Removal and archiving of HACCP plans?
Our facility has recently done a consolidation of finished good's profiles they are willing to produce in in order to focus on the products we do well from process capability standpoint and focused on highest volume customers or products in order to cut down unnecessary downtime and short runs.
This work has eliminated all products for two of my HACCP plans. So, I would like to archive those plans or designate them as "not active". They are FDA based plans, not sure if that really matters but what supporting documentation or assessment should be done in order to state they are not active plans and to prevent a GFSI auditor from reviewing them during our yearly audit?
The Management team is in agreement that there is not current plans to re-activate due to not being interested in products in those categories.
And I understand I cannot dispose of any of the previous documentation associated with the archived plans or products.
Just need a second opinion on proper next steps.
Why can't you remove it? Just indicate these plans obsolete as the products have been discontinued - and that's that.
i figured but wanted to make sure there's no additional documentation needed..... HACCP and Food Safety plans rarely are that simple to make changes to
It's your plans and you can (and should) review, adjust or remove them whenever it's necessary.
supporting documentation or assessment should be done in order to state they are not active plans and to prevent a GFSI auditor from reviewing them during our yearly audit?
Remove them from the scope of your audit, and file away for the life of the records associated with them. For the FDA it's one year for fresh and two years frozen.
We are a FDA/USDA facility. Many changes in the last year. So products added, some taken away.
Just to be safe - I archived the plans on the computer that we got rid of. Paperwork documentation related to those plans- I follow the 2 year rule of how long documents have to be kept. I do this as a just in case I need to look at it.
What I would do for the FDA - have your Food Safety plan signed off on again. Getting rid of two HACCP plans might be considered a major change that could require a reassessment.
Depending on the products you got rid of too - you may need to change your FDA registration. This is in regards to the type of products you produce.
Remove them from the scope of your audit, and file away for the life of the records associated with them. For the FDA it's one year for fresh and two years frozen.
I like "Fresh" and "Frozen" in relation to records! I'm going to use these terms from now on, thanks.
... I would like to archive those plans or designate them as "not active". They are FDA based plans, not sure if that really matters but what supporting documentation or assessment should be done in order to state they are not active plans and to prevent a GFSI auditor from reviewing them during our yearly audit?
...
Without regular inspection from the FDA you should be able to declare those plans not active without any hang ups. If you want to make things nice and clear you can write a little cover letter making the declaration, list the affected documents no longer in use, and sign and date it.
For the GFSI, like mentioned above just leave those items out of the scope for the next audit. Show them your signed/dated letter if they ask about the change during the audit.
I take it that the discontinued products use drastically different processes or standards? I'm used to having hundreds of different products under one plan and just having individual paths through the flow chart for different types of items (not all steps are used for every product).
If the plans are specific to the products no longer produced, just archive them and make a note (as stated above) that the plans are obsolete.
Marshall
One advantage of using a Page-based, Revision Documentation System for HACCP Manuals is that obsolete sections can be directly removed and the "Manual-wide" Documentation Sheet updated accordingly.