HACCP Plan Grower Farm

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Index Page 1 of 24 1. Introduction to HACCP 2. HACCP Scope 3. HACCP Team 4. Definitions 5. Methodology 6. Product Identification and Intended Use and Process 7. Product Descriptions 8. Flow Diagram for Farm 9. Risk Analysis Table 10. CCP Decision Tree 11. Verification Table 12. Validation Table

Introduction to HACCP Page 2 of 24 Hazard Analysis Critical Control Point, or HACCP, is a system, which gives us a pro-active common sense approach to the safety management of our food products. HACCP was originally designed in the early days of the American manned space programme, and was developed by the Pillsbury Company, NASA and the United States Army laboratories, to ensure the Microbiological safety of the astronauts food. The HACCP system was launched publicly in 1971, and is designed to identify and control hazards that may occur anywhere in a food processing operation. The benefits of the HACCP system are as follows: A Preventative System A Systematic Approach Helps demonstrate Due Diligence Internationally accepted Strengthens Quality Management Systems Facilitates regulatory inspection/external audits Demonstrates Management commitment

Scope of HACCP Plan Page 3 of 24 The purpose of this Farms food safety program is to identify and control, prevent and eliminate food safety hazards. The HACCP Team have identified the Scope of this study as being: From the purchase of the seed or propagation materials through to the final harvesting and collection of produce by packing facilities. The HACCP plan provides an overview of the process involved in: For: Intake of stock Growing Harvesting Storage Packing of stock Dispatch of product Strawberries Raspberries Blueberries Blackberries This HACCP plan has been prepared in accordance with: CODEX Alimentarius Guidelines 97/13A for HACCP European Communities (Hygiene of Foodstuffs) Regulations 2006

HACCP Team Page 4 of 24 Name Position Qualifications Team Leader Grower General Manager

Definitions Page 5 of 24 Term Critical control Point (CCP) Pre- Requisite Programme (PRP) Risk Analysis Table HACCP Table Sev Lik Sig Definition A step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level. Practices and procedures forming the basis of preventable actions: Receiving, Storage & Transport (e.g. procedure for receipt, approved supplier programme etc.) Calibration & Maintenance Cleaning Pest control Staff training & Personnel Product Identification, Traceability & Recall Premises (buildings & site) A tabulated record of all Hazards that affect or have the potential to affect the safety of the products under analysis. The significance of a hazard is rated as low, medium or high and control measures for each hazard are stated. Hazards identified in the risk analysis table as being of medium or high significance and their respective control measures are transferred to the HACCP table. The critical limit of these hazards is specified. Details of who will monitor the critical limit to make sure it is not broken are given. Actions to be taken when critical limits are broken are also given. Records of monitoring activities are listed. Severity: the consequences of the Hazard occurring H High Life Threatening or causing severe illness / injury M- Medium Moderate illness/injury not life threatening L- Low- Mild illness/injury, not life threatening Likelihood: the likelihood of the hazard occurring H- High Likely to occur often M- Medium May occur sometimes L Low Unlikely to occur Significance. The consequences of the hazard occurring when both the severity and likelihood are high, the significance is high.

Methodology Page 6 of 24 The flow chart has been designed so that each step has been allocated a number. All steps that are repeated throughout the process have been allocated the same number to save repetition in the risk analysis table. The method used to establish CCP s within this HACCP plan has been based on the significance of each hazard as determined by the risk analysis table. Hazards which can be controlled, Prevented or eliminated by the application of Per-Requisite Programme are not included in the HACCP table. Therefore these hazards have been identified in the risk analysis and have not been carried forward to the HACCP table as CCP s. All other hazards not controlled by PRP and defined as highly significant within the Risk Analysis Table have been carried over to the HACCP table as a CCP. These hazards are all monitored and a record of that activity maintained. Hazards defined as less than significant within the Risk Analysis Table are not carried over to the HACCP Table and may not be monitored or a record maintained. TOTAL RISK = LIKELIHOOD x SEVERITY Likelihood Severity 1 = Improbable event once every five years 1 = Negligible no impact or not detectable 2 = Remote possibility once every year 2 = Marginal only internal company target levels affected 3 = Occasional event once per month 3 = Significant Impact on critical limits 4 = Probable event once per week 4 = Major Impact on customers (may not be the public) 5 = Frequent event once per day 5 = Critical public health risk / public product recall Likelihood Severity 1 2 3 4 5 1 1 2 3 4 5 2 2 4 6 8 10 3 3 6 9 12 15 4 4 8 12 16 20 5 5 10 15 20 25

Page 7 of 24 Product Identification, Intended Use and Process Soft fruit, i.e., Strawberries, Raspberries, Blackberries, and Blueberries are a convenience food and can be eaten without further processing, or can be used by the consumer as a cooking ingredient. The plants are received into the facility and the goods in checks are carried out. Inspections confirm the following: Approved supplier confirmation Variety Weight Defects Quality of packaging The plants are introduced into the growing pots and bags where Biological Control is implemented.

Product Description Page 8 of 24 Description: Product Specification Strawberries - fruit See individual fruit specification for strawberries Relevant safety information: Processing Procedure Food Additives Processing Aids Preservatives (Minimum concentration) Packaging: Predominantly eaten raw. Can be eaten intact or peeled and/or cut. Grown above ground, Inside. Grown above ground, outside. Planting, Picking, Packing None None None Various forms including Loose in punnets, sizes vary depending on customer requirements 227g, 300g, 400g 454g, 500g Labelling requirements relating to Food Safety Durability & storage conditions: Method of Preservation (ph, a w, time temp etc) Product Shelf Life Method of distribution: Expected uses: Vulnerable groups of population: Product Name, Display Until, Origin, Variety, Barcode, Address all as per specification Storage conditions - chill storage 3 o C 8 o C 3 o C 8 o C Chill storage 3 days from manufacture Within country product is transported in refrigerated enclosed trucks. Generally fruit crops are transported in refrigerated sea containers or palletised in the bulk holds of ships. They can also be transported by air freight (e.g. berries). Generally consignments do not consist of more than one product. Predominantly eaten raw. May be cooked. All groups may consume these raw and/or cooked. Potential for abuse: Not washed or refrigerated in the home and/or at the distribution centre/retailer.

Page 9 of 24 Description: Product Specification Raspberries - fruit See individual fruit specification for Raspberries Relevant safety information: Processing Procedure Food Additives Processing Aids Preservatives (Minimum concentration) Packaging: Predominantly eaten raw. Can be eaten intact or peeled and/or cut. Grown above ground, Inside. Grown above ground, outside. Planting, Picking, Packing None None None Various forms including Loose in punnets, sizes vary depending on customer requirements 125g, 170g, 250g, Labelling requirements relating to Food Safety Durability & storage conditions: Method of Preservation (ph, a w, time temp etc) Product Shelf Life Method of distribution: Expected uses: Vulnerable groups of population: Product Name, Display Until, Origin, Variety, Barcode, Address all as per specification Storage conditions - chill storage 3 o C 8 o C 3 o C 8 o C Chill storage 3 days from manufacture Within country product is transported in refrigerated enclosed trucks. Generally fruit crops are transported in refrigerated sea containers or palletised in the bulk holds of ships. They can also be transported by air freight (e.g. berries). Generally consignments do not consist of more than one product. Predominantly eaten raw. May be cooked. All groups may consume these raw and/or cooked. Potential for abuse: Not washed or refrigerated in the home and/or at the distribution centre/retailer.

Page 10 of 24 Description: Product Specification Blackberries - fruit See individual fruit specification for Blackberries Relevant safety information: Processing Procedure Food Additives Processing Aids Preservatives (Minimum concentration) Packaging: Predominantly eaten raw. Can be eaten intact or peeled and/or cut. Grown above ground, Inside. Grown above ground, outside. Planting, Picking, Packing None None None Various forms including Loose in punnets, sizes vary depending on customer requirements 125g, 150g Labelling requirements relating to Food Safety Durability & storage conditions: Method of Preservation (ph, a w, time temp etc) Product Shelf Life Method of distribution: Expected uses: Vulnerable groups of population: Product Name, Display Until, Origin, Variety, Barcode, Address all as per specification Storage conditions - chill storage 3 o C 8 o C 3 o C 8 o C Chill storage 3 days from manufacture Within country product is transported in refrigerated enclosed trucks. Generally fruit crops are transported in refrigerated sea containers or palletised in the bulk holds of ships. They can also be transported by air freight (e.g. berries). Generally consignments do not consist of more than one product. Predominantly eaten raw. May be cooked. All groups may consume these raw and/or cooked. Potential for abuse: Not washed or refrigerated in the home and/or at the distribution centre/retailer.

Page 11 of 24 Description: Product Specification Blueberries - fruit See individual fruit specification for Blueberries Relevant safety information: Processing Procedure Food Additives Processing Aids Preservatives (Minimum concentration) Packaging: Predominantly eaten raw. Can be eaten intact or peeled and/or cut. Grown above ground, Inside. Grown above ground, outside. Planting, Picking, Packing None None None Various forms including Loose in punnets, sizes vary depending on customer requirements 125g, 150g, 170g Labelling requirements relating to Food Safety Durability & storage conditions: Method of Preservation (ph, a w, time temp etc) Product Shelf Life Method of distribution: Product Name, Display Until, Origin, Variety, Barcode, Address all as per specification Storage conditions - chill storage 3 o C 8 o C 3 o C 8 o C Chill storage 3 days from manufacture Within country product is transported in refrigerated enclosed trucks. Generally fruit crops are transported in refrigerated sea containers or palletised in the bulk holds of ships. They can also be transported by air freight (e.g. berries). Generally consignments do not consist of more than one product. Expected uses: Vulnerable groups of population: Predominantly eaten raw. May be cooked. All groups may consume these raw and/or cooked. Potential for abuse: Not washed or refrigerated in the home and/or at the distribution centre/retailer.

Flow Diagram Page 12 of 24 2 a. Water & Fertiliser input 1. Plant Intake 2. Plant in Pots / Bags 3. Introduce Biological Control 4. Crop Walking 5. Intermittent Spraying if necessary 6. Training of plants / Pruning 6 a. Waste 7. Harvesting 8 a. Packaging Input 6 b. Recycled waste 8. Pack & Label 9. Dispatch

Page 13 of 24 Hazard Analysis Process Step Potential Hazard Sev Lik Sig* Reasons fro significance 1. Plant Intake Microbiological contamination of plants 4 1 4 Contaminated production 1. Plant Intake Chemical Contamination by pesticides production 1. Plant Intake Physical Contamination from pests 2. Plant into Pots / Bags Microbiological Contamination from personnel 2. Plant into Pots / Bags Physical Contamination from personnel 2 a. Water & fertiliser input Microbiological Contamination from water contaminated production 3 1 3 Contaminated production could affect product 3 1 3 Contaminated production could affect product production could affect product CCP Control Measures Plants sourced from accredited suppliers. Plant passports accompany all material accepted on site. Plants sourced from accredited suppliers. Plant passports provide the history / traceability of used chemicals. Plants sourced from accredited growers. Plant passports accompany plants to detail they are pest free. Hygiene procedures in place. Glass procedures in place Personnel entering the facilities are trained to wash hands. Personal Hygiene procedure in place. Hand washing signs are visible to all staff and visitors. All staff trained and records retained on personnel files. Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files. Glass procedures in place All water used in the growing area passes through a UV filter. Water samples are taken before and after the UV filter to verify that the system is working. Samples are taken every 2 weeks for verification. This is monitored externally and advice and recommendations are

Page 14 of 24 3. Biological Control Introduced Microbiological Contamination from insects 4. Crop Walking Microbiological Contamination from personnel 4. Crop Walking Physical Contamination from personnel 5. Intermittent Spraying if infestation noticed 5. Intermittent Spraying if infestation noticed Microbiological Contamination from unclean spraying devices Chemical Contamination from overuse of plant protection products production could affect product 3 1 3 Contaminated production could affect product 3 1 3 Contaminated production could affect product production could affect product production could affect product 3 1 3 Contaminated production could affect product given from the service provider where results are unsatisfactory. A service contract is in place to ensure that the filters are maintained and changed when necessary. All biological controls are purchased from approved suppliers with certificates of conformance Personnel entering the facilities are trained to wash hands. Personal Hygiene procedure in place. Hand washing signs are visible to all staff and visitors. All staff trained and records retained on personnel files. Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files. Glass procedures in place Cleaning schedules are in place to ensure that all spray equipment is cleaned sufficiently preventing micro spread. Trained personnel only permitted to use chemicals. Chemicals records are kept on file. 5. Intermittent Spraying if infestation noticed Physical Contamination from personnel Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files. Glass procedures in place 6. Pruning & turning of Microbiological Contamination from 3 1 3 Contaminated Personnel entering the facilities are trained to

Page 15 of 24 plants personnel production could affect product 6. Pruning & turning of plants Physical Contamination from personnel 6 a. Waste Microbiological Contamination from personnel 6 a. Waste Physical Contamination from personnel 6 b. Recycled waste Physical Contamination from personnel handling the crop. 7. Harvesting Microbiological Contamination from personnel handling fruit 7. Harvesting Physical Contamination from personnel handling the crop. 3 1 3 Contaminated production could affect product 4 1 4 Contaminated Product could affect consumer 4 1 4 Contaminated Product could affect consumer 4 1 4 Contaminated Product could affect consumer Product could affect consumer Product could affect consumer wash hands. Personal Hygiene procedure in place. Hand washing signs are visible to all staff and visitors. All staff trained and records retained on personnel files. Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files. Glass procedures in place Personnel entering the facilities are trained to wash hands. Personal Hygiene procedure in place. Hand washing signs are visible to all staff and visitors. All staff trained and records retained on personnel files. Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files. Glass procedures in place Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files. All staff are trained on hand-washing procedures through basic food safety training during the induction. Personal Hygiene procedures in place Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files. Glass procedures in place

Page 16 of 24 8. Pack & Label Microbiological Contamination from personnel handling the fruit 8. Pack & Label Chemical Contamination from non food grade crates / liners 8 a. Packaging input Microbiological Contamination from packaging used to pack and label products 8 a. Packaging input Chemical Contamination from non food grade material 8 a. Packaging input Physical contamination from foreign bodies within packaging 9. Dispatch Physical Contamination from personnel Product could affect consumer Product could affect consumer Product could affect consumer Product could affect consumer Product could affect consumer Product could affect consumer Personnel entering the facilities are trained to wash hands. Personal Hygiene procedure in place. Hand washing signs are visible to all staff and visitors All crates and liners are constructed of food grade plastic. Packing procedures in place. Packaging is sourced from approved suppliers Supplier approval procedures in place. Certificates confirming food grade packaging in place. Primary packaging is made from food grade material. Packaging is sourced from approved suppliers. Supplier approval procedures in place. Certificates confirming food grade packaging in place. Packaging is sourced from approved suppliers. Packaging is only taken into the harvesting areas when needed. It is not left in the area when not in use. All opened packaging, which hasn t been fully used, is recovered and stored sufficiently to prevent the risk of pest infestation. Packaging is sourced from approved suppliers. Supplier approval procedures in place. Certificates confirming food grade packaging in place. Wood policy is in place to ensure that only good quality, fully intact pallets are used for stacking fruit. Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files.

Page 17 of 24 Glass procedures in place

Page 18 of 24 CCP Decision Tree The CCP decision tree is as follows: Q1 - Do control measure(s) exist for the identified hazard? YES Q2 - Is the step specifically designed to eliminate or reduce a hazard to an acceptable level? YES Q3 - Could contamination occur at or increase to unacceptable level(s) YES Q4 - Will a subsequent step eliminate or reduce the likely occurrence of the hazard to an acceptable level? YES CCP T A CCP CCP Determination: A CCP is a step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level. The information collated during the hazard analysis allows for the identification of CCP s. To assist in the decision making process of determining CCP s a CCP decision tree was used.

Page 19 of 24 Process Step Potential Hazard Q1 Q2 Q3 Q4 CCP (Y/N) Control Measures 1. Plant Intake Microbiological contamination of plants from the plant suppliers YES N/A Plants sourced from accredited suppliers. Plant passports accompany all material accepted on site. 1. Plant Intake Chemical Contamination by pesticides above the MRL levels specified for each chemical YES N/A Plants sourced from accredited suppliers. Plant passports provide the history / traceability of used chemicals. 1. Plant Intake Physical Contamination from pests YES N/A Plants sourced from accredited growers. Plant passports accompany plants to detail they are pest free 2. Plant into Pots / Bags Microbiological Contamination from personnel handling the plants. 2. Plant into Pots / Bags Physical Contamination from personnel handling the crop. 2 a. Water & fertiliser input Microbiological Contamination from water contaminated with Fusarium, coliforms, E- coli or Salmonella 3. Biological Control Introduced Microbiological Contamination from insects carrying disease YES N/A Personnel entering the facilities are trained to wash hands. Personal Hygiene procedure in place. Hand washing signs are visible to all staff and visitors. All staff trained and records retained on personnel files. YES N/A Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files. YES N/A All water used in the growing area passes through a UV filter. Water samples are taken before and after the UV filter to verify that the system is working. Samples are taken every 2 weeks for verification. This is monitored externally and advice and recommendations are given from the service provider where results are unsatisfactory. A service contract is in place to ensure that the filters are maintained and changed when necessary. YES YES All biological controls are purchased from approved suppliers with certificates of conformance

Page 20 of 24 4. Crop Walking Microbiological Contamination from personnel handling the plants 4. Crop Walking Physical Contamination from personnel handling the crop. 5. Intermittent Spraying if infestation noticed 5. Intermittent Spraying if infestation noticed 5. Intermittent Spraying if infestation noticed 6. Pruning & turning of plants 6. Pruning & turning of plants Microbiological Contamination from unclean spraying devices Chemical Contamination from overuse of plant protection products Physical Contamination from personnel handling the crop. Microbiological Contamination from personnel handling, pruning or training plants Physical Contamination from personnel handling the crop. 6 a. Waste Microbiological Contamination from personnel handling, pruning or training plants YES N/A Personnel entering the facilities are trained to wash hands. Personal Hygiene procedure in place. Hand washing signs are visible to all staff and visitors. All staff trained and records retained on personnel files. YES N/A Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files. YES YES Cleaning schedules are in place to ensure that all spray equipment is cleaned sufficiently preventing micro spread. YES YES Trained personnel only permitted to use chemicals. Chemicals records are kept on file. YES N/A Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files. YES N/A Personnel entering the facilities are trained to wash hands. Personal Hygiene procedure in place. Hand washing signs are visible to all staff and visitors. All staff trained and records retained on personnel files. YES N/A Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files. YES N/A Personnel entering the facilities are trained to wash hands. Personal Hygiene procedure in place. Hand washing signs are visible to all staff and visitors. All staff trained and records retained on

Page 21 of 24 6 a. Waste Physical Contamination from personnel handling the crop. 6 b. Recycled waste Physical Contamination from personnel handling the crop. 7. Harvesting Microbiological Contamination from personnel handling fruit 7. Harvesting Physical Contamination from personnel handling the crop. 8. Pack & Label Microbiological Contamination from personnel handling the fruit 8. Pack & Label Chemical Contamination from non food grade crates / liners 8 a. Packaging input Microbiological Contamination from packaging used to pack and label products 8 a. Packaging input Chemical Contamination from non food grade material 8 a. Packaging input Physical contamination from foreign bodies within packaging or from the surrounding personnel files. YES N/A Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files. YES N/A Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files. YES N/A All staff are trained on hand-washing procedures through basic food safety training during the induction. Personal Hygiene procedures in place YES N/A Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files. YES N/A Personnel entering the facilities are trained to wash hands. Personal Hygiene procedure in place. Hand washing signs are visible to all staff and visitors YES N/A All crates and liners are constructed of food grade plastic. Packing procedures in place. YES N/A Packaging is sourced from approved suppliers Supplier approval procedures in place. Certificates confirming food grade packaging in place. YES N/A Primary packaging is made from food grade material. Packaging is sourced from approved suppliers Supplier approval procedures in place. Certificates confirming food grade packaging in place. YES N/A Packaging is sourced from approved suppliers. Packaging is only taken into the harvesting areas

Page 22 of 24 area 9. Dispatch Physical Contamination from damaged wooden pallets Physical Contamination from personnel handling the crop. when needed. It is not left in the area when not in use. All opened packaging, which hasn t been fully used, is recovered and stored sufficiently to prevent the risk of pest infestation Packaging is sourced from approved suppliers Supplier approval procedures in place. Certificates confirming food grade packaging in place. YES N/A Wood policy in place to ensure that only good quality, fully intact pallets are used for stacking fruit Hygiene and Personal Hygiene procedures are in place to ensure that no foreign bodies are introduced into the growing area. All staff trained and records retained on personnel files.

Verification Table Page 23 of 24 Activity Description Frequency Responsibility Records Review certification records All annual Global Gap (or similar) must be up to date to ensure that Annual Certification Technical Manager Annual Certificates on supplier file system is followed & limits are adhered too Verify flow chart Follow flow chart through the production run During internal audits quarterly Internal auditor & Technical Manager Update flow chart HACCP system Review Hazards HACCP team reviews hazards Once / year Or After changes HACCP Team Hazards analysis report Review trade requirements through EU portal / FSAI Review customer complaints & rejections Validate critical limits Review staff training HACCP team reviews requirements Assess any customer complaint records to highlight any deficiencies of the system Check that critical limits are still appropriate carry out literature search Review staff training needs in HACCP / Food Safety awareness to ensure training records up to date Once / year Or After changes Once / year Or After changes HACCP Team Technical Manager E-mail alerts / memos from FSAI or EU Management review documentation Once / Year HACCP team Scientific Papers Once / Year Or on induction of new / contract staff HR Staff training records

Page 24 of 24 Validation Table Potential Hazard Critical Limits References Hepatitis A, Salmonella, E. Coli, E. coli 0157:H7 Listeria monocytogenes Campylobacter jejuni Shigella, Other food poisoning organisms Norwalk Viruses Parasites i.e. Cyclosporidium Elimination of poor hygiene practices By food handlers etc Poor hygiene practices Poor cleaning practices Code of Hygienic Practices for Fresh Fruit & Vegetables (Codex Alimentarius) CACP/RCP53-2003 Customers codes of practice Salmonella Sampling plan on microbiological criteria for foodstuffs Commission Regulation (EC) No: 2073/2005 15 th November 2005 Pesticides Control of MRL (pesticide) levels in fruit Commission Regulation (EC) No: 396/2005 23 rd February 2005