ISO 22000: WHAT IS ISO 22000 GAP ANALYSIS? – Section III

Gap Analysis III

Since ISO 22000:2005 standard was issued in September 2005, which has been widely adopted by most of the food safety regulatory authorities throughout the globe. It is well known public data by now that, by mid 2013 over 2,400 companies had received ISO 22000 certifications or its offspring, Food Safety System Certification (FSSC) 22000 globally. When it come down to FSSC 22000; it is basically the ISO 22000 standard plus ISO 22002-1:2009 “Prerequisite programmes on food safety – Part 1: Food manufacturing.” FSSC 22000 was developed to meet the benchmarking requirements for the Global Food Safety Initiative (GFSI). Because GFSI felt that ISO 22000 did not provide sufficient guidance to companies for the prerequisite programs.

Besides those companies seeking certification of an FSMS, there are many that utilize ISO 22000 as a framework to develop an FSMS but have elected not to spend the money on certification. However, the FSSC 22000 is much cleverly build focusing more audit business which is a cash cow, where it ensure the safety of what they are purchasing, which was a drive through success due to the acceptance of these purchasing parameters by multinational giants who control the purchasing of many different raw materials throughout the world.

Within the given context, it is emphasizes the importance in prerequisite programs which is on the other words “Good Manufacturing Practices”. As a rule of thumb,  having very good GMPs or PRPs in your production plant means that you are more close to achieve your ISO 22000 system certification easily. 

Section III: Storage Facilities

3.1 General (GMP and Codex requirement)

Adequate facilities should be provided for the storage of food, ingredients and non-food chemicals (e.g. cleaning materials, lubricants, fuels), where necessary.

Where appropriate, food storage facilities should be designed and constructed to:

Permit adequate maintenance and cleaning;

Avoid pest access and harbourage;

Enable food to be effectively protected from contamination during storage; and

Where necessary, provide an environment which minimizes the deterioration of food (e.g. by temperature and humidity control).

The type of storage facilities required will depend on the nature of the food. Separate secure storage facilities should be provided for cleaning materials and hazardous substances, where necessary.

Compliance Criteria

Closely inspect the given points to identify the extent of the existing design and recommend to improve or to maintain the current model. Concentrate on the given points to evaluate more thoroughly and systematically. 

The Control Points

1. Storage areas should be labeled and dry ingredients, chemicals, packaging and raw meat materials should be stored separately and away from finished cooked product. Stored product should be on pallets or shelves and not placed against walls.
2. Cooling units that leak water can increase risk of spreading bacteria like Listeria monocytogens. They should not be locate near finished cooked product or packaging areas and should have drain pans that are cleaned and sanitized regularly.
3. Refrigeration areas should be free from condensation.
4. It is recommended that all materials should be stored off the floor on clean pallets at least 20cm away from the wall to facilitate adequate cleaning, pest control and product ventilation.
5. It is recommended that stacking of pallets of raw materials or finished product is in a controlled manner to prevent the damage risk and or cross contamination through encouragement of pests through product leakage, spillage and taint (particularly sacked product).
6. Incoming materials, work in progress and finished product must be clearly identified and stored in separate designated areas of the factory.
7. Incompatible materials must be completely segregated e.g. aromatic cleaning materials, incoming and finished products, to prevent the risk of cross contamination.
8. Packaging materials should be stored in a separate area which is dust free and pest proofed with the same detail as other areas of the factory.
9. Non food chemicals such as cleaning compounds and agricultural chemicals should be stored in separate, secure areas, together with their associated application equipment.
10. Where non-food chemicals are decanted into containers for use, the containers must be clearly and unmistakably identified with their contents. If possible, they should be colour coded and dedicated to that sole use. Old or redundant food ingredient containers are strictly forbidden for this purpose.
11. All loading areas should be sealed and proofed against pests and birds to prevent contamination of product packaging during the loading operation.
12. In the case of chilled or frozen products, where temperature control is a critical factor in food preservation, loading of delivery vehicles must take place through sealed docks, from a temperature controlled environment.
13. All loading areas must be kept clean, tidy and well maintained to discourage pest ingress.
14. Fork lift trucks used within storage and loading areas should be battery driven to prevent fume contamination.
15. Packed finished product should be checked and approved by the Quality Assurance department prior to releasing to the finished goods storage facility. It must be clearly labeled.
16. Approved batches of finished product should be stored in separate areas, under the appropriate conditions of temperature and as agreed in the finished product specification.
17. Intermediate storage must be provided where delays in the process are unavoidable (e.g. through line stoppage, equipment breakdown).
18. Defective batches of finished product which do not meet the required specification should be quarantined, labeled clearly and held in a specific area pending investigation, to avoid their accidental use.
19. Batches of finished product which, have been recalled or returned, should be so identified and physically segregated, preferably in an entirely different storage facility.
20. Damaged goods should be stored in a designated area of the warehouse as they occur or are discovered. Extreme care must be taken not to expose other products within the storage facility to contamination or infestation.
21. Where disposal of damaged goods is necessary, all labeling should be removed, even for products going to staff sales, to prevent the products re-entry into the distribution chain.
22. Effective management procedures to safeguard against suspect, returned or damaged finished product being accidentally dispatched, must be implemented.
23. Where damaged product is accepted onto a vehicle also carrying “sound” product, it must be clearly labeled, kept separate and handled in a manner which will eliminate the risk of contamination or infestation to other products on the vehicle.
24. The company should have a formalized procedure to deal with the consequences of accidents or damage during storage and distribution.
25. Materials which may present a taint risk to other products e.g. label adhesive, cleaning chemicals, alcohol based sanitizers should be stored separately. This is particularly important for raw materials which, have been opened ready for use and for work in progress material in the system.
26. Both incoming raw materials and outgoing finished product must be swiftly handled at the loading bay to avoid temperature increase where relevant and to minimize the risk of contamination onto outer packaging from external sources.
27. Instrumentation used to record the internal conditions of storage areas must be regularly
    
    checked and calibrated, to ensure that it is working accurately. This is particularly important for temperature and humidity monitoring equipment.
28. Sufficient chill storage must be available for products requiring temperature control, within the specified temperature range. On no account must chilled product be held in ambient or frozen storage areas through lack of space.
29. Cleaning and pest control systems in place.