SALSA plus Beer Standard Guidance Notes

Transcription

1 Standard Guidance Notes Issue 2, January 2017 This document is published by SALSA, Bloxham Mill, Barford Road, Bloxham, Banbury, OX15 4FF. The information and opinion contained within is expressed in good faith. Neither SALSA nor its approved agents will accept liability for any error or omission in respect of information or guidance contained in this document. SALSA, 2017

2 About the Issue 2 Guidance Notes These Guidance Notes are designed to give small and local Brewers and Bottlers some of the basic information to help organise and manage their own food safety management system based on the SALSA Requirements as defined by the SALSA Standard. The Guidance Notes are general; they are not exhaustive. As the SALSA Standard is built on legal requirements plus elements of industry best practice, many SALSA members will have some, or even most, of the Requirements for the SALSA Plus Beer Standard already in place. It will not usually be necessary to start from scratch and members are encouraged to use their existing systems if they are working well and effectively, and then to use the Guidance Notes to add, adapt or modify as necessary. Within the Guidance Notes, there is a general assumption that members are aware of all the food regulations applying to their products (eg labelling, Weights and Measures, general food hygiene regulations, temperature control regulations etc) including any specific requirements applicable to their own operation. Members are expected to be aware of, and to comply with, any Codes of Practice, Best Practice Guidelines etc, from their sector-specific trade associations. Any other requirements imposed by Local Authorities via Environmental Health or Trading Standards Officers, or other relevant regulatory bodies must also be complied with. HELP FOR MEMBERS Members may find that they require further support to gain their SALSA Approval. The SALSA Scheme offers a range of support services and resources which members can call on to see them through to Approval: Mentoring support SALSA-approved Mentors can be found through the Mentors Directory on the SALSA website Tools & Tips Where these exist, they are indicated by the Tools & Tips logo in the Guidance Notes Self-Assessment Checklist An essential document to determine how your current system complies with the Standard HACCP Courses Interactive courses aimed at the needs of small businesses. Level 1 and Level 2 courses available Food Labelling Workshops Providing clear guidance on producing labels that comply with FIC regulations Telephone Helpline In person advice available from Mon-Fri. IMPORTANT INFORMATION about Standard Issue 2 and these Guidance Notes: Changes between Standard Issue 1, July 2015 and Standard Issue 2 are shown in bold italics in the Guidance Notes, as they are in the Standard. Areas specific to the Brewing Industry appear throughout the Guidance Notes and the Standard in amber boxes. Supplying the Public Sector/STS Requirements: It is not anticipated that Brewers and Bottlers will have to comply with specific STS Requirements (shown in lilac-shaded boxes) for supplying the public sector. Guidance Notes Issue 2, January

3 SECTION 1 PREREQUISITE CONTROLS Statement of Intent: Prerequisite food safety controls shall be identified, documented, adopted, legally compliant and maintained throughout the business. The controls shall include, but are not limited to, the Requirements identified in Section 1. SECTION 3 DOCUMENTATION Statement of Intent: Documents relating to the business s food safety and quality systems shall be clear, organised and accessible. 1.1 Training & Supervision 3.1 Document Control 1.2 Personal Hygiene 3.2 Specifications 1.3 Cleaning 3.3 Procedures & Working Instructions 1.4 Contamination/Cross-Contamination Prevention 1.5 Environment & Process Control SECTION 4 PREMISES 1.6 Control of Raw Materials 1.7 Stock Control Statement of Intent: 1.8 Waste Control 1.9 Pest Control 1.10 Equipment 1.11 Maintenance 1.12 Labelling Control 4.1 Location 1.13 Third Party Distribution & Storage Control 4.2 Perimeter & Grounds 1.14 Product Shelf-Life 4.3 Hand Washing Facilities 4.4 Equipment Cleaning Equipment SECTION 2 HACCP & MANAGEMENT SYSTEMS Statement of Intent: All hazards to product safety and legality shall be identified, analysed and assessed for risk. A documented HACCP (hazard analysis and critical control point) system, based on Codex Alimentarius principles, shall be in place alongside an effective management system encompassing regular systems reviews and procedures for Corrective Action, traceability, incident management and complaint handling. Premises shall be fit for purpose, clean, and provide safe and legally compliant facilities that meet production and staff requirements. Premises shall be registered with, and/or approved by the appropriate authority. 4.5 Location of Toilets & Staff Facilities 4.6 Condition of Building Structure 4.7 Condition of Building Services SECTION 5 LEGAL REQUIREMENTS Statement of Intent: A means of identifying all legal requirements applicable to the Brewing Industry shall be identified and steps shall be taken to comply with them. Requirements HACCP 2.2 Food Safety Systems Review SECTION 6 QUALITY REQUIREMENTS 2.3 Corrective Action 2.4 Traceability Statement of Intent: 2.5 Managing Incidents All reasonable steps shall be taken to ensure that the quality of beer shall 2.6 Complaint Handling be maintained throughout the brewing process. Requirements Guidance Notes Issue 2, January

4 SECTION 1 PREREQUISITE CONTROLS Statement of Intent Prerequisite food safety controls shall be identified, documented, adopted, legally compliant and maintained throughout the business. The controls shall include, but are not limited to, the requirements identified in Section 1. What does a Statement of Intent mean? The Statement of Intent summarises the overall aim of the section that follows. The SALSA auditor will check each requirement during an audit. Should the auditor find that there is a substantial failure to meet the requirements of the section, it is likely that the supplier will also fail to comply with the overall Statement of Intent and result in an unsuccessful audit. 1.1 Training & Supervision Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips The business shall have a training policy with a documented plan and records to demonstrate that the training is appropriate, effective and can provide evidence of competency. Food handlers should be trained and instructed to a level that means they can carry out their work activity safely and effectively. You should be able to demonstrate how you achieve this. An overall or general training policy may be documented, but for a very small company it may be appropriate to rely on a documented training plan/matrix and records. This should include refresher training for all staff. A training matrix should show the range of training required by the business and should specifically include appropriate training for those who are responsible for monitoring Critical Control Points. For individuals, the details of training required, training carried out and frequency of training should be specified. Training does not have to be by way of formal courses; effective training can be given via in house instruction. Diagrams and photographs can be useful as part of training. Consideration should also be given to the language skills of food handlers. Provide signage and critical information in additional languages if necessary. Records of the training undertaken by all staff should be retained for the period of employment plus the shelf life of any product they have been involved with if the period of employment is shorter than this (see 3.1 Document Control). Details of how training is monitored and details of Corrective Actions to be taken if training is ineffective, should be recorded. Food handlers are defined as all operatives who come into contact with raw materials through to final product. The easiest way is to document your training policy and plan is to keep a set of records that complement the procedure and demonstrate the training that each individual food handler has undertaken. The records can show: the trainer, the trainee and when training was given. Ensure that you keep records of Induction Training which should include company rules concerning personal hygiene (see and also 1.2, Personal Hygiene). An Induction Checklist can be helpful to ensure all relevant points are covered and reference to working instructions (see 3.3) will be helpful. Don t forget to keep training records up to date. All those who handle food and drink should have food hygiene training. This may be in the form of a formal course for existing, permanent and temporary staff and included in Induction training for all new staff. Keep records of the hygiene training given. Guidance Notes Issue 2, January

5 1.1.2 Temporary personnel and contractors shall be trained commensurate with their activity prior to commencing work. This training shall be documented A programme of appropriate refresher training shall be in place for key staff All personnel shall be adequately supervised throughout the working period. All visitors and contractors entering a food-handling area, and food handlers, whether permanent, temporary or employed for a specific task or time (eg agency workers) should go through induction training prior to entering the production area and/or starting work. The amount of training required will depend on the nature of the work activity but in all cases should include: 1. A questionnaire to establish the health status of the visitor/contractor or food handler (preferably before employment) 2. Company Rules covering the relevant requirements of Requirement 1.2, Personal Hygiene. This training can be simple, from a graphic illustration of the work involved to one-to-one training. The Foods Standards Agency issued Food Handlers Guidance: Fitness to Work (2009). The last page has a suitable questionnaire to be used for establishing the health status of prospective employees, contractors, visitors and staff returning from abroad. Training must take account of the protective clothing changing routine expected prior to entering and re-entering any high care/high risk area. (see and Glossary of Terms for definitions). Breweries do not normally involve High Risk operations in this regard. Training should be viewed as an ongoing activity with planned update/refresher training carried out at specified intervals. It may be useful to review training annually whilst carrying out your annual SALSA review. Supervision should be provided as required by the work activity. In a very small business this may not be applicable. It may be necessary to supervise personnel who are responsible for Critical Control Points (activities crucial to the safety of the product being made you will have identified your Critical Control Points in Section 2, HACCP & Management Systems). Document this in the training records for each member of staff. Ensure visitors to food handling/production areas are required to complete a Health Status Questionnaire and read the Company s personal hygiene rules prior to entering these areas. The responses to the health questionnaire should be checked before allowing entry, if safe to do so (see 1.2.9). Beer is a low risk product. See comments in HACCP section. Update your training records with a plan or dates for refresher training against each training activity. Define who and/or which job needs to be supervised and include this in your training records. 1.2 Personal Hygiene Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips Protective clothing shall be suitable for the food being handled and shall not pose a contamination risk to the product. Disposable protective clothing, if used, shall be subject to adequate control to avoid product contamination. Laundering of protective clothing should be controlled: Using a contract laundry service (preferable). Laundering on the premises following a written set of instructions, including the minimum temperature to be reached (at least 60 C) to ensure clothing is sufficiently cleaned and to avoid (cross) contamination. Laundering off the premises by staff in the home is not desirable, especially for handlers of ready-to-eat foods, but if necessary, written instructions, including the minimum temperature to be reached (at least 60 C), should be provided and it is advisable to have a system in place to monitor clothing cleanliness on return to the premises. More Draw up a document which states how you meet this requirement. You could include this on a routine check of the premises (see 1.3.2, Housekeeping Check). Guidance Notes Issue 2, January More

6 1.2.2 Where protective clothing is required, designated changing facilities shall be provided for all personnel, whether staff, visitor or contractor, prior to entry to all food handling areas. Protective clothing shall be stored physically separate from outdoor clothing. Condition/Style of protective clothing: Clothing must be kept in a clean condition and in good repair. For handlers of ready-to-eat foods, protective clothing must be changed daily or more frequently or if soiling presents a possible risk of contamination. Protective clothing for high risk/high care staff must be capable of being easily removed prior to going to the toilet or staff facilities eg it may be easier to provide white coats rather than short jackets and trousers (see also 1.2.3). Non-disposable rubber gloves: Must be kept in a clean, undamaged condition. Stored where they cannot present a contamination risk. Disposable gloves and disposable protective clothing: Must be single use and their issue controlled. In the case of disposable gloves, hand washing guidelines still apply. Must be changed if damaged, work breaks, after going to the toilet and after re- entering the processing/production area. Be stored & disposed of where they cannot present a contamination risk. It is Good Manufacturing Practice for staff to wear business-issued protective clothing and breweries should work towards this. As a minimum, a risk assessment should be undertaken to determine where this may be needed Storage of protective clothing: Must be stored physically separate from outdoor clothing. Must not be stored in the toilet cubicle area. Changing facility: Personnel should not change into protective clothing in the toilet cubicle area or the processing/production area. Separate, designated changing room(s) or changing area(s) should be used. Where personal clothing is allowed to be worn in production and storage areas, there must be a facility for storage of outer clothing. If you use disposable protective clothing, make it obvious where this is collected for wear and subsequent disposed of. This can be done by good signage and suitable dispensers and receptacles. Conduct and document a risk assessment showing your evaluation of what protective clothing, if any, should be worn in the different areas of the brewery. You should outline the changing procedure in your personal hygiene document/company rules and place a notice in the changing room(s) to remind staff about the correct procedures to adopt. You could include compliance with this on a routine check of the premises (see 1.3.2, Housekeeping Check) This will be assessed by the auditor during their visit. You should be able to show these areas. Guidance Notes Issue 2, January

7 1.2.3 For the production of High Risk/ High Care products, all protective clothing shall be removed, in a designated changing area, before visiting the toilet and controls shall be in place to ensure product safety is not compromised before returning to food handling areas All hair, including beards and moustaches, shall be fully contained to prevent product being contaminated in open food production and storage areas The business shall detail how to control jewellery, medical jewellery and personal items such as medicines, keys and mobile phones so that they pose no risk of product contamination. High care/high risk businesses will need to have defined procedures to ensure that staff change out of protective clothing/footwear prior to going to the toilet. Staff training must take account of the protective clothing changing routine expected prior to entering and re-entering the high care/ high risk area. Supervision and monitoring of this procedure is essential. See also 4.5 for additional Requirements for High Care/High Risk changing facilities which relate to the design and layout of premises. This does not normally apply to brewing. Staff should be issued with hair coverings that are capable of containing all hair when entering the production and storage areas. Disposable covers are better than washable versions for hygiene reasons. To minimise the risk of loose hair falling on protective clothing, hair coverings should be put on before other protective clothing. It is Good Manufacturing Practice to cover hair in breweries. As a minimum, a risk assessment should have been undertaken to identify those areas of the brewery (eg packaging hall) where it is mandatory and what hair covering is appropriate. It will be expected wherever raw materials, products or intermediates are open. State what jewellery, if any, is permitted to be worn: Any jewellery should be of a single piece such as wedding rings/sleeper earrings. Religious jewellery, such as wedding chains or crosses, must be covered by protective clothing. Exposed jewellery, if permitted and unavoidable, must be covered by controlled-issue, coloured, waterproof dressings. If you allow medicines on site, you should make provision for their safe storage so not brought into or taken in the production areas. You should outline the changing procedure in your Personal Hygiene document/company Rules and place a notice in the changing area to remind staff about the correct procedures to adopt. (see & 1.1.2, Training). You could include compliance with this on a routine check of the premises (see 1.3.2, Housekeeping Check). See You should outline the changing procedure in your Personal Hygiene document/company Rules and place a notice in the changing area to remind staff about the correct procedures to adopt. Include your Personal Hygiene document/company Rules in induction training (see & 1.1.2). Wearing of appropriate hair coverings in all production and storage areas. Document your risk assessment and comply in areas where hair covering is required. Have a plan to work towards hair covering throughout the brewery. Document this in your Personal Hygiene document/company Rules and include these in induction training (see & 1.1.2). You could include this on a routine check of the premises (see 1.3.2, Housekeeping Check). Guidance Notes Issue 2, January

8 1.2.6 Hand cleaning shall always be performed before handling food, after visiting the toilet and thereafter at a frequency that is appropriate to product risk. Staff should be trained how to wash their hands. State what hand cleaning is expected as follows: Hands must be washed thoroughly, before starting work, before handling food, after using the toilet, after handling raw foods or waste, after every break, after eating and drinking, after cleaning, and after sneezing, coughing and blowing the nose. If nailbrushes are used, they should be sound, clean, and plastic and kept in a sanitising solution which is regularly replaced. Document this in your Personal Hygiene document/company Rules and include these in induction training (see & 1.1.2). You could include this on a routine check of the premises (see 1.3.2, Housekeeping Check) All cuts and grazes on exposed skin shall be covered by a contrasting coloured plaster that is business-issued and monitored. If a metal detector is used to check finished product, plasters available for issue must be regularly checked through the machine to ensure: 1) that these plasters are metal detectable and 2) that your machine detects them. There must be a record of plaster issue and checking in place to make sure that all plasters are accounted for and traceable in the event of loss during food handling duties. It is best to make a trained individual responsible for purchasing plasters in order to avoid product or skin-coloured plasters being inadvertently issued for use. Blue metal detectable plasters are normally used in the food industry. Document this in your Personal Hygiene document/company Rules and include these in induction training (see & 1.1.2). Record all plasters issued, when, by whom and to whom. (This may link in with your H&S accident recording system). You could include this on a routine check of the premises (see 1.3.2, Housekeeping Check) Perfume or aftershave shall not be worn; fingernails shall be kept short, clean and unvarnished. False fingernails shall not be permitted. State this in your Personal Hygiene document/company Rules. Document this in your Personal Hygiene document/company Rules and include these in induction training (see & 1.1.2). You could include this on a routine check of the premises (see 1.3.2, Housekeeping Check). Guidance Notes Issue 2, January

9 1.2.9 The business shall have a procedure for the notification by employees, temporary employees, contractors and visitors, of any relevant infectious disease or condition with which they may be suffering, or have been in contact. If any food handler has a condition to notify, then this should be recorded by the business and a risk-based decision made as to whether or not the person is fit to work on food handling duties (see 1.1.2, Training). It is advisable to have systems in place to monitor contractors and visitors to the food premises as well as employees and temporary employees (see 1.1.2). It is advisable to monitor food handlers returning to work after infectious illness (see 1.1.2). Seek advice as necessary from a medical practitioner or your local Environmental Health Officer. The Foods Standards Agency has issued a 2009 document, Food Handlers Guidance: Fitness to Work which gives detailed guidance on action to take in the case of a food handler having an infectious disease. You should have documentation relating to health screening (see 1.1.2) which you could use as a return to work questionnaire for employees and a health questionnaire for contractors and visitors to control notification of infectious illness (see 1.1.2). Document this in your Personal Hygiene document/company Rules and include these in induction training (see & 1.1.2) Beer Areas where tasting is allowed shall be clearly identified. Areas where sampling is allowed should be identified (away from open product or raw materials). Allowable areas should be included in Personal Hygiene document/company Rules. 1.3 Cleaning Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips Documented cleaning procedures and records shall be in place and maintained for the building, services, plant and all equipment in direct contact with food. Cleaning schedules should be in place. Depending on the size and complexity of the business, this could range from one schedule to a range of schedules. These schedules should specify: All the areas of the site, surfaces (including floors and walls), equipment, own or rented distribution vehicles and loading areas to be cleaned. How each is to be cleaned (method). The frequency of cleaning (eg after each use, daily, weekly, etc). What chemicals are to be used, dilution rates, special instructions (eg wearing of protective gloves & goggles). Who is to carry out the cleaning? A section for the cleaning operative to sign to confirm cleaning has been carried out. A section for signing by the person checking that the cleaning has been carried out to a satisfactory standard. Ensure that your cleaning routines take into account any allergens that may be present in the area concerned, and that they minimise the risk of cross-contamination of allergens between raw materials and products. Keep copies of cleaning schedules and completed records to show the schedules are being followed and that evidence of cleaning taking place is available. The checking of cleaning must also be documented. The checker should not be the same person as the cleaning operative. Guidance Notes Issue 2, January

10 1.3.2 All areas of the site shall be visually clean and tidy and the standard of cleaning and housekeeping shall be suitable to minimise the potential for contaminating the product In High Risk/High Care areas, cleaning and disinfecting processes shall effectively control any microbiological risk to the safety of the product. Each area should be cleaned & checked in accordance with the cleaning schedules. All areas, following cleaning, should be clean, tidy and uncluttered. Where hoses are used, they should be stored on hose racks when not in use. Toilet cleaning should be specifically planned with separate cleaning materials such as coloured mop buckets, disinfectant & cloths made available. If the same cleaner is cleaning both the processing areas and the toilets, toilets must be cleaned at the end of the cleaning time with no return to the processing areas. Don t forget to include external areas and waste containers. For vessels, this can take the form of a visual inspection, microbiological testing or adenosine triphosphate (ATP) testing depending on e.g. the site s risk assessment, to validate the effectiveness of cleaning Areas to be disinfected must be clearly specified on the cleaning procedures and the type of cleaning must be appropriate to the food safety risk and the equipment in use in that area. It may be appropriate, particularly in high risk situations, to monitor cleaning processes by carrying out swab testing, either by external laboratory or rapid in-house methods, to make sure that cleaning is demonstrably effective. To ensure this requirement is complied with throughout the premises and site, a documented routine check of the cleanliness and tidiness of the premises (Housekeeping Check) will need to be carried out. Record on Brewing or Fermentation sheets. The number of casks needing recleaning should be noted. The barcode of each dirty cask and the outlet that last returned it could be recorded and trends noted if systems allow. Keep copies of cleaning schedules and completed records to show the schedules are being followed and that evidence of cleaning taking place is available. See Glossary of Terms on website for definition of High Risk/High Care. This does not normally apply to brewing. However where yeast is cropped, stored and re-used, this may be considered a High Care operation with temperature of storage and acid washing being the main issues. The checking of cleaning must also be documented. The checker should not be the same person as the cleaning operative. The results of any monitoring tests, whether by an in-house rapid method or carried out by an external laboratory, must be maintained. See Guidance Notes Issue 2, January

11 1.3.4 Cleaning chemicals shall be fit for purpose, suitably labelled, secured in closed containers and used in accordance with manufacturers instructions. Cleaning chemicals in use must be specifically for food use: Disinfectant products, where appropriate, should comply with the BS EN 1276 or BS EN standards. Cleaning chemicals should be kept in closed containers, and in a secure storage area or lockable cupboard away from production areas except when in use. Containers used for decanting (such as sprays) must be labelled. Manufacturers instructions and dilution rates must be followed at all times. Ensure the accuracy of any automatic dosing system attached to a utensil or tray washing machine. Make sure you have a practicable method of ensuring the correct dilution of each chemical in use. Possible options are: o Documented method (see 1.3.1) of dilution, stating volume of chemical in stated volume (bucket?) of water. o Use of a measured dosing plunger fitted to the top of the bulk o chemical container. Use of an in-line dosing system connected to the water supply. If this method is used, set up a routine check and a record to verify that the correct dose strength is being delivered by the system. Information on the chemicals used must be held and be readily accessible at all times. If an in-line dosing system is being used, keep a record of the results of your checks and any alterations made, to ensure the correct dose is being achieved. Where an automatic dosing system is attached to a utensil or tray washing machine, include a routine check on its correct operation. This could be part of the machine maintenance programme (see ). Keep records of each chemical used on file (Control of Substances Hazardous to Health COSHH Regulations). Make sure there are suitable safe and secure storage places for chemicals when not in use. Make sure all containers, including sprays, are labelled Beer Vessels, including those with Clean In Place (CIP) systems, shall be checked to ensure that no detergents remain. Residual detergents, where used, shall be drained. This may take the form of a visual assessment or testing the ph of the final rinse water with either: test paper, a ph meter or a conductivity meter. Flow meters may also be used to ensure that the scavenging pump runs at a faster rate than the feed pump. Record on Brewing or Fermentation sheets Beer Procedures shall be in place for cask cleaning. Procedures shall be in place to prevent contamination of the beer from the cask and its cleaning operation. Casks should be washed on the day they are required but, when a number are washed before (no more than 2 days in advance) in order to start up, they should be fitted with a keystone and loosely fitting shive. It would be Good Manufacturing Practice to rinse these with a residual disinfectant (e.g. peracetic acid/paa) immediately before use. For casks, a visual inspection of each cask after washing would be expected and may be a Critical Control Point (CCP). This may take the form of a visual assessment or testing the ph of the final rinse water with either: test paper, a ph meter or a conductivity meter. The procedure for cask washing should include what to do if casks are found not be clean. Keep record of checks and returned beer Guidance Notes Issue 2, January

12 1.3.7 Beer The brewing plant shall be subject to a caustic clean at a frequency determined by risk assessment Plates should be lifted for each clean and any residual grain washed away. The frequency at which the brewing plant is caustic-cleaned can be based on microbiological results or Apparent Total N-nitroso Compounds (ATNC) levels. Include in Cleaning Schedule and record when done. 1.4 Contamination/Cross-Contamination Prevention Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips The business shall operate methods of working and process flow(s) that minimise the potential for the unintended physical, chemical, microbiological or allergen cross-contamination of product at all process steps. You will need to complete this before undertaking your Hazard Analysis (see 2.1.2). The simplest approach is to draw up a flow chart showing all the steps involved in your production. This may involve just one flow chart for a very small business with one type of product or may require separate flow charts for different products or product groups. These steps are likely to include: delivery, storage, processing (there will be several steps here), packing, labelling, storage and distribution. Take each step and identify where contamination could occur, noting the reasons and the working methods or the process itself that needs to be changed to minimise the potential for unintended physical, chemical and/or microbiological contamination. An example would be covering an open mixing vessel. Your process flow should follow a logical sequence to avoid unnecessary overlapping or repetition of process steps. Consider the potential for cross-contamination from the movement of staff within and around the production area. Consider the potential for cross-contamination caused by the handling of different raw materials within an area. Be organised in such a way that the risk of raw materials - or staff handling raw materials - coming into contact with processed products is minimised. Production should be planned and staff trained in their work activity. Do not allow animals, pot plants etc, in production, food/packaging storage areas or staff facilities If factory tours are undertaken, or the site is a Brew Pub, then a documented risk assessment and suitable controls must be put in place. If milling occurs on site, controls procedures (i.e. sieving and magnets), systems and records must in place to remove potential foreign bodies The milling operation must be done in a dedicated area. Make sure procedures, risk assessment and monitoring of contamination/crosscontamination prevention is documented and that records demonstrate that staff are trained in these procedures. The risk assessment can be included within the HACCP Study. Magnets and sieving checks must be recorded and any findings recorded and actioned Guidance Notes Issue 2, January

13 1.4.1a STS Ready-to-eat food products that may support the survival or growth of Listeria monocytogenes shall be tested for the presence or absence of this pathogen. Results shall indicate absence of Listeria monocytogenes in a 25g sample. Food products should be tested for the presence or absence of Listeria monocytogenes as part of a sampling plan. Set the limit as not detected in a 25g sample. Requirement 1.5.1a provides details of the STS Requirements for environmental testing. Demonstrate that you have followed, and are continuing to follow, a suitable sampling and testing plan (see also shelf-life requirements in 1.5 and product specifications in 3.2). The plan should cover a representative range of products, ingredients and environmental samples for microbiological quality and safety, including Listeria monocytogenes. Results should be kept in a suitable and accessible manner There shall be effective segregation in place to minimise the risk of product or meat species crosscontamination. Where the risk of product cross-contamination is identified, such as for meat and animal by-products, specific handling and storage procedures must be in place. This may include specific cleaning schedules, specific storage requirements and could include the separation of processes by time. If it is not possible to avoid cross-contamination by products on shared surfaces or equipment, then separate handling and production equipment must be used. If physical segregation is necessary, the segregated areas must be clearly identified and movement of materials and people appropriately controlled. Different species of meat: Make sure that meat of different species is clearly labelled and well segregated in your storage and processing areas. Unless intended to be mixed in a product, different species should be processed: In different areas and/or Using different equipment or Using the same equipment at different times with appropriate cleaning and disinfection in between. This type of contamination is unlikely in beer; the major consideration might be any allergens brought on to the site by unusual ingredients. (see 1.4.3) Check and record the fact that this is happening, for example by: Showing well organised labelling/signage and segregation in recognised storage and processing areas. Any Time Segregation should be planned and documented with cleaning methods and records that demonstrate compliance. You could include this on a routine check of the premises (see 1.3.2, Housekeeping Check). You could monitor the effectiveness of cleaning and disinfection between species by use of ATP surface swabs. Make sure that you have a documented procedure and training records demonstrating that staff understand and will comply with it (see 1.1.1, Training). Document those allergens present in the brewery whether in the process or brought in by employees/contractors/visitors and how these are controlled. Guidance Notes Issue 2, January

14 1.4.2a STS If horsemeat is handled, then a dedicated area shall be provided. Horsemeat - Although it is unlikely that you process horsemeat intentionally in the UK, if you do, whether it is in the form of carcasses, offal, cuts or any processed meat of horse origin, it is necessary to do this in a dedicated area that is not used for handling or processing any other meat species. Make it as obvious as possible that you have a designated area for handling of horsemeat only, with signage and relevant controls of staff movement A system shall be in place to identify allergens handled on site and to minimise the potential for crosscontamination. This shall include the risk of allergen contamination from food provided for, or brought onto site by employees, contractors and visitors. Labelling legislation now requires allergens to be specified in lists of ingredients for pre-packed foods. These allergenic ingredients are: Cereals containing gluten: (wheat, rye, barley, oats, spelt, khorasan wheat and their hybridised strains), crustaceans, molluscs, fish, egg, milk, soya, peanuts, tree nuts: (almond, hazelnut, walnut, cashew, pecan, brazil, pistachio, macadamia and Queensland nuts), celery, mustard, sesame seed, lupin, sulphur dioxide and sulphites, (and products derived from these). Where allergens are handled and/stored on the premises, specific handling/storage procedures must be in place. This may include specific cleaning schedules, specific storage requirements and separation of processes by area or time. If it is not possible to avoid cross-contamination by allergens on shared surfaces or equipment, then separate handling and production equipment must be used. Check items in snack bars and vending machines on site for any allergen content and discourage staff from bringing foods containing nuts onto site. In breweries the following will generally apply: Sulphur dioxide is a processing aid/preservative in raw materials. If no Sulphur dioxide is utilised as processing aid, calculations have shown that product SO 2 levels are below the 10 parts per million (ppm) threshold for declaration. It should be noted that some yeasts produce SO 2 and this should be checked. Note - Sulphur dioxide is found within Caramel. If a brewery is selling gluten-free beer, precautions must be in place to prevent cross-contamination with other beers and tests must be put in place to support the claim. Isinglass finings are made from fish but no fish protein is present in finings so fish does not need to be included on a list of allergens on site. If finings are cut on site, fish does need to be included on a site allergen list. Beware unusual recipes such as Oyster Stout that may bring unexpected allergens into the brewery. Document your risk assessment and procedure for handling allergens. Staff and visitors (including contractors) must be aware of the procedure for the control of foodstuffs containing allergens when on the premises. This can be done by including the procedure on your Visitor Health Questionnaire (see 1.1.2). See above. Guidance Notes Issue 2, January

15 1.4.4 Where there is a risk to product and/or packaging, a written procedure for dealing with breakages, along with a list of relevant glass and brittle items to be checked, shall be provided Procedures shall be in place to prevent contamination of product by cleaning chemicals or pest control measures. This refers to a) minimising the risk of product contamination through checking the condition of unavoidable glass and brittle plastic items which might, if damaged, hazard the product, AND b) dealing with any actual breakages of glass or brittle plastic in production and food/packaging storage areas. For a): Identify those glass and brittle plastic items, which, due to their location and vulnerability may constitute a risk to the product and/or packaging. eg fluorescent tubes, light bulbs, equipment dial covers, stop/start buttons etc and list them on your register. This is particularly relevant in areas where product is exposed. Consider if it is possible to remove, replace or relocate any in order to minimise the risk. Carry out and record the results of a routine check on the condition of the listed items. Take appropriate Corrective Action when damage has been identified (see 2.3). For b): Consideration should be given to action necessary to remove risk of glass or brittle plastic contamination when a breakage occurs in a given area. The procedure should define the area affected, equipment eg brushes to be used and what product would need to be destroyed as a precaution, a record of breakage incidents and action taken. Unless you are packing into glass containers where it is not unusual to have to deal with broken glass, it is appropriate to dispose of any cleaning equipment used to clear up. Where frequent glass breakage occurs (packing into glass containers), it is appropriate to provide dedicated, colour-coded cleaning equipment. Where you are packing into glass containers it would normally be expected to have a written instruction detailing exactly what action is to be taken when a breakage occurs on, or adjacent to, the filler and/or the capper/lidder. There should be an intake procedure for pallets of glass bottles. If breakages are noted on the pallet, consideration should be given to returning the pallet to the manufacturer. Pallets of bottles should be stored inside if feasible. Part-pallets should be adequately protected and must be stored inside. If breakages are noted at de-palletisation, all glass below the breakages should be inspected. See also 1.3.4, 1.9.2, and Manufacturers instructions for the use of these chemicals must be followed. Products which have to be decanted must be transferred into clearly labelled containers. Unlabelled containers, (including spray bottles) are not acceptable. Keep records of your checks on identified glass and brittle plastic items, their condition and any Corrective Actions taken (see 2.3). Document your breakage procedure. Procedures for these should be documented. Records of breakages should be kept. Document the procedure and include this on a routine check of the premises (see 1.3.2, Housekeeping Check). Guidance Notes Issue 2, January

16 1.4.6 Procedures shall be in place to prevent in-process contamination by foreign bodies including metal, wood and plastic. Your HACCP documentation should indicate what foreign bodies might be considered as physical hazards eg metal from equipment, eggshells etc. If using a metal detector, make sure there is a detailed procedure for the operation of the machine, including the sizes of test pieces and frequency of testing. The procedure should also state the action to be taken a) if the detector fails to recognise a test piece, and b) if the detector identifies potential metal contamination in product. Ensure that only the minimum number of knives, blades and utensils are available for use in production areas. Remove all non-essential items. Ensure that those available for use are in good condition and their use is controlled. Where possible, the use of wood should be avoided. If not avoidable, include the wood items on a replacement programme and in the meantime: If a food contact wood surface or implement is essential to the food processing procedure, the surface or implement must be sound, capable of being cleaned and disinfected and must be checked frequently (daily/weekly) for cleanliness and condition. Otherwise, ensure that there are no wooden food contact surfaces or implements in use. If wooden walls and doors etc are present in storage areas, make sure that the wood is sealed (varnished/painted) and is capable of being washed and disinfected if necessary. If unavoidable or used for decoration (eg vessel cladding), include the wood items (including pallets and fermentation vessel covers) on an Inspection and Replacement programme. Surfaces should not be varnished where found over the product. Where knives and cutting/dicing/slicing blades are in use, these should be identified on a register and routinely checked for their presence, for damage or signs of wear which could lead to metal contamination of product. The results of these checks should be recorded (see 1.4.1). Document the procedure and include a check on the condition of any wood surface or implement on a routine check of the premises (see 1.3.2, Housekeeping Check). Include the check on food contact wood surfaces or implements in a suitable record. The auditor will assess this during the audit. Keep records of your inspections Beer In plate heat exchangers, particularly those using glycol, product shall be at a higher pressure than coolant. Maintenance checks shall be in place. You should be able to show maintenance records to demonstrate that the heat exchanger is regularly tested and/or serviced. The level of the glycol header tank should be checked, any level drop investigated and any coolant leaks repaired. If interior coils are used for cooling, any joints must be positioned so that they cannot drip into vessels. Tanks with jackets should form part of the maintenance schedule with inspections to check that there is no corrosion. Include servicing in maintenance records and record any issues. Refer to the British Beer and Pub Association Code of Practice ex Glycol Beer Where beer or water is sterilefiltered, appropriate pressure differential tests shall be in place. 0.45μ filters should be used and checked in situ. Pressure differential tests should be in place for each run at least at the start and end of each run. Keep records of checks. Guidance Notes Issue 2, January

17 1.4.9 Beer For final packaging and containers, tests shall be in place to verify that these are clean and are empty. For returnable packages, tests should be in place to ensure there is no residual detergent present. For manual washing (monikers, etc), visual inspections should be in place. Where Intermediate Bulk Containers (IBCs) are used (for example to transport beer to a contract packager) it is preferable that a one-trip liner is used. If reusable IBCs are used, checks must be in place to ensure that they are clean before they are re-used. Records should be retained on packaging and/or dispatch sheets. 1.5 Environment & Process Control Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips Monitoring shall be carried out in accordance with product specification requirements and/or specified operating procedures. Your temperature monitoring records should reflect your required product specification temperature ranges i.e. your process details or recipes should include the Critical Limits of temperature ranges necessary. Include any temperature monitoring requirements during distribution. See 1.7.2, Stock Control, for guidance for incoming goods. Check the format of your written recipes or processes to make sure they cover the details of any critical temperatures necessary during storage, handling, processing and distribution. Have temperature monitoring records which illustrate that these temperatures are met. Temperature records may be automated or manual, digital or analogue. Other than yeast storage (<5 o C) and acid washing (2 to 4 o C), temperature is for quality, rather than food safety considerations. Process temperature, including pasteurisation shall be monitored and, if automatically controlled, cross-checked with a hand-held device on a scheduled basis Record fridge temperatures. Record residence time and temperature of acid washing. Guidance Notes Issue 2, January

18 1.5.1a STS An environment sampling plan shall be in place to test for the presence or absence of Listeria monocytogenes. As well as testing food for Listeria monocytogenes, include the following: Periodic testing of food contact surfaces after cleaning between production runs/batches. Hand and utensil washing sinks and taps that can cross-contaminate if not regularly sanitised. Floors and drain covers that, if not cleaned properly, can harbour a build-up of food debris and provide an opportunity for Listeria monocytogenes to thrive and contaminate the production environment. Make a plan for your environmental sampling by area and frequency. Indicate results on the plan using a scheme such as green, amber and red colour-coding b STS Temperature monitoring points at distinct stages of the cold chain within the premises and during storage and distribution shall be established. This includes receipt, storage, processing, picking, loading and transport. There should be a written recognition of the normal and maximum residence time of the raw materials, intermediates and finished products in the various areas of the premises in which they are handled. Measure and record temperature of monitoring points continuously or manually to a defined schedule/interval. Show records of evidence that relevant temperature-sensitive raw materials are being checked upon receipt and that these raw materials, temperaturesensitive intermediates and finished products have been kept under refrigerated conditions during their time on the premises Facilities, including distribution, shall be adequate to maintain raw materials, intermediate and finished products within a safe temperature range. The storage capacity (for ambient, chilled and frozen storage) must be sufficient for the maximum throughput of product you make and handle, as well as making allowances for cleaning, defrosting etc. It is essential that temperatures can be taken easily and methodically. If fridges and freezers have external temperature gauges, then they should be checked for accuracy regularly by taking the internal temperature of the cabinets and contents (see 1.5.4). Casks shall be stored at cellar temperature (10 to 14 o C) before distribution. (Checks have shown that the temperature rise during local distribution is insignificant). Package-conditioned products must be stored at a high enough temperature to allow conditioning. Have a written procedure to specify how you will deal with maintaining control of temperatures in your business. Record cellar temperature and temperature of conditioning rooms (daily). Guidance Notes Issue 2, January

19 1.5.3 In the case of equipment failure, procedures shall be in place to establish the safety status of the product prior to release Environment monitoring devices, such as temperature monitoring equipment and process control devices such as weighing equipment identified as essential for legality and food safety shall be calibrated to ensure accuracy within agreed parameters at a predetermined frequency. Ensure you have documented what action should be taken when environmental monitoring equipment fails and to prevent production continuing without any checking to establish that it is safe to do so. This does not normally apply to brewing. Exceptions include failures in pasteurisers and heat exchangers. This requirement only refers to devices and equipment used to ensure legality and food safety and is aimed at ensuring they are accurate when compared against internationally recognised standards. You should identify all such equipment essential for legality and food safety. Your Critical Control Points will also indicate the equipment that needs to be calibrated. This may include thermometers, weighing scales, ph meters, refractometers, pressure or vacuum gauges, chart recorders and data loggers. Make sure that you have up-to-date information about the aspects of Weights & Measures legislation which applies to, and/or which you are using for your product(s) (eg minimum weight, average quantity, average weight, measuring container or quantity). If the quantity of the product is not governed by legislative requirements (eg bulk quantities for wholesale sale), check that the product conforms to the customer s specifications. Make sure that staff are appropriately trained to deal with your verification procedures (see 1.1.1). In addition to calibration it is also necessary to have a routine in-house verification system whereby the accuracy of these monitoring devices is checked (see 1.5.5). Records of such verification checks should be maintained. A calibrated Master/Reference probe thermometer may be used to verify the accuracy of other probes and temperature displays in use. Iced/ boiling water may also be used to verify probe thermometers. A calibrated weight, or weights, may be used to routinely verify the accuracy of scales. NB Calibration here means the testing and adjustment of equipment by the manufacturer or qualified agent who would normally provide evidence of the work by the provision of a certificate to this effect which would normally be valid for 12 months. However, if the manufacturer recommends a different frequency this should be adhered to. Document the procedure you will follow in the event of equipment failure. Include details of how product will be quarantined if defined limits have been exceeded. Record incidents and Corrective Action taken (see 2.3). Conduct and record a risk assessment of processes where controls are needed, and introduce a system of recording instances of failures in these processes and Corrective Action taken. Keep records of calibration for all relevant devices. External calibration companies will usually affix a sticker that identifies the date calibration took place and/or provide a certificate relating to the equipment tested. Keep records of routine inhouse verification checks. You should have a written procedure specifying how you deal with Quantity Control for your products. You may wish to include details of any Quantity Control training provided in your staff training records (see 1.1.1). Guidance Notes Issue 2, January

20 Such certificates of calibration should be held on file as evidence of calibration having taken place. Verification here and in Requirement means internal routines to cross-check equipment against other equipment or standards which are recognised to be accurate. (eg melting ice/boiling water for thermometers; weights for scales) All other devices and equipment (not covered in 1.5.4) used for monitoring production processes and product quality shall be regularly checked and adjusted if necessary. Equipment used for Alcohol by Volume (ABV) measurements for HMRC must be included in this Requirement. This requirement only refers to devices and equipment that are NOT used to ensure legality or food safety. a. Identify all other devices and equipment (apart from that for 1.5.4) which are used for process control, but may not necessarily be essential for legal compliance or food safety. This may also include the same items listed in (such as thermometers, weighing scales, ph meters, refractometers pressure or vacuum gauges, chart recorders and data loggers) and where comparison against international standards is not essential. b. Carry out a routine verification check to confirm that the identified equipment is sufficiently accurate to ensure your process conditions are under adequate control to maintain product quality within specification. In most cases it would not be expected that verification includes comparison with calibrated equipment. Don t forget to include any automatic chemical dosing equipment. The accuracy of in-line carbonators should be checked against offline Carbon dioxide (CO2) results. Hydrometers, to be accurate should be inspected to ensure they are intact and clean. Refractometers should be checked e.g. weekly Keep calibration records. Keep records of any verification checks carried out. Keep calibration records. Define the difference between off- and on-line results that may be considered significant There shall be a system of quantity control in place to ensure the product complies with Weights and Measures legislative requirements. Make sure that you have up-to-date information about the aspects of Weights & Measures legislation which applies to, and/or which you are using for your product(s) (eg minimum weight, average quantity, average weight, measuring container or quantity). Make sure staff are appropriately trained to deal with your control system. If the quantity of the product is not governed by legislative requirements (eg bulk quantities), check that the product conforms to the customer s specifications. You should have a written procedure specifying how you deal with Quantity Control for your products, and records to demonstrate effective application and compliance. You may include details of any Quantity Control training provided in your staff training records (see 1.1.1). Guidance Notes Issue 2, January

21 For casks and kegs, the brewer must take 1 container per filling head per day or 0.1% of production if filling over 4000 containers per day. Smaller brewers (<60,000Hl/per annum) could show that their cask population is satisfactory (bought to a specification including capacity and undamaged) if they brim-fill. For bottles, an automatic system can be used and test bottles presented at regular (suggest hourly) intervals. Alternatively, a gauge may be used, in which case bottles must be e-marked. One from each filling head should be taken at each test. For cans, an automatic device is preferable, otherwise a statistically valid sampling plan of weight-checking should be in place (also applies to 5L cans). Take-home packs such as PET bottles are exempt from Weights and Measures. Good practice is to brim fill. Record fill results, perhaps on process control/packaging sheets. The site should be in compliance with the current British Beer & Pub Association Large Pack Code of Practice (i.e. kegs and casks) Guidance Notes Issue 2, January

22 1.5.7 Beer The business shall ensure the filling operations are effectively controlled with regard to quantity control (volume), cleaning, foreign body control Filling the process step of filling should be considered when developing the Hazard Analysis for the site s operations Foreign Body Control Where packing into glass containers, it would be expected to have a written instruction detailing exactly what action(s) is to be taken when a breakage occurs on all parts of the line - these actions may be different for different parts of the line. For manual filling lines this should include removal of bottles from the head where the breakage occurred and those surrounding it (any bottles that are open to contamination). Bottles from these heads should also be removed on subsequent revolutions of the filler. For lines with automatic wash-down systems, the system should be tested (start, end and hourly suggested). Training records would be expected to be available for staff undertaking this work. Washing For bottle and can rinsers, checks (at start and end of run and preferably hourly throughout the run) should be in place to confirm that there is sufficient water pressure and that jets are not blocked water should reach the base of all inverted bottles. If Empty Bottle Inspectors (EBIs) are in place, the EBIs should be presented with test bottles (start, end and hourly minimum). For automatic washers, the manufacturer s recommendations should be followed. Hand bottling hand filling procedures should be in place to ensure they are clean before filling i.e. cleaning/washing in potable water (ideally filtered) and then inverted or blowing with filtered compressed air whilst inverted. Keep calibration records. Define the difference between off- and on-line results that may be considered significant. Capping (hand/automatic) Caps must be stored in a hygienic manner prior to use. Cap crimping the use of a Go-no Go gauge should be used to check correct crimping. Records should be kept. Hourly tests are recommended. For manual capping operators are recommended to wear disposable gloves when handling caps during capping to minimize cross-contamination. Storage of bottles/cans During the filling operations bottles and cans must be stored in an appropriate manner to minimise foreign body contamination. See (Beer) Sterile Filtering (bottling) The accuracy of in-line carbonators should be checked against offline Carbon dioxide (CO2) results. For Quantity Control see Requirement/Clause Guidance Notes Issue 2, January

23 1.6 Control of Raw Materials Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips A supplier assurance system shall be in place to ensure suppliers of raw materials are reputable The business shall ensure that adequate specifications exist and are regularly reviewed, for all bought-in raw materials including food contact packaging. It is advisable, unless buying from a well-recognised supplier operating to a national Quality Assurance Standard (eg buying from a major multiple), to carry out your own investigation as to whether or not your raw materials come from a safe source. When receiving raw materials they should be checked to make sure they are sound and true to the specification. If products are analysed to make sure there are no harmful levels of harmful bacteria or chemicals, records must be kept. If appropriate, make sure Requirement concerning provenance is applied. The method of supplier approval is very much size-dependent. For a smaller brewery the use of suppliers which have a good reputation within the industry and have caused no issues at the brewery would suffice; larger breweries would be expected to use either a supplier questionnaire or obtain annual certificates of third party audits on food safety compliance (e.g. BRC, SALSA, STS or UK Assured Malt Scheme). Either way, records are needed. Supplier performance should be reviewed periodically. Letters of Guarantee might be sought to ensure that legal requirements are met (e.g. N-Nitrosodimethylamine NDMA - in malt). You should have specifications for all the raw materials used to make your products, both food and food-contact packaging. It is strongly recommended that you seek to obtain these specifications from the supplier BEFORE placing an order to purchase. The ability of a supplier to provide a suitable specification can be a good indication of the supplier s suitability and capability and should be taken into account as part of the supplier approval process. The details of the specification should include all relevant aspects of food safety (eg shelf-life, storage conditions, allergens, ingredients etc) and should indicate the date of issue and the person who issued it. If the supplier is not able to provide a suitable specification, or you are not satisfied with the information provided, then it may be necessary for you to ask the supplier to complete your own specification form. An example of such a form, including the typical information required, is given in the Example Record in the Tools & Tips. Document your supplier assurance procedure and keep records to demonstrate you are satisfied that they are suitably reputable. Conduct a risk assessment on what supplier approval system is appropriate for the size of brewery site. Check audit directories e.g. SALSA Directory or BRC Directory to confirm if a supplier has an up-to-date certification. Keep records of their approvals. Review supplier performance annually and document any area for improvement. Document a list of your raw materials and your planned review frequency. The specifications may be stored either electronically or on paper. The review may be evidenced by recording a review date on this list or by signing and dating a printed copy of the specifications themselves. Any changes you have made as a result of the review should be recorded. Guidance Notes Issue 2, January

24 The specification for all packaging material in contact with food must confirm that it is safe for use in contact with food. This includes any packaging material (eg plastic film) which may be used temporarily to protect the food during processing. When reviewing your specifications, you should ensure they all accurately relate to the raw materials you are currently purchasing. Check that their ingredients are accurately reflected in the label declaration of the products in which they are used (see 1.12). Consider any changes you may have made to the products and/or processes that these raw materials are used in and if they are still suitable. Don t forget to ensure you have specifications for any new raw materials you may purchase, or to archive or destroy any that relate to materials you no longer use. The frequency of the review should relate to the nature of the raw material concerned. As a guide, an annual review would be appropriate for food raw materials containing multiple ingredients, and for printed food-contact packaging. On the other hand, for raw materials containing a single ingredient and for plain food-contact packaging a 2-3 yearly review may be adequate. Consider any provenance issues which may be applicable (see 1.12 and 2.4.2) The business shall carry out checks to ensure raw materials are manufactured to the agreed specifications Water shall be potable, and shall not present a contamination risk to products. You will have to keep records showing where and from whom you are buying your products/raw materials. If necessary, you may have to seek further information from your supplier if it is not obvious where the product has come from (eg buying soft fruit from a farmers market). You may have to make a risk-based decision as to whether or not you continue to use a supplier if you are unable to assess the safety of your supplied raw materials. The minimum expected is a visual inspection of goods upon receipt and visual and organoleptic inspection of the vehicle and any accompanying goods. Certificates of analysis or conformity might be expected for malt and hops. More This is not an issue where mains water, without any intermediate storage, is used for all processing and cleaning operations. If stored mains water or non-mains water or private supply water is used (whether as ice, liquid water or steam) for any processing stage, hand washing or cleaning of utensils or factory environment, then it is essential to carry out regular testing, by an accredited laboratory, to monitor the quality of the water used. The laboratory will be able to tell you what the acceptable limits are for the test results. Document your intake procedure and keep copies of intake records. Record results in Brewing and Packaging records. Keep records of private supply or non-potable water testing and any Corrective Action taken when results indicate this is necessary. If using non-mains water, make sure you have a written Action Plan ready in the event you receive a non-conforming water testing report. Guidance Notes Issue 2, January

25 If bore hole or spring water is used it must be registered with the local authority and tested by them. This is a legal requirement. If steam comes into contact with the product or packaging (eg keg and cask sterilisation), condensate should be tested. Internal water treatment systems (eg softening, reverse osmosis, filtration, carbon filtration) must be included in the HACCP plan. Water used for brewing or processing should be regularly tasted, preferably each day beer is brewed. Keep results of water analysis Beer Malt and hops shall be stored in such a way as to prevent deterioration or contamination. Storage to be clean, dry and off the floor to prevent pest infestation. Hops should preferably be stored cool but must not be subjected to heat. Raw materials to be arranged in such a way as to enable a First-In First-Out (FIFO) approach to stock rotation. Any external storage facilities should be accredited to a third party standard or visited regularly. Could be included in site hygiene checks Beer Suppliers of services, such as contract bottlers, shall be approved and controlled. This can take the form of third party accreditation or an audit of the supplier by brewery personnel. It is advisable to oversee an occasional bottling to ensure that systems are satisfactory and being followed. The easiest way is to keep an up-to-date copy of any third party certification (eg SALSA, BRC) that the supplier has. 1.7 Stock Control Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips A system shall be in place to facilitate correct stock rotation and to ensure that raw materials and intermediates are used within their allocated shelf- life. Ensure you can easily identify when stock was delivered so that you can use stock on a first-in, first-out basis. Make sure all date codes are adhered to. If using ingredients with Use By dates without any further processing, make sure that the final date code for your manufactured product does not exceed this. Check that the shelf-life of intermediates are compatible with the shelf-life of your finished product i.e. foods used as an input in the production of other foods such as flavourings and colourings, or, where one food such as pastry is made and held for further processing. It is an offence to alter or remove a Use By date mark if you are not yourself the person who originally applied the date mark, or do not have their written permission to make such a change. Make sure that you have a system which enables you to track the stock used in your finished product (see 2.4, Traceability). Have a written procedure detailing how you deal with Stock Control in your business. Carry out regular stock checks and make sure this is recorded on a checklist. Guidance Notes Issue 2, January

26 1.7.2 Incoming goods shall be identifiable and where appropriate, be thoroughly checked on arrival for temperature compliance, damage, cleanliness and the absence of pest infestation. Ensure that all stock is suitably labelled so as to easily identify what it is. Check all stock on arrival before acceptance. If there is any doubt as to its suitability for use, (eg further tests required, awaiting a certificate of conformance or analysis), the stock should be clearly marked as being unsuitable for use and if appropriate, placed in a designated (Quarantine) location (see Corrective Action 2.3). Make a record of the checks & the findings on, for example, a Goods In record or the delivery notes. It may be appropriate to have a documented Goods In procedure or Work Instruction for the appropriate staff to follow. 1.8 Waste Control Ref Requirement What do I have to do to comply with this requirement? How can I demonstrate this? Tools & Tips Systems shall be in place to minimise the accumulation of waste in handling and storage areas. Waste must be regularly and effectively removed, paying particular attention in food processing areas to avoid any potential for crosscontamination from waste to food. Ideally, waste bins in processing areas should be lined, and have footoperated lids. Waste bins and the area around bins must be clean and tidy. You should have a document detailing all the controls you have in place for Waste Control. Make sure that the waste containers are listed on your cleaning schedules. Consider how to record the monitoring of Waste Control External waste collection containers and compactors shall be managed in such a manner as to minimise risk and pest harbourage Products that require specific conditions for disposal shall be separated and disposed of using licensed contractors. External waste areas must be clean and tidy. Waste should be suitably packed before being removed to external collection points (usually tied black bin bags). External containers should be lidded or covered to prevent attracting flies or vermin. A suitably frequent uplift of waste should be in operation to avoid waste containers being too full to cover properly or from overflowing. Contract arrangements must be in place which are specific to the type of waste, eg oil disposal, meat and fish waste etc. Make sure that the uplift arrangements are suitably frequent in order to avoid the build up of waste. The waste area should be listed on a cleaning schedule (see and 1.3.2) or if cleaning is contracted out, details of the contractual agreements kept. Details of the contractual agreements should be kept. Where disposal is monitored by the Environment Agency, ensure the contractor is authorised by the Environment Agency to dispose of this waste by keeping a valid copy of the certificate issued by the Agency. Guidance Notes Issue 2, January

27 Ref Requirement What do I have to do to comply with this requirement? How can I demonstrate this? Tools & Tips Beer If spent grain, yeast or ullage is sold or given for animal feed, where product from the animals will continue through the food chain, this must be included in the HACCP plan. If spent grain, yeast or ullage is sold or given for animal feed to members of Assured Food Standards schemes, the business must operate to a suitable feed materials assurance scheme standard. The business should demonstrate certification to one of the feed assurance schemes accepted by Assured Food Standards schemes. Accepted schemes include those operated by: Brewing, Food & Beverage Industry (BFBi); Feed Materials Assurance Scheme (FEMAS); and Universal Feed Assurance Scheme (UFAS). If you operate and are certified to these schemes, the requirements will be met. Spent grain should be regularly removed. Grain awaiting removal should be stored so as to minimise any chance of contamination or pest infestation. Any spent yeast should be stored cool if it passes into the food chain. Include in the HACCP plan. Retain certificates for assurance accreditation. Check storage temperature Beer Recycling/purification shall be undertaken where economic. Effluent plants shall be positioned so as not to affect the product. Consider the economics of reducing effluent. Effluent plants positioning should be away from entrances. Reed beds can be effective but the possibility of pest infestation should be considered. The auditor will assess this during an audit. 1.9 Pest Control Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips The business shall either contract the services of a competent pest control organisation, or shall have trained personnel, for the regular inspection and treatment of premises to deter and eradicate infestation. Where the services of a pest control contractor are employed, the service contract shall be clearly defined and reflect the activities of the site. If setting up a new contract with a pest control organisation it is recommended that they are given a copy of this section of the Guidance Notes, so that they are fully aware of the SALSA requirements and can quote for the appropriate level of service. If a pest control contract is in place, check what is covered by the contract is suitable for the production and the premises, and complies with the requirements of this section. As a minimum, this should state the number of visits, the pests covered and if trend analysis is included. The contract should also indicate if it includes the servicing, tube changing and catch tray counting of any fly-killers. Competency of the organisation is supported by certificated membership of the British Pest Control Association (BPCA) or the National Pest Technicians Association (NPTA), and certificates to demonstrate that the individual(s) who carry out the service are suitably trained. If a pest control contract is not in place, then it is essential that the premises and products are checked regularly for any sign of pests and appropriate action taken in the event that pests are discovered. The action taken in the event of discovering the presence of a pest may be to call in a pest control organisation. If pests are tackled in-house, then the person(s) responsible for pest control must be able to demonstrate that they have received suitable training to be able to carry out suitable and effective remedial action. If you use a pest control organisation, check that the contract details are available and a report issued at each visit. If pest control is carried out inhouse, document the full details along with the training records of the person responsible. Guidance Notes Issue 2, January

28 1.9.2 The location of all pest control measures shall be identified on a plan/diagram of the site Inspections shall be at regular intervals and documented records shall show details of any pest activity and pest control treatments undertaken at individual pest control points Records of recommendations made by the contractor or inhouse expert along with details and dates of actions taken, shall be maintained Results of pest control inspections shall, on a regular basis, be assessed and analysed for trends. When trends are identified, If you have a pest control contract, you should have a description of where any pest control measures are located. If you do not have a pest control contract, make sure that if you are using any pest control measures (baits, traps, electronic fly-killers etc), that they are clearly illustrated and marked on a site diagram and that these can be identified in the pest control records. Inspections should be at planned regular intervals with a call-out facility available in the event of a pest problem. A report should be created following each pest control visit. Records of all in-house checks and their findings must be kept and made available for inspection. Inspection findings at individual pest control points, including fly-killers, should be recorded in manner that enables trend analysis to be carried out (see 1.9.5). Any pest control treatments should be recorded and it should be clear what treatments are used at each pest control point. UV tubes in fly killers should be changed at least annually, preferably in the spring. The tubes should be shatterproof and included on the glass and brittle plastic register (see 1.4.5). If you have a problem with birds as pests, it is important to take professional advice to identify the species of bird and the techniques available for solving the problem. Remember that is it also illegal to destroy nests and eggs without a licence. Most birds, including sparrows and starlings, are protected under the Wildlife and Countryside Act It is important to take note of the contractor s recommendations (in his/her visit report) for you to carry out repairs, modifications or other actions to minimise the risk of pest ingress/infestation. Often, contractors leave site without discussing their findings. It is advisable to have the contractor s report discussed with a responsible person before leaving the site so that he/she may explain any recommendations being made. You should make a note in the relevant report, of the action actually taken and the date when carried out. If you have a pest control contract, either ensure that the contractor is checking for trends on each visit (eg if there is evidence of a specific pest such as ants or flour moth in the flour store) or that you discuss the results of the visit with the contractor on each occasion in order to remedy any problems arising. Your pest control contract or inhouse documentation should have an up-to-date plan or diagram of the site with the pest control stations, including any fly-killers, marked on them. Check your pest control records to ensure that your contractor (if used) is demonstrating compliance with this Requirement and guidance. Check that your pest control records are kept up to date and make sure that any recommendations have been followed up, carried out, and signed off. Note: Some recommendations may be for the contractor to carry out on a future visit; others may be for you to take action; for example, repair an external door or cut the perimeter grass. If requested, your pest control contractor should include this in the contract, carry this out for you and record in it the pest control file. Or, if carrying out Guidance Notes Issue 2, January

29 Corrective Action shall be taken to eliminate further risk to product safety All products shall be stored in a manner so as to minimise the risk of infestation. Where stored product pests are considered a risk, appropriate measures shall be included in the pest control programme Baits and other materials such as insecticide sprays or fumigants shall be applied and used safely. Documentation on their safe use shall be held on site. It is easiest if the contractor records his findings at each pest control point, including fly-killers and any pheromone traps, in a manner that enables any trends to be easy to see and monitor any problem or trend. If you do not have a pest control contract, then you should be checking for any evidence of trends on a regular basis. See 1.7 Stock Control. Some raw materials such as flour are susceptible to infestation by crawling insects and moths. To minimise this risk, storage areas should always be kept clean. Ensure your pest contractor is made aware of the types of raw materials being stored and used on your premises. External doors to any storage or production areas should be kept shut when not in use, or suitable protection fitted to the opening to minimise the possibility of pest entry to the premises (see 4.6). If a malt silo is used for bulk storage it should be subjected to inspection at least annually. This should include conveyors. If not using a pest control contractor, any pest control chemicals used must be approved for use in food premises, and be used in such a way that they do not pose any risk of contamination of food. Pesticides, if stored on site, must be clearly labelled and stored in locked cupboards accessible only by trained personnel (see 1.4.5). Toxic baits should not be used in production or packing areas unless this is required to eradicate a problem. in-house pest control, make sure that you document any trends. Your pest contractor will advise you on any specific action you may need to take or any special pest control measures that may be necessary. Look out for any recommendations made by the contractor (see 1.9.4). Ensure site s pest control contractor includes this in their records. Keep all documentation and COSHH (Control of Substances Hazardous to Health) sheets for pest control chemicals on file. Ensure that the COSHH safety data sheets are specifically for the UK, including UK emergency contact numbers. Make sure you have documentation for all chemicals in use both inside and outside the premises Equipment Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips Equipment shall be fit for purpose, constructed of appropriate materials, positioned so as to give access under, inside and around it for ease of cleaning and servicing. Where permanently sited, equipment shall be properly sealed to the floor. Equipment should be: Able to be cleaned effectively. Positioned safely and to provide sufficient access for both use and cleaning. Equipment should be: Suitable for the intended purpose. In good repair. Made of food grade material (ie the parts which come into contact with food). Ensure the equipment is included on the appropriate cleaning schedule (see 1.3.1). If the equipment needs to be maintained or serviced regularly, this should be listed on the Maintenance Control Sheet or Schedule (see ). Guidance Notes Issue 2, January

30 Be particularly aware of dead legs in piping as they can lead to infection. External pipes should be capped. Packaging conveyors must be covered from rinser to capper. Conveyor drive motors must have a catch-tray fitted if over lines This will be assessed during the audit Maintenance Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips Planned maintenance systems shall be in place for premises and equipment critical to product safety, legality and quality. Make sure that maintenance is planned in advance. Do not wait for equipment to break down before maintaining it (see also 4.7). Make sure that pot/pan/utensil washing machines and Clean in Place (CIP) systems are addressed (see also 4.4). If you carry out your own distribution of product, make sure that the vehicles you use (and where applicable, their refrigeration equipment) are included in your maintenance system. Document your equipment that requires planned maintenance and include it on a schedule. Keep records of maintenance carried out (See also 4.7) The business shall ensure that the safety, legality and quality of product is not jeopardised during maintenance operations Cleaning and/or replacing light fittings and glass shall be carried out in a manner to minimise the potential for product contamination. There are few items in a brewery that require maintenance (eg cooling and packaging equipment) but spares should be available for items, such as pumps, that may affect process schedules. It is important that staff and contractors are aware of their responsibilities with regard to avoiding any possibility of contaminating food when carrying out maintenance. As far as possible, carry out maintenance when food is not being produced. If lubricants are used on equipment positioned over products, they must be food grade and not pose a contamination risk. Avoid temporary repairs with materials that can themselves cause contamination (string, cardboard, paper, sticky tape). These requirements could be included in a Visitor Health Status Questionnaire along with relevant Company Rules on Personal Hygiene (see 1.1.2). Where possible, carry out any high level cleaning and bulb replacement outside production times. See also 1.4.5, Contamination/Cross-Contamination Prevention Document a risk assessment on what maintenance is required, implement a maintenance programme and record what is actually done. Your Maintenance Procedure (above) should specify what is expected (eg contractors must agree to check and remove all tools and items such as nonessential nuts, bolts, springs etc). Your Maintenance Procedure (above) should detail how and when light tube/bulb changing and cleaning is to take place. Guidance Notes Issue 2, January

31 1.12 Labelling Control Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips There shall be a system in place to ensure the labelling of product fully conforms to legislative and where appropriate, customer requirements. Make sure that you have up-to-date information about the aspects of labelling regulations which apply to your product(s). Be aware that in 2016 it will be mandatory to include Nutrition Information on your labels if you do not already do so. All label details and claims must be true, clear, accurate and verifiable. Validate claims by checking back to raw material specifications (see 1.6.2) and production recipes. The use of a label copy checklist is often helpful. It can help to keep your completed checklist with the relevant product recipe, finished product specification, a copy of the approved label/outer packaging and where an external printer has been employed, a copy of the artwork you have approved. You may find it useful to check your labelling information with your Local Authority (if service available) or via SALSA s own label-check service/food labelling workshops. Compile a labelling procedure and make sure that you retain copies of approved labels and relate them to product recipes. Make it clear how you have verified that your labels comply with legislation whether this be internally or via a third-party (such as Trading Standards or SALSA). 1.12a STS Chilled, ready-to-eat products shall indicate store at 5 C or below on all primary, retail and outer packaging (if used). Include this requirement in your label copy checklist. Self-evident on printed labels and packaging Third Party Distribution & Storage Control Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips 1.13 Where third party distribution is involved, there shall be an agreement in place to ensure the integrity and safety of the product is not compromised during storage and/or distribution to the customer. This requirement relates to distribution of product by third parties such as haulage contractors or postal services. The requirements for own vehicle distribution can be found in (Cleaning), (Temperature Control) and 1.11 (Maintenance). It is advisable to continue monitoring finished product through storage, loading, transporting and delivery to the customer. Make sure that all aspects of storage conditions, hygiene, crosscontamination control and temperature control relating to your product are monitored. This may involve checking suitability of outer packaging, mixed loads, vehicles, transporting times, transfers and personnel involved in distribution. Where distribution is contracted out, keep a copy of the agreement which should include all relevant SALSA Requirements which relate to the safety of the product. Where distribution is by postal/ courier services or similar, keep a copy of the service levels which are operated by the distributor. Guidance Notes Issue 2, January

32 1.14 Product Shelf-Life Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips 1.14 There shall be a system in place to ensure that the minimum durability (shelf-life) applied to products is determined and checked using appropriate verification techniques. It is a mistake to make any assumption about the shelf-life of your products based on similar products in the market. By all means, use other companies products as targets or guidelines, but you must check the shelf-life of your own products and keep a record of the results. For ambient stable products (eg preserves, soft drinks) and low risk perishables (eg bakery, hard cheese) the easiest way is to keep products back from production runs and look at them and taste them periodically throughout the expected shelf-life and make any adjustments necessary with subsequent production runs. Depending on the microbiological stability of the product(s), you should consider the need to carry out microbiological testing to validate your findings. For high-risk products and ready-to-eat products (eg cooked meats, fresh dairy, pasteurised fruit juices etc) you will need to prove the intended shelf-life is microbiologically safe and the product does not spoil within the shelf-life, taking into account normal expected consumer storage and use. Don t forget to ensure your Finished Product Specifications show the shelflife and the storage conditions associated with it (see 3.2). For beer, shelf-life tests are mainly based on tasting. Some microbiological testing is also advisable. For small-pack products whole packs should be retained for the shelf-life. These can also act as reference samples in the event of a complaint. For full packages where storing a whole keg or cask is not feasible, subsamples may be taken, though it must be borne in mind that this is not a true reflection of beer from full packages. Forcing tests may be useful for predicting the haze stability. Shelf-life of cask beer, once broached, should also be confirmed by shelf-life testing. Low risk foods: Records of visual and taste assessment of retained samples from a production run. Re-check periodically. High risk foods: Records of visual and taste assessment AND microbiological test results proving the suitability of the Use By date. Periodic retesting should be performed throughout the year. The frequency of testing should be based on your own risk assessment which includes the susceptibility of the food and the results of previous tests. Record results of taste tests at all stages. Guidance Notes Issue 2, January

33 1.14a STS Shelf-life testing shall include analysis for Listeria monocytogenes in products that support the survival or growth of this pathogen. Because the public sector provides food to those who are susceptible to serious infection from this pathogen, STS s Public Sector Code of Practice requires that Listeria monocytogenes must not be present in any of these products which the public sector purchases. Shelf-life testing must include analysis for Listeria monocytogenes in products that support the survival or growth of this pathogen. This includes products that require chilled storage, have a short shelf-life and are ready-to-eat. The testing regime should be carried out at a temperature of around +5 C and must include a period when the product under test is stored at ambient temperature of +18 to +22 C for 4 hours. This is to represent possible temperature abuse during storage by the customer. Depending on risk, additional storage temperature abuse testing may be necessary. More Shelf-life testing on a representative range of these foods should be carried out at least annually. If a significant change is made to either the formulation or the processing of these foods, then shelf-life testing must be carried out again and the need to review your HACCP plan should also be considered. Follow a suitable sampling and testing plan which covers a representative range of finished products for microbiological safety, including Listeria monocytogenes, at least at the beginning and end of the specified shelf-life. Ensure that the testing plan states the test storage temperature and includes More at least four hours of storage at ambient (+18 to +22 C). The results of the tests should demonstrate that when tested on the last day of the product s stated shelf-life, the levels of bacteria are no greater than those stated in the finished product specification stated in 3.2 and specifically that Listeria monocytogenes is not detected in a 25g sample. SECTION 2 - HACCP & MANAGEMENT SYSTEMS Statement of Intent All hazards to product safety and legality shall be identified, analysed and assessed for risk. A documented HACCP (hazard analysis and critical control point) system, based on Codex Alimentarius principles, shall be in place alongside an effective management system encompassing regular systems reviews and procedures for Corrective Action, traceability, incident management and complaint handling. What does a Statement of Intent mean? The Statement of Intent summarises the overall aim of the section that follows. The SALSA auditor will check each requirement during an audit. Should the auditor find that there is a substantial failure to meet the requirements of the section, it is likely that the supplier will also fail to comply with the overall Statement of Intent and result in an unsuccessful audit. 2.1 HACCP Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips The person responsible for undertaking the hazard analysis shall be able to demonstrate competence in It is important that those responsible for HACCP are able to show that they understand and can apply the principles of HACCP to your business. This usually implies evidence of formal training but demonstrable experience may suffice in some circumstances. Your training records can provide evidence that training/learning has been undertaken. Guidance Notes Issue 2, January

34 the understanding of HACCP principles and their application. If a consultant has developed your HACCP system or you have taken a generic ( off the shelf ) system and adapted it for your business, then that can be very effective. However, it is essential that those involved with the day-to-day running of your business have a good, clear understanding of what it means in terms of risk and product legality and safety. If you are a member of a sector trade association, they may provide guidance on HACCP for your particular food sector. Again, if this is used, it is essential that it is adapted to suit the needs of your business. This can take the form of formal training such as attendance at a SALSA or any other accredited HACCP course (not on-line), or one-to-one instruction from a qualified mentor or a suitably trained member of staff Conduct a Hazard Analysis by identifying the cause/source of any physical, chemical and biological hazards (including allergens) that must be prevented, eliminated or reduced to acceptable levels. There are a variety of ways in which to do this. A very simple method is to: Take each step of your process (eg purchase, storage, preparation etc through to distribution). Decide what hazards could potentially occur at each step (physical, chemical, biological, allergens) and their likely cause/source. You may identify more than one hazard at each step. If so, they should be considered separately. Process flow diagrams will help you identify hazards and their source. The use of a suitable table to record your findings will help to document this. You may decide to adapt generic material used in training courses or issued by your trade association Conduct a Risk Assessment of the physical, chemical and biological hazards (including allergens) identified in that must be prevented, eliminated or reduced to acceptable levels. In conducting a Risk Assessment, you will need to decide which hazards are realistically likely to happen (likelihood or probability of occurrence) and which hazards are genuinely harmful if they do occur (severity of occurrence). The method below is described in more detail in Tools & Tips. The likelihood of a hazard occurring could be measured as: High: likely to happen, could happen often/frequently. Grade as 3 Medium: could happen, but not frequently. Grade as 2 Low: unlikely to happen/rare occurrence/remote chance. Grade as 1 The severity of a hazard occurring could be measured as: High: likely to cause severe injury or death. Grade as 3 Moderate: would cause reversible illness/minor injury. Grade as 2 Negligible: would cause very slight/no injury. Grade as 1 Then, multiply the likelihood by severity to give the risk score: (L x S = R). In this situation a risk score of 3 or higher would be considered significant and further consideration beyond what you have in your Prerequisite Controls (section 1). Explain in your documentation how you have conducted your risk assessment. On the basis of the risk assessment, it may be considered that the majority of the hazards inherent in the brewing process can be controlled by a prerequisite programme: Some physical contamination is not a food safety issue in some beer types (e.g. cask beer). This premise can eliminate this particular issue from the The use of an appropriate table to record your findings will help to document this. You may decide to adapt generic material used in SALSA or other accredited HACCP training courses, given in the Tools & Tips or issued by your trade association. Include the risk assessment in the site s HACCP plan. Guidance Notes Issue 2, January

35 HACCP study, though Good Manufacturing Practice (GMP) dictates their exclusion from the product altogether. Pathogens cannot grow in beer with an ABV of 3% and microbiological contamination is, in the main, a quality/spoilage, rather than a food safety issue. However, the contamination and growth of bacteria such as Obesumbacterium proteus can lead to nitrosamine production (ATNC). Other microbial contamination can lead to beer spoilage and prevention is therefore Good Manufacturing Practice. Cross-contamination is unlikely to be a food safety issue in brewing as all products contain similar raw materials but the HACCP study should include a risk assessment on the effect of any possible crosscontamination. This is particularly important where unusual raw materials are included in one particular beer. (see 1.4.3) Identify the Critical Control Points at the step or steps at which control is essential to prevent or eliminate a hazard or to reduce it to acceptable levels Establish Critical Limits at Critical Control Points which separate acceptability from unacceptability for the prevention, elimination or reduction of identified hazards. Once you have assessed the risks as outlined in 2.1.3, you will have to decide which of your steps may represent a Critical Control Points (CCP) in the following manner. See Tools & Tips for more detailed explanation. Look at each significant hazard and decide at which step in the process that this hazard is already or if not, should be, controlled. Use a tool such as a decision tree to help you decide whether or not the process step is considered a CCP. CCPs will normally be at the last or only step in the process where the hazard can be controlled (eg metal detector or cooker). You must decide the Critical Limits for your Critical Control Points that will result in a safe process. Be aware that some limits may also be legal requirements (eg milk pasteurisation temperatures). Your Critical Limits must state the minimum and maximum permitted ranges to control your process (eg if you are storing fresh meat, your minimum refrigeration temperature could be +1 C and your maximum temperature could be +4 C). Clearly document your Critical Control Points. This can be done by marking them on a flow chart and highlighting in a risk assessment table or by listing them separately. You may have already documented your Critical Limits in your Prerequisite Controls records Establish and implement effective monitoring procedures at Critical Control Points. Monitoring means to check. There are a variety of ways in which you can check Critical Control Points (you may also be checking other Control Points as well). You might: Carry out visual checks such as the integrity of a filter or a sieve. Check temperatures/brix level/metal detector reject settings/ph. Suitable monitoring (checks) for CCPs must be able to identify the nature of the problem in time for it to be corrected before finished product leaves the premises. The results of all CCP monitoring must be recorded by the (trained) person carrying out the monitoring. You can record your monitoring methods in a variety of ways. For example, you can monitor cleaning by making sure the cleaning operator signs/initials a cleaning record. Temperatures can be entered on a sheet Establish Corrective Actions when monitoring indicates that a Critical Control Point is not Effective monitoring will indicate if a control is not as it should be. For example if your Critical Limits for refrigeration are +1 C to +4 C but records show consistent readings of +6 C to +11 C, then Corrective Actions are required. Your Prerequisite Control documentation from Section 1 should have the necessary Guidance Notes Issue 2, January

36 under control. You must make sure that staff involved in monitoring Critical Control Points know what immediate action to take if the critical control point is out of control. For example, the Corrective Actions for the fridge temperatures running too high might be: 1. Decide if the product in the fridge is safe to use. 2. Dispose of product or move to a functioning fridge. 3. Adjust fridge temperature control to achieve correct temperature. 4. Call fridge engineer if fridge still not functioning etc. An example, relevant to brewing, is that if the lower Critical Limit for the pressure of rinse water in bottle washing is 2 bar and it is below 2 bar, then the rinse water may not reach the bottom of the bottles meaning they are not adequately washed and Corrective Actions are therefore required. information, detailing Corrective Actions. For example, your temperature control information should list required temperatures, how to monitor temperatures and what Corrective Actions to take if things go wrong. As above. The Corrective Actions for the above, which would be combined with a check that all jets were working, would be: 1. Stop the line 2. Quarantine product bottled since the last successful Critical Control Point (CCP) measurement 3. Check and repair the fault 4. Restart the line and inspect quarantined product to determine whether it is fit for sale Establish regular checks to verify that the limits and controls outlined in to are working effectively Establish documents and records commensurate with the nature and size of the business to demonstrate the effective implementation and regular review of the HACCP system. Verification means: to confirm that the HACCP system is being followed and that staff understand and are carrying out their instructions. This is sometimes known as the Supervisor/Manager check. This verification (or supervisor check) must confirm that: a. The checks were carried out correctly at the prescribed frequency/times b. The results of the checks are within the prescribed limits c. In the event of either of the above not being compliant, appropriate Corrective Action has been taken and recorded by the operative and/or the supervisor carrying out the verification d. The frequency of these verification checks may be daily or possibly less frequently, but should be such that any at risk product should not have left your control or reached the consumer. You may also wish to take account of any testing which has been carried out such as microbiological testing on high-risk products and ingredients. Your HACCP system should be reviewed at least annually or when any new practices, process or product changes are being introduced, to ensure that it still reflects your current practices and/or your proposed changes are appropriately controlled and monitored. Questions you should seek the answers to are: Have there been any changes to: The way we make our products since we created or last reviewed our HACCP system and do these changes require a change to the process flow diagrams? (If they do, then it is likely that the rest of the HACCP system will need some revision). Have a supervisor/manager checkbox for signature/dating on your Monitoring records (eg temperature monitoring sheets, cleaning records, delivery/ dispatch records etc). Create a separate checklist for verification such as a daily or weekly check which will list all your Prerequisite Controls (Section 1) and have a review section for Corrective Actions entered in the Monitoring records (see 2.1.5). You should make a record of your HACCP system review and document your findings and any action(s) you may, or may not, have taken as a result. Don t forget to ensure that any revised HACCP documents should be Document-controlled (see 3.1). Guidance Notes Issue 2, January

37 Have there been any changes to: Raw materials or suppliers? Ingredients or recipes? Processing methods or equipment? Packaging, storage or distribution methods/conditions? If the answer to any of these questions is Yes, then you will need to consider if your HACCP system needs to be changed or adapted. If all of the above have been taken into account, then you should have sufficient documentation to cover the HACCP system which you have in place (see 3.1). More At least one person, who shall be able to demonstrate competence in HACCP principles, shall be present and responsible for the implementation of the business s HACCP plan at all times during production. You should also take the opportunity to consider if any incidents have taken place which might indicate that your HACCP system is not working as effectively as it should do. Take a look at your: Customer Complaint or enforcement authority records. Incident or Non-compliance records. Product Recall incidents. All documents associated with the development and ongoing application of the HACCP plan and associated records should be retained on file to demonstrate that product safety has been actively managed and achieved. These documents and records should be included as part of the review process. The most effective way to ensure you can comply with the requirement is to ensure the person(s) responsible for daily production is/are trained in HACCP principles and in the application of the business s own HACCP plan. The actual level of knowledge expected will depend on the type and size of business and how production is managed. The key point is that the staff member responsible must show they know what to do if a Critical Control Point is out of the defined limits. SALSA Mentors are qualified to give HACCP training and guidance and many are accredited to issue certificates through recognised awarding bodies such as CIEH (Chartered Institute of Environmental Health) and REHIS (Royal Environmental Health Institute of Scotland). Alternatively, you may prefer to enrol relevant staff on an external course. Training records of relevant staff and/or certificates of training, if undertaken externally. Ensure relevant staff are keeping records to show Critical Control Points are under control and recording the Corrective Actions taken if they are not. 2.2 Food Safety Systems Review Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips The Food Safety Systems Review (or internal audit programme) shall be carried out and documented at least annually and include all the A food safety systems review (or internal audit) entails the consideration of how you are going about complying with all the relevant requirements of the SALSA Standard, and its efficacy in ensuring you are manufacturing safe and legal food to the desired quality. If you do not already carry out regular internal audits, you should review Keep a record of the review and its findings, when it was carried out and by whom. Guidance Notes Issue 2, January

38 applicable requirements of the SALSA standard. The review shall be carried out by appropriate personnel who shall not review their own work. your entire food safety management procedures regularly. You could use a SALSA Self-Assessment Checklist to do this, available in the Downloads/SALSA Standard section of the website. The review needs to be carried out in a way which avoids reviewing your own work. Therefore, if your business is very small, you will probably need to appoint a competent third party to help you with this, such as a business colleague, fellow trade association member or similar, or an external consultant. NB SALSA Mentors are appropriate for this task and are listed in the Mentors Directory on the SALSA website. The review may be carried out by looking at specific areas of the system, one at a time, over several months, or by considering the whole system in one go. The main consideration is that the whole system should be reviewed at least annually Results of the review shall include a timetable for correction of any noncompliances found and the date the action was taken. Once the systems review (or internal audit) is carried out, it is important to record the outcome and to plan clearly for correcting any aspects which are not as they should be, i.e. non-compliances. For example, the controls you have specified to comply with Section 1 of the SALSA requirements should be in place. It is important to specify an action plan for correcting non compliances and record the planned and actual dates of remedial action (see 2.3). For all remedial actions required and undertaken, keep a record of the target date for completion and actual completion dates. Where relevant, include details of the actual action undertaken. 2.3 Corrective Action Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips 2.3 The business shall ensure that procedures exist to record, investigate and remedy the cause of any product noncompliance including complaints, incidents and substandard product. Records shall be available to the Food Safety Systems Review (2.2.1). The procedure shall include details of how nonconforming product will be quarantined. Any time a product is not up to its normal standard, you need to consider what has been the cause. It may be due to a raw material behaving differently, process equipment failure or inadequate staff training. Where there is any doubt as to the safety and/or legality of the product, it is vital that immediate action is taken to quarantine any affected product and to investigate the cause (see 2.5 Managing Incidents). If a product is quarantined make sure a Corrective Action record is completed (see also Environment & Process Control 1.5.3). If something has gone wrong, it stands to reason that Corrective Action is required, not only to prevent sub-standard product from reaching the customer but also to prevent a recurrence. Having learnt the lesson, Corrective Action should therefore be put in place as quickly and safely as possible. Some Corrective Actions can be predicted and clear guidance put in place for staff to follow. For example, what to do in the event of refrigeration breakdown or glass breakage. (See and also 1.4.4). Consideration must always be given to the safety and legality of your products when Corrective Actions are required. Record and/or report any incidents and noncompliance. Take immediate action to make safe. Identify cause of incidents and non-compliance. Determine suitable remedial action. Implement action. Check action is successful (see 2.2.1, Food Safety Systems Review). Guidance Notes Issue 2, January

39 2.4 Traceability Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips The business shall have the proven ability to identify and trace all raw materials, including food contact packaging, from suppliers through all stages of production to the point of despatch and, where appropriate, delivery to known customers & vice versa. Traceability shall be tested each way at least annually and more frequently if there are known risks in the supply chain. In order to meet this requirement, your systems must be able to trace all of your ingredients and food contact packaging: Back to your supplier. Through all your process steps. To your customers (but not necessarily consumers). This means you need to be able to trace 100% of your finished product, back through the process and to the ingredients and suppliers used and one step forward to where/who you shipped the product. Take care to ensure that this can also be done with any reprocessed material added during the process. When tracing product sent to your customers, you should compare the amount traced (and still on site or in transit) to the amount actually produced. This will require you to ensure that your production and/or stock records clearly identify quantities produced. Likewise, when tracing ingredients used, you should know the quantity of a traced ingredient still in stock (in case you need to quarantine it) or used in other products (in case they too are affected and may need to be recalled). This technique is sometimes known as a mass-balance. You should keep copies of the actual records you have checked when carrying out a trace test to demonstrate the efficacy of the system. Ensure that your goods receipt, storage, processing and despatch records capture the necessary information to trace the relevant raw materials through your factory to your customers and vice versa. Carry out tests of your system. If these tests identify any shortcomings introduce any necessary changes and carry out a re-test. Keep records of these tests and changes (see 2.3 Food Safety Systems Review). Consider the use of the massbalance technique to demonstrate complete control over traceability. Details of how to achieve this are given in Tools & Tips. Beer sold in a Company Shop does not need to be traced to the consumer. If a food safety issue is noted, a recall notice could be placed in the local press; for quality issues a note could be placed in the Shop. Include notification, via local press, of any issues recorded in the site s Incident Management Plan. Guidance Notes Issue 2, January

40 2.4.1a STS For each supplier of meat, the business shall demonstrate traceability of meat back to the farm of origin or source. Suppliers to the public sector must go a step further than legislation dictates with regard to the traceability of meat and meat products to ensure the authenticity of these products. For each supplier of meat, demonstrate that you have traced meat back to the farm of origin or source at least once a year or more frequently if there are known risks in your supply chain (eg of non-eu origin). Make sure you document the traceability system, including references to any records used. Show records of the traceability and/or authenticity tests you have carried out. These records should include copies of the original documentation you have used in the traceability exercise b STS If the business handles or reprocesses meat that has already been processed and cannot be traced back to its original source, periodic authenticity testing shall be carried out. If you handle or reprocess meat that has already been processed and cannot be traced back to its original source, it will be necessary for you to periodically carry out authenticity testing. The frequency of testing should be in relation to the risk. Show records of the authenticity tests you have carried out. Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips Where provenance claims are made on finished products regarding their origin or status (eg Red Tractor, SEAFISH Responsible Fishing Scheme), a system shall be in place to verify the origin of relevant raw materials and the correct use of logos on finished product or packaging. Be aware of any provenance schemes that exist for your industry and the specific requirements for traceability that may exist over and above the principles in above. Consider raw material specifications (see 1.6.2). Consider labelling requirements (see 1.12). All relevant ingredients should be identified and recorded on arrival and itemised when used in production. If segregation of products, or a process step, is required by a Provenance Scheme, records should show how this has been achieved. 2.5 Managing Incidents Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips 2.5 The business shall have written guidance for key staff in the event of any incident which may compromise the safety and/or legality of a product. This shall include customer notification; product withdrawal and product recall procedures. It is necessary to have guidance in place which specifies what steps you and your key staff should take in the event that you have a problem which results in your products being unsafe (eg you have received notification that one of your raw ingredients is contaminated or you have suspected glass contamination in your product). Make sure you document your procedures and keep any records of incidents that may affect the safety of products to consumers. Guidance Notes Issue 2, January

41 2.5a STS The business shall immediately notify STS, and if appropriate, their local authority, when: Legal proceedings or a formal notice of the intention to prosecute has been received or There is a need for product withdrawal or recall due to a food safety incident, quality and/or legal concerns. STS SUPPLIERS: If microbiological tests show results at, or in excess of, your defined limits stated in 3.2 (Specifications) and if Listeria monocytogenes is detected in food and environmental samples, whether taken by or on behalf of the business or by another party (such as an Environmental Health Officer or customer), there is a requirement to immediately inform STS and where appropriate, the Local Authority. Should the business be aware of any potential legal proceedings against them with respect to product safety or legality, or be in receipt of formal notification such as an improvement, prohibition or remedial action notice, then the business must immediately notify STS, and where appropriate, the Local Authority. STS SUPPLIERS: A written procedure would be the best way to demonstrate that you are aware of the undertaking to inform STS if you have not had any incidents. More. More Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips Defined limits for pathogens are exceeded, and/or Listeria monocytogenes is detected in food or environment samples. Members being audited for the first time by a SALSA auditor, have had any such incidents arising in the six months immediately before the audit. Written guidance must include actions to be taken in the event of deviation from your defined microbiological standards for finished products and in particular, Listeria monocytogenes in food and environmental samples, whether taken by or on behalf of the business or by another party. If any of the above incidences have occurred, there is a requirement to immediately inform STS. Any incident occurring in the six-month period prior to commencing supply to the public sector must also be notified to STS. If there have been no incidents described above you only need to acknowledge that you understand these undertakings. If you have had an incident; demonstrate that, upon immediately becoming aware of it, it was reported to STS and, if appropriate the Local Authority. Keep to hand EHO visit reports and the Public Sector Code of Practice as they contain the relevant contact information. STS suppliers are required to have a copy of the Public Sector Code of Practice on site. 2.6 Complaint Handling Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips 2.6 The business shall have a system for the management and documentation of product complaints including responses to complainants. Any complaints should be recorded and a procedure put in place which clearly indicates what actions are to be taken in the event of a complaint being received. The actions should specify: Make sure you keep records of all complaints and how you responded and dealt with each. Guidance Notes Issue 2, January

42 Who will handle the complaints procedure? What sequence of actions is to be taken (eg acknowledge complaint in writing, investigate complaint, take any actions necessary to ensure safety of product, respond to customer, refund to customer etc). Following a justified complaint, it is good practice to check your procedures to see if there are any ways of improving your system to avoid repeat incidents. The ullage system must meet HMRC requirements. Record ullage and assess any trends. SECTION 3 DOCUMENTATION Statement of Intent Documents relating to the business s food safety and quality systems shall be clear, organised and accessible. What does a Statement of Intent mean? The Statement of Intent summarises the overall aim of the section that follows. The SALSA auditor will check each requirement during an audit. Should the auditor find that there is a substantial failure to meet the requirements of the section, it is likely that the supplier will also fail to comply with the overall Statement of Intent and result in an unsuccessful audit. Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips 3.1 Document Control: All documents and records appropriate to the safety, legality and quality of products shall be legible and able to be used by the appropriate personnel. The control of these documents and records shall be the responsibility of a senior member of staff. The company shall ensure these documents and records are stored safely for at least the shelf-life of the product(s) concerned plus 1 year, but must take into account any legal or customer requirements and the use and It is advisable to set up a document control system which is the responsibility of one person in the business (see also recommendations in HACCP section, 2.1.9) The use of Footers or Headers in a document simplifies this process. You should aim to have a list of the current documents in place that relate to the control of food safety and legality. Make suitable arrangements for archiving your records and superseded documents. Storage boxes for paperwork labelled so you can find things quickly. A safe, dry, pest-proof place to keep paperwork. Documents other than records may be archived electronically. The minimum period for collecting records before a SALSA audit is dependent on the ability of the business to demonstrate compliance to the systems implemented. This is typically 2-3 months for start-up businesses. If you are not sure that you have enough records to demonstrate This control system can be very simple; with a page numbering system, date of issue, issue number and person or department responsible for issue marked on each document relating to product safety and legality. Guidance Notes Issue 2, January

43 possible increased shelf-life of the product(s) (eg the possible freezing of product(s) by the consumer). compliance, you should discuss this concern with the auditor prior to the audit and he/she will advise you. 3.2 Specifications: Specifications for recipes and finished products shall be adequate, accurate and regularly reviewed. : HMRC require that excise records are retained for at least 6 years. Your recipe documents should include details of: Name of company and name of product. The ingredients and their weights/volumes per batch or by percentage. The date of issue & identity of the person issuing or approving the recipe. The recipe document may also include details of the processing method required to achieve the desired finished product. In addition to above, your finished product specifications should include details of: Description of product including (as appropriate) ingredients list, nutrition information, allergenic ingredients, shelf-life and associated storage temperature information (see 1.14), microbiological information, weight/ volume content, storage information, food contact and outer packaging. When reviewing your specifications and recipes, you should ensure that they each accurately relate to the products you are actually making and the processing methods you are using. (If they have changed, you will need to consider if your HACCP plan requires modification (see 2.1.9). Check that the ingredients are accurately reflected in both the raw material specifications (see 1.6.2) and the label declaration of the products in which they are used (see 1.12). Consider any changes that you may have made to the products and/or processes and that these recipes and specifications fully reflect these changes. Don t forget to consider any new raw materials you may be using and their compliance with any special requirements eg provenance (see 1.6.2). An appropriate frequency for this review is annually. The auditor will inspect the site s records. Document a list of all the products you manufacture, and the recipes and finished product specifications relating to each product. The specifications and recipes may be stored either electronically or on paper. The review may be evidenced by recording a review date on this list or by signing and dating a printed copy of the specifications themselves. Any changes you have made as a result of the review should be recorded. See Tools & Tips for an example of a finished product specification. 3.2.a STS Specifications shall include defined limits for microorganisms which may affect the quality and/or safety of the finished product. Your finished product specification for ready-to-eat foods must include details of: Microbiological standards that include defined limits for micro-organisms which may affect the quality or safety of the finished product. Ensure that you have documented specifications which include microbiological limits for all finished products. 3.2b STS In the case of ready-to-eat products that may support the survival or growth of Listeria monocytogenes: Specifications shall indicate a critical limit set as not detected in a 25g sample. You must ensure that Listeria monocytogenes is included, and the Critical Limit is set as not detected in a 25g sample. Ensure that you have documented specifications which include microbiological limits for all finished products. 3.3 Procedures & Working Instructions: Staff should be in no doubt as to their working instructions and these should be easy to access. Use these documents as training tools. Instructions could be displayed as a wall poster, kept in an Guidance Notes Issue 2, January

44 Shall be clearly legible, easy to understand by staff and readily accessible at all times. Make sure that the instructions themselves do not become physical hazards for the product e.g. torn or dirty bits of paper. Make sure staff working at Critical Control Points realise how important it is that they follow set procedures (see 1.1.1, Training & Supervision). Check that procedures and instructions are accurate. easily accessible file or visible on a computer screen in the relevant workplace. You may have to consider having instructions in different languages if this will help your staff understand their responsibilities. SECTION 4 PREMISES Statement of Intent What does a Statement of Intent mean? Premises shall be fit for purpose, clean and provide safe and legally compliant facilities that meet production and staff requirements. Premises shall be registered with, and/or approved by the appropriate authority. The Statement of Intent summarises the overall aim of the section that follows. The SALSA auditor will check each requirement during an audit. Should the auditor find that there is a substantial failure to meet the requirements of the section, it is likely that the supplier will also fail to comply with the overall Statement of Intent and result in an unsuccessful audit. Ref Requirement What do I have to do to comply with this Requirement? How can I demonstrate this? Tools & Tips 4.1 Location: Consideration shall be given to any external factors which may contaminate products. Premises should not be positioned where there is the potential for contamination of the product. Consider environmental impacts such as type of businesses surrounding the premises (e.g. effluent treatment plants, gasworks, contaminated land, airborne pollution etc). As part of your Food Safety Systems Review documentation, (see 2.2) you could include a check of your premises positioning and any external factors which could have become relevant since your last review, or you could include checks on the local environment in a routine check of the premises (Housekeeping Check, see 1.3.2). Guidance Notes Issue 2, January

45 4.2 Perimeter & Grounds: External areas shall be maintained in good order and drainage shall be adequate and effective. External areas should not create any potential contamination problems: Premises walls should be clear of plant growth and soil (risk of pests). If you are using a Pest Control contractor, these should be monitored during his/her visits (see 1.9.3). Outside areas should not be used for storing raw materials, finished products, packaging or equipment unless items are covered and suitably protected from people, adverse weather, animals and pests. There should be clean and clear access and egress from the buildings. Due regard must be given to Waste Control (see 1.8), Pest Control (see 1.9) and Maintenance (see 1.11). Drainage must be adequate (eg no pooling or ground saturation outside premises). Foul drains must connect directly to the sewerage system or septic tank and not connect to any other drains within the premises. Product waste must comply with all statutory regulations. Include checks on the perimeter and grounds in a routine check of the premises (Housekeeping Check, see 1.3.2). 4.3 Hand Washing Facilities: Suitable and sufficient hand cleaning facilities shall be provided. Hand washing facilities must be suitable for the type and risk associated with your business. Staff must be trained in how to use the hand washing facilities (see Section 1.1 Training & Supervision). Ideally, hand wash basins should be located to enable hand washing when entering the production area and a sufficient number of hand wash basins available throughout all food handling areas to encourage hand washing. Hand washing basins must not be used for any other purpose. If possible, do not use hand-operated taps except perhaps in toilet facilities. If hand-operated taps are used, plan to replace them as part of your ongoing maintenance/upgrading. There must be temperature-controlled warm water available. Soap and hand-drying facilities must be available by hand wash basins. A soap and paper towel dispenser and used paper towel bin/container must be provided. Bars of soap/washable towels are not recommended. Hot air driers are not recommended in areas other than toilet facilities. Paper towel disposal must be adequate and not pose a risk of contamination to food or the production environment. If nailbrushes are used, they must be clean, plastic, in good repair and kept in a clean sanitising solution. Include checks on hand washing facilities in a routine check of the premises (Housekeeping Check see 1.3.2). Guidance Notes Issue 2, January

46 4.4 Equipment Cleaning Facilities: Facilities for tray and utensil washing and general purpose cleaning shall, where appropriate, be adequately segregated from product handling and storage. Small equipment must not be cleaned in hand wash basins or in sinks used for washing food. Separate sinks or dishwasher/equipment washers must be provided and staff trained in their use (see Training & Supervision 1.1.1). Equipment sinks must be sufficient to enable washing and rinsing. The type of detergents used will depend on what they are used for, but detergents used for food contact surfaces and equipment must be specifically designed for food use. Detergents, disinfectants and sanitisers for hand washing, machine washing and clean-in-place must be used in the correct dilutions and according to manufacturers instructions (see and ). For high risk products it may be appropriate to carry out occasional microbiological or ATP testing, to ensure the equipment is working correctly. Consideration must be given to the location of equipment cleaning facilities as this is a dirty process. If the wash-up area cannot be totally separated from the food handling areas, then you must be clear in how your process flow operates, to avoid the risk of cross-contamination (see 1.4.1). Include checks on the operation of your equipment cleaning facilities in a routine check of the premises (see 1.3.2, Housekeeping Check). 4.5 Location of Toilets & Staff Facilities: Toilets shall not open directly into handling or storage areas. Changing facilities shall be appropriately sited and appointed to avoid external contamination after changing into protective clothing. Toilets and changing areas must be adequate for the number of staff likely to use them at any one time. Toilets must be easily accessible to staff and must not open directly into any processing, food handling or storage area. The actual location/accessibility of toilets and staff facilities will be determined by the type of business. Areas where eating, drinking and smoking are permitted should be clearly identified. For high risk/high care areas, there must be a clearly identified changing area, preferably positioned in a way which ensures staff must pass through this area when leaving the high risk/high care area en route to the toilet. This could involve having two (or more) changing areas on site. See for additional procedural and training requirements for high care/high risk changing of protective clothing prior to using toilets. There must be a sign in the toilet area instructing users to wash their hands. Provide this instruction in additional languages if necessary. Hand washing basins may be located in the toilet cubicle or just outside, provided users have to directly pass the basins. Ensure that there are adequate facilities and signage as per the Requirements and this Guidance. 4.6 Condition of Building Structure: Walls, ceilings, doors, floors, drains and lighting shall be The premises must be suitable for the production of food products and must comply with all the legal requirements for the product type. Floors. Must be able to meet the demands of the process and withstand Include checks of building structure and services in a routine check of the premises Guidance Notes Issue 2, January

47 sound, fit for purpose and regularly maintained. cleaning materials and methods. Should be impervious and in good repair. Walls, Partitions and Doors. Must be smooth, washable and in sound repair. External doors to production areas or for staff access should be effectively proofed against pests (see 1.9.6). Windows. Windows in production areas must be shatterproof and if they can be opened, must be pest-proofed. Sills must be washable & clear of clutter (or, preferably, slope downwards). Ceilings. Must be in sound repair and should be easily cleaned. Ceilings should be provided in all processing areas. Exposed pipes. If it is not possible to enclose pipes, it is essential that pipes and ducting can be cleaned easily and effectively, particularly horizontal runs. Lighting. Must be adequate for safe working and the degree of illumination must comply with legal requirements. Fluorescent tubes in all areas where food or food packaging is stored or handled must be shatterproof, or covered with diffuser covers, in case of shattering. Suspended lighting must be cleanable. Internal drains (see also Premises 4.2). Floor drains, if present, must be constructed and slope in such a way that waste and cleaning water can drain properly. The drains must be easy to clean and have grating flush with the floor surface. Any traps must be accessible and easy to clean. Drains from toilets must not present a risk to products. (Housekeeping Check, see 1.3.2). Keep records for maintenance carried out. 4.7 Condition of Building Services: Services, such as ventilation, compressed air and steam shall be sound, fit for purpose and regularly maintained. Include services in your Planned Maintenance system (see ). Keep records of maintenance carried out. SECTION 5 LEGAL REQUIREMENTS Statement of Intent A means of identifying all legal requirements applicable to the Brewing Industry shall be identified and steps shall be taken to comply with them. What does a Statement of Intent mean? The Statement of Intent summarises the overall aim of the section that follows. The SALSA auditor will check each requirement during an audit. Should the auditor find that there is a substantial failure to meet the requirements of the section, it is likely that the supplier will also fail to comply with the overall Statement of Intent and result in an unsuccessful audit. No SALSA Requirement What do I have to do to comply with this requirement? How can I document this? Tools & Tips 5.1 The brewery shall be registered with HMRC, and with AWRC (except when it sells only from the brewery gate ) Register with HMRC and AWRC (Alcohol Wholesalers Registration Scheme). Ensure the site has its own unique reference number. Duty records or registration document. Guidance Notes Issue 2, January

48 5.2 Alcohol by Volume (ABV) analysis shall be conducted to meet HMRC requirements. 5.3 The brewery shall have adequate product liability insurance. ABV analysis must be conducted at least annually on each product. The analytical laboratory should ideally be certified against an accredited scheme e.g. ISO Other methods of approval such as a proficiency testing schemes could be used e.g. Brewing Analytes Proficiency Testing Scheme (BAPS) Level of insurance dependent on the size of the business, but a minimum of 10 million is recommended. Conduct analyses. Contract a laboratory that is accredited and keep a copy of the Accreditation certificate or proficiency testing information e.g. letter of confirmation. Ensure the scope of accreditation includes the analyses that are requested. The site s insurance certificate should be available for the auditor to inspect. 5.4 ABV analysis of cask and bottle-conditioned beer shall be undertaken at the end of conditioning. Conditioning in either cask or bottle will produce additional alcohol. Checks need to be undertaken to ensure this additional fermentation does not make the final ABV higher than the allowed tolerance of the labelled ABV. Retain certificates of analysis. SECTION 6 QUALITY REQUIREMENTS Statement of Intent All reasonable steps shall be taken to ensure that the quality of beer shall be maintained throughout the brewing process. What does a Statement of Intent mean? The Statement of Intent summarises the overall aim of the section that follows. The SALSA auditor will check each requirement during an audit. Should the auditor find that there is a substantial failure to meet the requirements of the section, it is likely that the supplier will also fail to comply with the overall Statement of Intent and result in an unsuccessful audit. No SALSA Requirement What do I have to do to comply with this requirement? How can I document this? Tools & Tips 6.1 The beer shall be tasted to ensure it meets product specification(s) and is of good quality before packaging. Tasters shall be experienced and/or trained. Beer should be tasted at all stages of production and passed as fit to package. Shelf-life tests should be in place to monitor flavour changes. Tasters should be able to recognise potential flavour defects/significant variations The Auditor will expect to see a tasting during the course of the audit. Beer tasting courses are available through beer industry bodies e.g. Institute of Brewing and Distilling (IBD) Brewing and packaging sheets are the easiest method of recording pass to the next stage. Guidance Notes Issue 2, January