methods.
10.3.6 Measures shall be implemented to avoid cross contact from
food provided in canteen/ catering facilities, vending
machines or brought onto site by personnel. Personnel shall
be aware that no food shall be taken into the manufacturing,
packing or storage areas.
10.3.7 Corrective actions to be taken if product contact with an
undeclared allergen is suspected shall be identified, be
effective and clearly documented.
10.3.8 Records of all corrective actions taken shall be maintained.
10.3.9 Standard operating procedures shall be followed to minimise
cross contact when using shared processing equipment to
handle/manufacture ingredients and products that contain an
allergen and those that do not e.g. products that do not
contain an allergen shall be scheduled to run first post
cleaning and sanitisation.
To avoid cross contact between ingredients and products that contain
an allergen and those that do not when they are
handled/manufactured in close proximity, but not on shared processing
equipment the following measures shall be implemented:
10.3.10 Dedicated tools and equipment e.g. rework containers, trays, food bins,
utensils, knives and weighing equipment shall be used on lines utilising
allergens.
10.3.11 Dedicated cleaning equipment shall be used on lines utilising
allergens.
10.3.12 Dedicated maintenance equipment shall be used on lines
utilising allergens.
In addition, where personnel and clothing are identified as a potential
carrier of allergens the following measures shall be implemented:
10.3.13 Dedicated company issued protective clothing shall be
provided and used by personnel.
10.3.14 Protective clothing shall meet the requirements of GMP 02
and shall not be removed from site or taken home.
10.3.15 The protective clothing shall be segregated for laundering.
Laundry facilities shall meet the requirements of 2.3.8.
10.3.16 Procedures shall be in place to prevent personnel moving
between processing areas without taking all precautionary
measures e.g. changing protective clothing, hand washing
etc.
10.3.17 Procedures shall be in place to prevent maintenance
personnel moving between processing areas without taking
all precautionary measures e.g. changing protective clothing,
hand washing etc.
10.4 Control of Product Labelling
10.4.1 To prevent the incorrect labelling of product for the
presence/absence of allergens, standard operating
procedures shall be followed to ensure that correct packaging
material/labels are used for all products.
10.4.2 Records of packaging used shall be kept to ensure
traceability of correct labelling.
Note: All materials and products shall be clearly identifiable at all
times.
10.5 Training
10.5.1 Induction training for GMP and Food Safety shall include an
awareness of allergens and their controls.
1
This GMP details the requirements for the active management of
allergens in manufacturing, packing, labelling and storage areas.
It does not address the protection of food Industry personnel, visitors,
tourists or contractors who are susceptible to allergens. See the
Environmental, Health and Safety Standards.
It does not address allergen management with suppliers and new
product introductions.
2
Food allergens are any substances, but commonly proteins, which
may cause “allergic reactions” of the immune system in some
individuals.
Allergens are naturally present in food or ingredients or occur through
cross contact, or in some cases, are produced by processing, cooking
or digestion. Common examples of potential allergens include milk,
wheat, peanut, tree nuts and shellfish. These foods are perfectly safe
for the majority of people but may cause a reaction in some
individuals.
Allergic reactions can occur on exposure to trace amounts of the
allergen, resulting in a range of mild to severe symptoms affecting the
skin, respiratory tract, intestinal tract, or multiple systems. In severe
cases, a life-threatening allergic reaction (anaphylaxis) may occur.
Packaging may contain an allergen or intolerances such as latex
(natural or synthetic).
GMP 11 Storage, Warehousing, Receipt, Despatch and Transport
Scope: Raw materials/ingredients, work in progress, intermediate and
finished products herein after called food products; and food packaging
material.
Food Safety Hazards and Quality Risks: Poor or incorrect product
handling during receipt, storage, handling, despatch and
transportation can affect product causing:
- Microbiological, chemical and physical contamination
- Microbiological growth
- Product damage
- Product deterioration
- Allergen cross contamination
- Product taint
- Loss of product identity and traceability
- Insect infestations
Management Goal: receipt, storage, handling, despatch and
transportation of all materials within the scope of this document are
managed to provide protection from damage, contamination or
deterioration.
11.1 General Requirements
11.1.1 Responsibility for storage and transport (including
warehousing, receipt and despatch) shall be defined and
documented.
11.1.2 Storage and warehouse personnel shall be appropriately
trained and competent (see GMP 01 GMP and Food Safety
Training).
11.1.3 Clearly defined procedures shall be in place for storage,
warehousing, receipt and despatch and transport of materials.
11.1.4 Security shall be in place to prevent unauthorised access to all
materials during storage and transportation.
11.1.5 Food products and food packaging material shall be stored and
transported to prevent contamination, deterioration and
damage. This may include
• temperature variation
• moisture
• sunlight
• air
• pests
• contamination with foreign odours and materials
• excess weight from top loading
• poor stacking.
FoodIssue 02 Issue Date: November 2005 Page 41 of 44
11.1.6 Clearly defined procedures outlining the requirements for the
repacking of finished products shall be in place.
Finished product shall only be repacked if:
• Primary packaging is intact, not contaminated, damaged,
defective or suspect in any way.
• Only secondary or tertiary packaging is replaced.
• Product identification and traceability information from the
original packaging is transferred to the replacement
packaging.
• The repacking operation shall not result in contamination
within/of the secondary or tertiary pack.
The following shall NOT be repacked:
• Any finished products in contact with broken glass,
including where glass fragments have been found within the
outer pack.
• Any finished products from wet/damp outer packs where
there is potential for corrosion (cans) or mould growth.
11.1.7 Personnel working in storage and distribution shall be
provided with company issued clothing and shall maintain a
clean and tidy appearance.
11.1.8 Personnel hygiene standards required for different types of
storage and warehouse facilities shall be determined through
risk assessment, using GMP 02 Basic Hygiene – Personnel as
a point of reference. The requirements that are determined
shall be formally documented.
11.1.9 Storage facilities shall be operated in accordance with CS
GMP requirements for building standards, maintenance,
housekeeping, cleaning, waste management and pest control
(see GMP 03, 04, 05, 06, 07 and 08).
11.1.10 Vehicles used for transportation shall be constructed of
materials that will not contaminate or damage food products
or food packaging material and shall offer adequate
protection from tampering or unauthorised access.
11.1.11 Agricultural commodity items e.g. cocoa beans shall be
adequately covered during transportation, where necessary.
11.1.12 Vehicles for transportation of all non-agricultural food
products and food packaging material shall be fully enclosed
and capable of maintaining the conditions for the product
being transported.
11.1.13 Forklift trucks used inside buildings shall not generate fumes and particulates
that may contaminate food product, food packaging and protective clothing.
11.2 Material Handling
11.2.1 Liquid food products shall not be stored above dry food
materials or packaging materials.
11.2.2 Where food products and food packaging materials are
required to be stored or transported under defined
temperature or relative humidity conditions, effective controls
shall be in place, shall be formally monitored/recorded at an
appropriate frequency and timely action taken to restore
control in the event of failure.
11.2.3 All food products and food packaging materials shall be
protected against contamination and damage during loading
and unloading operations.
11.2.4 All food products and food packaging materials shall be stored
off the floor and a minimum of 0.5m from walls.
11.3 Segregation
11.3.1 Incompatible materials shall be sufficiently segregated during
storage, warehousing, transport, receipt and despatch to
prevent contamination, tainting or soiling. Incompatible
materials include:
• high risk/low risk food products e.g. raw cocoa beans vs
cocoa powder
• food materials/packaging material
• quarantined/standard products
• food/strongly flavoured food products
• food/ noxious, toxic or odorous non food materials
• food/ products intended for animal consumption
• food/ waste.
11.3.2 The potential for inadvertent cross contact between materials
that contain allergens during storage and transportation shall
be managed as per GMP 10: Allergen Management.
11.3.3 Effective systems shall be in place for the identification and
management of quarantined product and non-conforming
products.
11.4 Stock Control
11.4.1 Stock shall be used within shelf life.
11.4.2 Stock shall be rotated on a FEFO (First Expiry First Out) basis.
11.4.3 Stocks of materials that are obsolete shall be disposed of in a timely manner.
11.5 Identification and Traceability
11.5.1 All food products and food packaging material shall be clearly
identified with - material name - origin e.g. name of ingredient
manufacturer/supplier - batch/lot identity
- date code/shelf life/expiration date (as appropriate for
packaging materials)
- specific conditions for storage, where appropriate.
11.5.2 Systems shall be in place to ensure there is traceability of food
products and packaging from point of receipt to despatch.
11.5.3 The integrity of the traceability system shall be periodically
verified. This verification shall be fully documented.
11.6 Palletisation
11.6.1 Pallets shall be suitable for purpose, clean and in good repair.
Wooden pallets shall not be treated with preservatives that
may contaminate food products.
11.6.2 Goods stacked on pallets shall be secured before moving
(strapping, stretch wrap) to prevent spillage or damage.
11.6.3 Palletised goods for dispatch shall be stacked in accordance
with defined palletisation specifications or in a manner to
maintain pallet stability and prevent damage during transit.
11.7 Receipt of Food Products and Food Packaging
11.7.1 All delivered materials shall be subject to checks prior to
acceptance and unloading:
Confirmation that the materials correspond with those detailed
on the documentation from the supplier.
Confirmation that the materials have originated from:
- An approved supplier
- An approved third party manufacturer or contract packer
- A Cadbury Schweppes manufacturing site
Vehicle/Material inspection
- Materials have not been subject to unauthorised access or
tampering
- The exterior of the vehicle is clean
- The interior of the vehicle is clean and hygienic, in good
condition and free from sources of contamination and odours
- There is no evidence of pest activity
- The materials on the vehicle are compatible with the Cadbury
Schweppes products being delivered
- Materials are undamaged and have sufficient shelf life
remaining
- Materials are identified with material name, origin and lot/batch.
For bulk tanker deliveries checks shall also be completed to verify:
- That vehicle has a current cleaning certificate
- That all access points (manways, discharge points) and hose
compartments are securely sealed and the seal numbers corresponds
with those on the delivery documentation/cleaning certificate.
Where applicable, Certificates of Conformance or Certificates of
Analysis shall be confirmed as acceptable.
11.8 Despatch of Food Products
11.8.1 Vehicles, including shipping containers shall be inspected
before loading to ensure the:
- Exterior of the vehicle is clean and well presented
- Interior of the vehicle is clean and hygienic, in good condition
and free from sources of contamination and odours.
11.8.2 For bulk tankers, checks shall be completed to ensure:
- All access points (manways, discharge points) and hose
compartments are securely sealed
- The vehicle has a current cleaning certificate detailing the
seal numbers for the seals in place on the vehicle.
11.8.3 Products for despatch shall be undamaged and in good
condition.
11.8.4 Vehicles shall be loaded and protected to prevent damage or
instability during transit.
11.8.5 Post loading, vehicles shall be sealed with numbered seals to
prevent unauthorised access to the load and to provide tamper
evidence. Seal numbers shall be recorded on despatch
documentation sent to the recipient.
11.9 Record Keeping
11.9.1 Details of all materials received shall be recorded, including
material name, quantities, supplier/origin and batch/lot
identity.
11.9.2 Details of all materials despatched shall be recorded, including
- material name/number
- quantities despatched
- source/origin
- batch/lot identity
- Date coding/shelf life expiry date
- Seal serial numbers, where applicable
- Time of despatch
- Destination/ customer details
- Vehicle details