SFCA, SFCR, ECCP, GMP, third party certifications?
Quick intro, I've been here a while and lurking while wading my way through benchmarking FSSC 22000 at my hand batch co-pack kitchen in Quebec. We have been manufacturing in our current location with the current name since 2004, but my partner had previous food manufacturing companies the all totalling 50 years of safe food manufacturing. My 500K (read little) revenue company custom manufacturers for multiple companies. We do not do wholesale, we simply manufacturer. HACCP is my introduction to ISO Standards, and in 2017 we began the process of benchmarking FSSC 22000 for when the certifications came into play so that we'd be above and on top of the situation. We are a 6 man company, so we are working on the KISS principle as our end goal, but in order to get there, we have to do it piecemeal with priority placed on food safety risk assessments.
Now, the rules and regs are kicking into gear and I am curious how to deal with this. This is threatening to get pricy. and we're only a little place.
One of our client's distributors has a purchaser who requested a HACCP certification for sale into their chain. Now, maybe I went about this the wrong way, but I assumed that if I successfully benchmarked the highest food safety standard, life would be simpler. I like simple. This isn't simple. Today we learned that we have to have an ECCP in order to ship into the US. Now, having read through what is required for said document, we comply with it in principle, my question is, do I need a completely written ECCP in addition to the written FSSC 22000 documents or is a simple policy statement that addresses exports, in addition to the FSSC sufficient, or what?
How do your companies deal with requests for certifications for standards that are similar to the ones you've benchmarked? Do I simply bring in an auditor every time someone requests them?
Thanks for any thoughts and comments.
Ok, can i ask what type of product so I can help-----different commodities have different requirements
HACCP certification is it's own and FSSC is a GFSI that is above and beyond a basic HACCP plan, so no need to worry there. Are you in fact FSSC certified? Have gone through an audit?
these are the requirements for an ECCP----you should already have all of this info, just not located all in one place, so you can do this yourself (please don't hire any more consultants----they rules are too new and I'm worried people are going to start hanging out shingles calling themselves consultants when they haven't a clue what they are talking about)
Elements of the ECCP planYou should incorporate all elements of the export certification controls into your food safety system. The ECCP plan is the written document that describes the procedures and processes used to capture the following elements:
- Preventive control plan (PCP)
- Exporting roles and responsibilities
- Foreign country requirements
- Product compliance
- Certification
- Eligibility lists
- Inspections and fees
- Traceability
We make several different types of products, mostly sauces, condiments, cocktail mixes, dried spice mixes, etc. So far, all processed products, but we expect to expand, the ECCP is new to me.
Our consultant is an ISO Standard specialist, a 3-party auditor herself, she has been training me and helping me focus, but her background is NOT food, so it's complicated. She has been working with me since 2017. I got lucky.
We are not certified, we have as of now run three mock audits, I'm getting close to being able to nail our mock audit, but there it always something that is missed. The employees are always my weakest link. My head chef doesn't like to collect data. I am expecting to pass our next mock audit which is scheduled for June. My biggest lack right now are written documents that will stand up to scrutiny. (That's assuming the recent release of FSSC 22000:2018 doesn't kill me.)
We do custom manufacturing, so our customers tend to be little guys who are ordering less than 3 pallets of product at a time. We are four employees, 11 in the kitchen during peak manufacturing/harvest, but still just a little place. We have been working with the CFIA to ensure that we get it right, too, because we are a feeder pipeline for an ever expanding network of local farmers.
The trickiest part of our documentation is that we are the manufacturer. We do not own the brands, someone else does. IOW, tons of work writing individual processes. Also, because we do not own the brands, our sales are ALL at the back door. We don't do the exports, our clients do.
I am hoping the new license structure will fix the headache.
Since you are NOT the exporter, merely the producer, the ECCP does NOT fall onto you. It is the exporters responsibility to ensure documentation meets the requirements of the importing country. This is based on you saying you sell to your customers and THEY export
HOWEVER, you obviously still need the license to manufacture.
Your chef is going to HAVE to start completing paperwork. It is a MUST, otherwise how do you REALLY know what lot went into what finished product....plus meeting time/temp/pH etc requirements. You will automatically fail a CFIA inspection if these things are not done
have you performed a mock recall yet?
As for paperwork for sales...........you simply need
A) records that the product was safe (GMP inspections/sanitation/batch records (including all ingredient lots) and inspection of shipping containers oh and labeling (which should all be done during production with the exception of the shipping containers and trucks)
B) a record of which finished goods went to which customers...............this is the only piece you will have in the event of a recall on your products OR one of your ingredients/packaging
Having someone with ISO experience helps.....but food is very different than widgets
Sorry for the novel.
Ok, I have a couple of suggestions.................1 is an app called goCanvas (low cost cloud based paperless records that can push reminders et all) or if you want to spend huge $$$ icicle software (canadian company)
https://www.thebuyin...oot-dip-mat.htm These are ideal for dry areas (put in granular quat that breaks when you step on it)..........you can buy rigid black plastic trays with a grooved bottom at the local coop (cheap cheap) and use chlorine or a liquid quat
https://www.hogslat....-boot-scrubbers
https://www.google.c...iact=mrc&uact=8
The type you use depends on the hazards and whether or not it's a RTE facility
We went with Vision4 because they were designed for and by a manufacturing company with multiple product lines and it's bilingual. I just wish it was set up like Mario Kart, the employees'd be more interested in working with it. GoCanvas may be useful, I will check it out.
No meat. I think we'll be safe with the boot mats. They'll be delivered Monday or Tuesday. Thanks. Now I just need door closers.
Have a great weekend!