Audit grading
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Changes to the Audit Requirements It contains detailed requirements on how to
manage product-change-overs and for sample
New fundamental sections label verification within the product trail (verti-
cal traceability).
Management of suppliers of raw mate-
rials and packaging (3.5.1) Areas of particular interest (causing recalls):
Unintentional presence of an allergen
Labelling and pack control (6.2)
Cross-contamination during production
Accidental addition of an allergen by using
the wrong recipe
Supplier Approval
Mis-packing the wrong packaging is used
Insufficient or ineffective changeover con-
This is now a fundamental requirement. All 3
trols
clauses are revised and a new requirement is
Inadequate packaging management
added for products supplied by Agents and
Wrongly labelled packaging
Brokers.
Specification errors
3.5.1.1 Packaging includes, Substitution or
Communication poor during packing devel-
fraud and the Risk assessment needs to be
opment
reviewed at least annually.
Ineffective change management when a
3.5.1.2 for suppliers assessed as low risk, sup-
recipe changes
plier questionnaires are sufficient, an up-to-
Ineffective sign-off of new packaging or print
date list of suppliers must be available.
changes
3.5.1.3 Raw materials purchased from agents
Error on printing
or brokers
3.5.1.4 Exceptions handling
These elements are reflected in changed
clauses 5.2.2, 5.2.4, 6.2.1 and 6.2.5.
Traceability
Authenticity
Two new clauses are taken up to ensure
greater assurance of supplier traceability
Paragraph 5.4 was extended with Authenticity
(3.9.3) and on the accountability of agents and
to encourage development of systems to avoid
brokers (3.5.1.3).
purchase of fraudulent products.
Three new clauses were created:
5.4.1: access to information to inform risk
assessments
5.4.2: vulnerability assessment of raw materi-
als
5.4.3: introduction of risk based testing or
assurance to mitigate risks.
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Certificates of analysis Implementation of customer specific policies,
Raw material testing codes of practice (3.12.1);
Supply chain audits Ensuring sub-contractors and/or suppliers are
Use of tamper evidence or seals on incoming aware of or adhere to customer policies where
raw materials applicable (3.12.2).
Enhanced supplier approval checks
Mass balance exercises at the raw material Managing surplus food and products for
supplier animal feed.
Changes to the supply chain
Objective is to ensure that surplus food for
food banks and charities is safe to eat.
Ensure brand owners prior consent for
disposal of labelled product (4.13.1);
Ensure procedures in place to ensure
products are fit for consumption (4.13.2);
Controls on food going for animal feed
(4.13.3).
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