Hi Brendan,
I think your schedule is along the right lines, you should also be carrying out inspections which can assist in verification of GMPs.
I find some of the previous SQF Guidance less confusing, from Guidance for Developing, Documenting, Implementing, Maintaining and Auditing an SQF Food Safety System for Manufacturing SQF Code, Edition 8.1–SQF System Elements for Manufacturing:
Critical food safety limits are said to be validated because they have been confirmed by scientific analysis. Pre- requisite programs and other food safety controls, however are confirmed by observation, inspection or audit to ensure that they are achieving the desired result.
Validation methods for CCP’s or CQP’s must demonstrate that the hazard is adequately controlled. Possible validation for intervention steps used in the processing of product such as a “kill” step, may be one of the following:
• Scientific literature;
• Peer-reviewed published research;
• In-house or laboratory challenge studies;
• Reference to legally defined CCP’s, such as for the pasteurization of milk.
If technology is being used in a manner that is different from that described within literature or research then the supplier must demonstrate how the revised manner of use conforms to the original claim of intervention.
Some potential methods for confirming the effectiveness of specific pre-requisite programs are listed below. The implementation of these specific methods is not necessarily required, but confirmation of the effectiveness of the program is required. This is not an exhaustive list, but provides some examples:
• Personnel practices: Observe employees during the internal audit or daily operational inspection to ensure they are meeting the requirements of the supplier’s program.
• Personnel processing practices: Observe employees during the internal audit or daily operational inspection to ensure they are meeting the requirements of the program.
• Training of personnel: Interview employees to ensure that job training has been effective and that key points are understood.
• Calibration of equipment: Engage an outside contractor to confirm that equipment is properly calibrated.
• Management of pests and vermin: Trend pest activity information to determine that the program is
effective.
• Premises and equipment maintenance: Trend equipment breakdowns for signs of repeat problems.
• Cleaning and inspection: Perform environmental testing to ensure that microbiological loads are acceptable.
• Water microbiology: Perform water testing to ensure that it meets potability standards.
Internal audits are an in-house check to identify gaps or deficiencies in the SQF System and provide a sound basis for deciding on measures for improvement. Internal auditing is a verification method and when used properly, can reduce the uncertainty and risk of external audits.
This element requires the supplier to audit the activities in their System on a regular basis to ensure that everything is running smoothly. Internal audits help the supplier to identify faults in their System so that it can be improved.
Kind regards,
Tony