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3663 Quality Manual

3663 FOOD SAFETY/DUE DILIGENCE SYSTEMS BACKGROUND

3663 sells and distributes multi-temperature foods (fresh, chilled, frozen and ambient) as well as non-food and catering equipment supplies to the food service industry throughout the UK from its network of 22 distribution depots The company is part of Bidvest Europe, currently the largest foodservice distribution group in Europe. 3663 has a long tradition of serving the food service industry and handles a large product range, which are categorised as follows: · 3663 Own Brands: Chefs Smart Choice, Culine, Smart Choice Professional, Coronet , Springbourne & Whites Brands 3663 Own Brand products are manufactured to strict quality standards by third parties on behalf of the Group and appear in our published sales brochures. They are available to all customers. · Manufacturers Branded Products Sourced by 3663 These products are sourced from reputable suppliers and are offered for sale to customers, once again through the published sales brochures. · Customer Sourced Products Many National and Regional Customers have direct links with manufacturers and develop, select and source particular products for use within their own outlets. These may be manufacturers brand or end-user specific e.g. signature (bespoke) products. In these cases 3663 is contracted to act as stockist and to provide local distribution to individual outlets within the customers' organisation. Such products are not made available to all customers.

FOOD SAFETY POLICY

3663 constantly monitor and ensure absolute compliance with all legal standards. Food Law is a constantly improving set of standards and 3663 ensures it is always operating above the minimum legal standard. Whilst not a comprehensive list 3663 is aware of and aims to be fully compliant with: · · · · · Food Safety Act 1990 (and superseding regulations) Guidelines to the Statuary Defence of Due Diligence General Food Law Regulation EC 178/2002 (and guidance) General Food Regulations EC 352-354/2004 Food Hygiene (England) No2 ­ 852/2004

There are many other guidance documents/codes of practice and recommendations for good manufacturing practice which also apply to a business as complex as 3663. Our Food Safety and Quality Management System (QMS) relies on HACCP to identify and manage the important audit points within 3663.

Doc Ref QM 01 PL

Authorised By: Director of T.F.S.

Revision No: 8

Issue Date: 27.07.10

Page 1 of 7

3663 Quality Manual

All of our systems are subject to regular internal first party and second party and more importantly independent third party auditing. Our systems allow for both unannounced and planned auditing to be carried out as the risk warrants. The following sections indicate the systems and controls operated by 3663 with respect to: A) B) C) D) Purchasing Management Sourcing 3663 Own Brand Products Sourcing Manufacturers Brand products for General sale Depot and Distribution Management

3663 systems are designed to provide the level of due diligence appropriate to the specific category or product risk.

A. PURCHASING MANAGEMENT

Responsibility for ensuring that all products delivered to 3663 depots satisfy the requirements of the Food Safety Legislation rests with the 3663 Group Commercial Director. Individual Managers within the Group Purchasing Department specialise in particular product ranges and are responsible for all products within these ranges. The 3663 Quality Assurance Department works closely with the Group Purchasing Department in order to establish and document that all suppliers follow accepted Codes of Practice and have effective Food Safety and Quality Control procedures. · 3663 Own Brands

Much emphasis is placed upon ensuring that 3663 Own Brand products meet the highest standards of consistency and quality. The sections documented below cover the steps taken to demonstrate due diligence. · Manufacturers Brand Sourced by 3663 for General Sale

Due Diligence for these products encompasses both sections C and D documented below. Follow-up would therefore be determined in the context of Sourcing Manufacturers Brand Products for General Sale. · Customer Sourced Products

For these items 3663 due diligence relates essentially to Depot and Distribution Management (Section D) as set out below. However, details of any concerns with product or supplier would be passed on by 3663 to the catering customer for whom these products were being stocked.

B. SOURCING 3663 BRANDS

- All suppliers are visited, inspected and approved by an accredited independent assessor working to an internationally recognised standard supply agreement. - Regular visits from 3663 personnel who are professionally trained food and non-food technologists and auditors. The warranty mentioned above is also required for all own brand products. The procedures relating to own brand product development include a detailed specification for each product.

Doc Ref QM 01 PL

Authorised By: Director of T.F.S.

Revision No: 8

Issue Date: 27.07.10

Page 2 of 7

3663 Quality Manual

These specifications, together with Quality Audit reports and delivery performance are used to assess the extent of the supplier's own due diligence procedures and to develop 3663 technical audit schedules and sampling programmes to confirm their effectiveness. Product quality audits carried out under this programme encompass physical, organoleptic (tasting), chemical and microbiological parameters. Details within the specifications are also used during the pre-launch activities to confirm that the products and proposed pack copy details conform to the relevant food safety, quality, compositional and labelling regulations. A powerful customer complaints management system is used to analyse complaint trends and to facilitate rapid investigation of complaints by the relevant manufacturer. The accumulated data from all these activities is analysed during regular supplier performance reviews.

C. SOURCING MANUFACTURERS BRAND PRODUCTS FOR GENERAL SALE

The majority of branded products are supplied by leading manufacturers with established reputations for reliability, food safety, quality and adherence to Good Manufacturing Practices. These suppliers are required to provide warranty relating to each specific product as a condition of continued trade. In addition a comprehensive risk assessment questionnaire is required to be completed. Branded Suppliers are required to hold 3rd Party Accreditation to the BRC or equivalent standard prior to approval to supply. Risk assessments are performed by professional Food Technologists and as a result, where necessary, supplier visits are carried out. No supplier is listed without going through the assessment process.

The Quality Assurance department is responsible for the effective implementation of these procedures. They can be contacted at the following address: 3663 Quality Assurance Department Buckingham Court Kingsmead Business Park London Road High Wycombe Bucks HP11 1JU Telephone 01494 555900 Fax 01494 555991 Email [email protected]

D. DEPOT AND DISTRIBUTION MANAGEMENT

3663 has a well-established set of operating principles and procedures defined within the 3663 Operations & Facilities Manuals for Wholesale and Logistics. The manual contains details of all relevant Food Safety, Hygiene and Quality legislation and makes reference to appropriate Codes of Practice.

Doc Ref QM 01 PL

Authorised By: Director of T.F.S.

Revision No: 8

Issue Date: 27.07.10

Page 3 of 7

3663 Quality Manual

Technical and Operations staff regularly revise sections. Operational Services takes responsibility for the manuals and adherence to the procedures within individual depots rests with Depot General Managers, Business Unit Controllers and the Regional Directors. The manual covers operations and distribution procedures and is designed to ensure: 1. Compliance with relevant hygiene/health and safety requirements and are protection against damage or contamination of foods by pests or other contaminants. 2. Vehicles are clean, temperature controlled and properly maintained. 3. Chillers, cold stores and vehicle refrigeration equipment are capable of maintaining product temperatures as set out in the General Food Hygiene Regulations 1995 and/or Quick Frozen Foodstuffs Regulations 1990. 4. Staff are appropriately trained, particularly with regard to the importance of maintaining the cold chain. Designated personnel are trained in the first principles of food hygiene to increase their awareness of the standards required at customer's premises and by enforcement officers. 5. Adherence to strict control and cleaning procedures. 6. Strict control with regard to receipt, acceptance and segregation of goods, cold store operating conditions and distribution.

Specific Control Elements Include: 1. FABRICATION

External The premises are located in areas free from contamination of adjacent activities, are easily accessible for service provision; effectively drained and fenced; free from flood risk and pest infestation. The premises are of sound construction and maintained in a good condition, receiving regular review and repair as part of the companies active Planned Maintenance Programme. Internal a) Walls The surfaces of the walls are constructed of a suitable impermeable material which is smooth, durable, washable and free from crevices with sealed joints. b) Doors The close fitting doors are constructed of a non-deteriorating material with doors opening directly to the outside adequately screened and protected against pest or other contamination. c) Windows The windows are constructed to minimise dirt and debris with sloping ledges or sills; are screened or sealed where the opening is direct to the outside and maintained in a good condition to comply with the company's Glass/ Brittle Material Control Policy. d) Ceilings The ceilings are designed to prevent the accumulation of dirt, debris and condensation, with smooth, easy to clean surfaces and kept in good repair. e) Floors Floors are durable, constructed from impervious material which is smooth and free from cracks and open joints and maintained in a suitable condition.

Doc Ref QM 01 PL Authorised By: Director of T.F.S. Revision No: 8 Issue Date: 27.07.10 Page 4 of 7

3663 Quality Manual

f) Lighting Suitable and adequate lighting is kept free from dirt and debris and provided with shatterproof coverings to comply with the Company's Glass/Hard Plastic Control Policy.

g) Services Pipe work, ventilation and other associated structures are sited and constructed so that they can be easily cleaned. h) Effluent and Waste Disposal The effluent and waste disposal facilities are efficient, constructed to capacity and well maintained to avoid contamination of water supplies. i) Refuse Collection Refuse is removed from food handling and other work areas as often as necessary and at least daily and a waste management contract ensures the correct disposal of the material from the site.

2. EQUIPMENT

Equipment is designed and maintained in accordance with manufacturer instructions, to ensure ease of cleaning and adherence to hygiene standards and prevent contamination of product. Monitoring equipment is calibrated annually and provided with a UKAS Calibration Certificate

3. TEMPERATURE MONITORING

Static and hand-held temperature monitoring equipment is provided to ensure the correct handling and storage of chilled and frozen products. The temperature recordings for the static refrigeration plant are monitored on a daily basis and alarmed to ensure the right action is undertaken and documented. All records are retained for 36 months in a readily accessible location. All hand-held thermometers are disinfected prior to use, using appropriate methods. The hand-held thermometers and static temperature monitoring equipment is tested, using UKAS calibrated equipment, on a weekly basis and calibrated annually. All records are retained for 36 months in a readily assessable location.

4. . VEHICLE AIR TEMPERATURE MONITORING EQUIPMENT

All vehicle refrigeration unit air temperatures are monitored and recorded using equipment that is calibrated annually. All records are retained for 36 months in a readily assessable location.

5. PEST MANAGEMENT

National and regional pest control contracts are in place to provide effective cover against rodents, flying insects, stored product pests and birds. The national specification for the contract requires regular technical and field biologist visits with clear guidance, reports and actions for site management. In addition the contracts are independently audited by Acheta (an independent nationally recognised expert organisation) every 6 months. All records are retained for 36 months in a readily assessable location. Equipment used for the control of infestation includes the following:Doc Ref QM 01 PL Authorised By: Director of T.F.S. Revision No: 8 Issue Date: 27.07.10 Page 5 of 7

3663 Quality Manual

Bait Boxes ­ clearly numbered, secured in position with their location clearly indicated on a site plan. Ultra-Violet Fly Killing Units - with suitable catch trays fitted with sticky boards which are regularly inspected and cleaned where necessary. The ultra-violet light tubes are nonbreakable glass and replaced on an annual basis. Bird Control ­ effective screening, including plastic curtains are maintained to exclude the ingress of birds.

6. RECEIPT OF GOODS AND REJECTION PROCEDURE

Vehicle condition, refrigeration, packaging integrity, date coding, condition of goods and product temperatures are checked and recorded for all deliveries using defined procedures. All temperature-controlled products are tested at the point of receipt to ensure that: · Frozen products are at ­18oC or colder (with a tolerance in exceptional circumstances of up to a maximum of ­15oC). · Chilled products are at 5oC or below to a minimum of 0oC (with a tolerance in exceptional circumstances of up to a maximum of 8oC). Product failing to comply with these requirements are rejected immediately and returned to the supplier.

7. REJECTION PROCEDURE

Rejected products failing to meet the company's acceptance standards are appropriately marked to prevent redelivery and immediately returned to the supplier. Appropriate records are maintained and retained for 36 months in a readily assessable location. The rejections are monitored and repeat causes may result in cessation of trade with the offending supplier.

8. HYGIENE

A high standard of hygiene is maintained at all times. Washing Facilities Toilet and cloakroom facilities are constructed of waterproof washable materials maintained in a clean condition. Adequate hand wash facilities, with antibacterial soap, appropriate hand drying amenities, hot and cold or pre-mixed water with relevant hand washing notices are provided and maintained. Protective Clothing Appropriate clothing to reflect the low level of risk (wrapped product only) is provided, including overalls and safety footwear. The protective clothing is changed on a regular basis and maintained in a clean condition. Adequate storage space is provided to ensure that working clothes do not come into contact with outdoor clothing. Hygiene Policies

Doc Ref QM 01 PL

Authorised By: Director of T.F.S.

Revision No: 8

Issue Date: 27.07.10

Page 6 of 7

3663 Quality Manual

Smoking is only permitted in designated areas which are not within any food handling or food/non food storage area. A jewellery control policy is not necessary due to the low level of risk provided by the wrapped products handled.

9. TRAINING POLICY

All employees undertake a formalised system of training commensurate with their work activity within each depot. Records are maintained in a readily accessible place for each employee. All employees are made aware of the Hygiene Regulations of the Company prior to commencement of work in the food handling areas.

10. CLEANING SCHEDULES

A permanent cleaning schedule is provided at each depot to ensure that all areas, including delivery vehicles and equipment, are appropriately cleaned. Suitable records are maintained at each site. The schedule is checked and signed off by the site management to ensure the cleaning has been carried out to the required standard All cleaning staff are fully trained in chemical safety and cleaning techniques.

11. MAINTENANCE OF STANDARDS

The Environmental Services Controller (ESC) shall oversee the operational procedures, to ensure that high standards are maintained as required. The ESC shall maintain records to ensure that all depots are checked regularly and that all areas requiring attention are focused on.

12. VERIFICATION OF STANDARDS

The depot food safety/hygiene and quality standards are monitored by an external environmental health consultancy, which carries out annual site audits against defined standards. This Due Diligence Policy forms part of the 3663 Quality Management System.

Approval Standards for 3rd Party Service Providers (Hauliers, Warehouses and Consolidators)

3663 use external storage and distribution only in rare circumstances. Potential new suppliers are assessed and approved via risk assessment, using the following criteria: · · · · Supplier Audit questionnaire Accreditation standard.* History of association with 3663 Technical approval audit by a company representative (depending on the standard of response and level of certification). Suppliers are preferred to have as a minimum, certification to a nationally recognised `Food Standard for Wholesaling, Storage and Distribution', which has been inspected against an independent, accredited (e.g. in the UK by UKAS) inspection body.

*

Doc Ref QM 01 PL

Authorised By: Director of T.F.S.

Revision No: 8

Issue Date: 27.07.10

Page 7 of 7

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