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ISO 22000:2005 CHECKLIST

Client: GNL
Auditor:

Bright Peter Dzah

Clause
No

4
4.1

Date:

Clause

Food safety management system


General requirements
Is the Food Safety Management System (FSMS) documented?
Are there documented procedures for:
- 4.2.2 Control of documents?
- 4.2.3 Control of records?
- 5.7 Emergency preparedness and response
- 7.6.3 Determination of critical limits for CCPs?
- 7.6.4 System for the monitoring of CCPs?
- 7.6.5 Actions when monitoring results exceed critical limits?
- 7.10.2 Corrective action?
- 7.10.3 Handling of potentially unsafe products?
- 7.10.4 Withdrawals?
- 8.4.1 Internal Audit
Is the scope of the FSMS adequately defined?
Are the products or product categories, processes and all production
sites specified?
Does the organisation communicate appropriate information to the
food chain regarding the safety if its products?
Does the organisation satisfactorily communicate internally to ensure
the FSMS is followed?
Is the FSMS periodically evaluated and updated to ensure its currency
and applicability to newly identified hazards?
Does the organisation outsource any processes? If so is this
documented and the controls required documented

4.2

Documentation requirements

4.2.1

General
Does the FSMS documentation include:
- Food Safety Policy and related objectives?
- procedures, including records?
- Other documents, including records, needed for effective
development, implementation and updating of the FSMS?

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Evidence of
implementation

Clause
No

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4.2.2

Control of documents
Are FSMS documents controlled?
Are records controlled?
Are documentation changes which impact on the FSMS reviewed prior
to implementation?
Does the procedure for document control require:
- approval of documents for adequacy prior to issue?
- the review, update and re-approval of amended documents?
- that changes and current revision status are identified?
- that relevant versions of documents are available at points of use?
- that documents remain legible and readily identifiable?
- that externally originating documents are identified and have a
controlled distribution?
- to prevent unintended use of obsolete documents and suitably
identify obsolete documents if retained?
- record the rationale of changes to documents?
Is this procedure documented?

4.2.3

Control of records
Are sufficient records established to substantiate conformance with the
FSMS?
Are records legible, readily identifiable and retrievable?
Is there a documented procedure for the control of records? Does the
procedure specify record correction, identification, storage, protection,
retrieval, retention time and disposition?

5
5.1

Management responsibility
Management commitment
Does evidence of top managements commitment to the development
and implementation of the FSMS include :
Business objectives supporting food safety?
Establishment of the food safety policy?
Communication to the organisation by top management regarding
- the importance of meeting the requirements of this International
Standard?
- any statutory and regulatory requirements?
- customer requirements relating to food safety?
- The conducting of management reviews?
The provision of resources by top management?

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Evidence of
implementation

Clause
No

5.2

Clause

Food safety policy


Does top management define and document and communicate the
Food Safety Policy?
What is the Food Safety Policy called?
Is it authorised by top management?
How does top management ensure this policy is communicated?
Is the Food Safety Policy relevant?
Does it comply with the requirements of customers and regulatory
requirements?
Is it communicated, implemented and maintained at all levels?
How is it regularly reviewed?
Does it specifically address external and internal communication?
Is the Food Safety Policy supported by measurable objectives?

5.3

Food safety management system planning


Does top management ensure planning of the FSMS is carried out to
meet:
- the requirements given in 4.1?
- the objectives of the organisation that support food safety?
Is the integrity of the FSMS maintained when changes to the FSMS are
planned and implemented?

5.4

Responsibility and authority


How are responsibilities and authorities defined and communicated?
Are these authorised?
What evidence is available to indicate these have been communicated
to personnel?
Do employees have access to these?
Do responsibilities include that personnel shall report problems with
the FSMS?
Do designated personnel have defined responsibility and authority to
initiate and record actions?
Is the organisation chart (where such exists) consistent with Job
Descriptions titles, reporting roles?

5.5

Food safety team leader


Has a Food Safety Team Leader been designated?
Are the responsibilities/authorities of the Food Safety Team Leader
defined to include
- management of the Food Safety Team and its work?
- the food safety team are appropriately trained and educated ?
- the food safety management system is established, implemented,
maintained and updated ?

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Evidence of
implementation

Clause
No

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reporting to top management on the effectiveness and suitability of


the FSMS?

Evidence of
implementation

Clause
No

Clause

5.6

Communication

5.6.1

External communication
Are there effective arrangements for communicating with:
- suppliers, vendors and contractors?
- customers or consumers, in particular in relation to product
information (eg instructions of intended use, storage requirements,
shelf life etc.)?
- statutory and regulatory food authorities?
- other organisations the FSMS may impact on or be impacted by ?
Do these communication arrangements provide adequate information
on the food safety aspects throughout the food chain?
Particularly, are known food safety hazards that need to be controlled
by other organisations satisfactorily communicated?
Are associated records maintained of this communication?
How are food safety requirements from customers and regulatory
authorities made available?
Has the responsibility and authorities been defined for the designated
personnel which have been authorised to communicate to external
parties eg suppliers, customers, regulatory authorities on information
concerning food safety?
Where has this been defined and is their evidence of communication to
the relevant personnel?
Is the external communication included during review of the System
by the Food Safety Team and also as input to the management review?

5.6.2

Internal communication
What arrangements are there for communicating food safety issues and
changes internally to the relevant personnel?
Have these arrangements been effectively established, implemented
and maintained?
How does the organisation ensure that the Food Safety Team is
informed of changes in:
- products or new products?
- raw materials, ingredients and services?
- production systems and equipment?
- production premises, location of equipment, surrounding
environment?
- cleaning and sanitation programs?
- packaging, storage and distribution systems?
- personnel qualification level and allocation of responsibilities and
authority?
- regulatory requirements?
- knowledge regarding food safety hazards and control measures?
- customer, sector and other requirements?
- relevant enquiries from external parties?

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Evidence of
implementation

Clause
No

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- complaints including health hazards associated with product?


- other conditions which may impact on food safety?
Is the Food Safety Team informed of these changes in a timely
manner?
What process is in place to ensure the described information is
included in updating the FSMS?
Does the FST include this information when evaluation the FSMS and
is it also included as input to the management review?

5.7

Emergency preparedness and response


Have potential emergencies and accidents that can impact on food
safety been identified??
Has a procedure(s) been developed to manage the potential emergency
situations and accidents identified?

5.8

Management review

5.8.1

General
How does top management review the FSMS?
How often is it reviewed?
Is relevant information available to top management for the review?
Are opportunities for improvement and the need for change the FSMS
assessed?
Is the Food Safety Policy included in this assessment?
Are records of management review maintained?

5.8.2

Review input
Is there an agenda for the meeting?
Does the agenda cover:
- results of external audits?
- analysis of results of verification activities ?
- changing circumstances that can affect food safety?
- emergency situations, accidents and withdrawals?
- reviewing results of system up-dating activities?
- review of communication activities (internal and external)
conducted including customer feedback?
- follow-up actions from previous meetings?
Is the data presented to enable the information to be related to the
objectives of the FSMS?
Are review intervals defined/adhered to?
Are review agenda adhered to?
Are attendees in accordance with procedures?
Are actions followed up and assigned to personnel?

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Evidence of
implementation

Clause
No

5.8.3

6
6.1

Clause

Review output
Does the review realise decisions and actions for:
- assurance of food safety?
- improvement to the effectiveness of the FSMS?
- resource requirements?
- revisions to the Food Safety Policy and FSMS objectives?

Resource management
Provision of resources
Have adequate resources been provided for the FSMS by the
organisation?

6.2

Human resources

6.2.1

General
Are any external experts required for the operation of the FSMS?
Are there records of agreements in place establishing the responsibility
and authority of these experts?
Are members of the Food Safety Team and other personnel employed
with activities affecting food safety competent?
Do competencies take into consideration appropriate education,
training, skills and experience?

6.2.2

Competence, awareness and training


Have the necessary skills and competencies of relevant personnel
whose activities impact on food safety been identified?
Does the organisation provide education or training to meet any gaps?
How is the effectiveness of this education and training evaluated?
How does the organisation ensure personnel with responsibility for
monitoring food safety processes (ie CCPs/OPRPs) are appropriately
trained?
How is the effectiveness of training and competence evaluated?
How are personnel made aware of the relevance and importance of
their individual activities in contributing to food safety?
How are personnel made aware of the necessity for effective internal
and external communication regarding food safety issues?
How are records of education, training, skills and experience
maintained?

6.3

Infrastructure
Is the infrastructure in place appropriate to achieve conformity to the
FSMS?

6.4

Work environment
Is the work environment appropriate to achieve conformity to the

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Evidence of
implementation

Clause
No

Clause

Evidence of
implementation

FSMS?

7
7.1

Planning and realisation of safe products


General
How does the organisation ensure appropriate planned activities are
implemented?

7.2

Prerequisite programmes (PRPs)


ie manage basic conditions/activities for the purpose of hygienic production, processing and
handling.

7.2.1

7.2.2

Has the organisation established, implemented and maintained


Prerequisite Programs (PRPs)
What PRPs has the organisation identified?
Are these PRPs relevant and appropriately implemented/controlled for
the organisation?
Are they approved by the Food Safety Team?

Has the organisation identified statutory and regulatory requirements


related to the PRPs identified?
7.2.3
Has the organisation consider appropriate existing information when
establishing PRPs (eg codes of practice, regulations, guidelines)?
Are PRPs documented, maintained and updated as required?
How are PRPs documented?
On establishing PRPs has the organisation considered the following
(where relevant):
- construction and lay-out of buildings and associated utilities?
- lay-out of premises, including workspace and employee facilities?
- supplies of air, water, energy and other utilities?
- supporting services, including waste and sewage disposal?
- suitability of equipment and its accessibility for cleaning,
maintenance and preventative maintenance?
- measures for the prevention of cross contamination?
- cleaning and sanitising?
- pest control?
- personnel hygiene?
- packaging procedures?
- management of purchased materials, supplies, disposals and
handling of product?
- other aspects as appropriate?
What documents specify how activities included in the PRPs are
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Clause
No

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managed?
How are the PRPs verified and how is this verification planned?
Are records of these verifications available?
Have records been kept of any modifications made from the
verification process?

7.3

Preliminary steps to enable hazard analysis

7.3.1

General
Is all relevant information needed to enable hazard analysis maintained
updated and documented ie Food safety team details, raw material
and end product characteristics, intended use, flow diagrams, process
steps and control measures ?
Are relevant records retained?

7.3.2

Food safety team


Has a Food Safety Team been appointed?
Is the mix of knowledge and experience in the Food Safety Team
sufficient to develop/maintain the FSMS for the scope of the
organisation?
Are records maintained demonstrating the Food Safety Teams
knowledge and experience?

7.3.3

Product characteristics

7.3.3.1

Raw materials, ingredients and product-contact materials

Are all raw materials, ingredients and product-contact materials


specified in documents and containing all relevant information to
conduct the hazard analysis?
Has relevant information been obtained from suppliers to ensure the
following has been identified:
- biological, chemical and physical characteristics?
- composition of ingredients, including additives and processing
aids?
- origin and method of production?
- packaging and delivery methods?
- storage conditions and shelf life?
- preparation and handling before use or processing?
- food safety related acceptance criteria or specifications of
purchased materials/ingredients?
Has the organisation identified regulatory food safety requirements
relevant to the above?
Are raw material/ingredient specifications kept updated?
7.3.3.2

Characteristics of end products

Are all end products adequately specified in documents with relevant


information in order to conduct the hazard analysis?
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Evidence of
implementation

Clause
No

Clause

Does the information include:


- product name or similar
- biological, chemical and physical characteristics
- intended shelf life and storage conditions?
- Packaging/labelling and instructions for handling, preparation and
usage?
- method of distribution?
Has the organisation identified regulatory food safety requirements
relevant to the above?
Are product specifications kept updated?
7.3.4

Intended use
Has the intended use and the reasonably expected handling of the end
product been considered and documented?
Has any unintended use but reasonable expected mishandling and
misuse been considered and documented?
Is it included in the product specifications?
Are users and consumers identified for each product?
Have groups especially vulnerable to food safety hazards been
considered?
Are specifications kept up to date?

7.3.5

Flow diagrams, process steps and control measures

7.3.5.1

Flow diagrams

Have flow diagrams or charts been prepared for product or process


categories?
Are they sufficiently detailed and do they include:
- the sequence and interaction of all steps in the operation?
- any outsourced processes or subcontracted work?
- where raw materials, ingredients and intermediate products enter
the flow?
- where reworking or recycling takes place?
- Where end product, intermediate products, by-products or waste
are removed?
Has the Food Safety Team verified the flow diagrams on-site?
Are there records of this verification?
7.3.5.2

Description of process steps and control measures

Are control measures, process parameters or procedures necessary for


food safety sufficiently described to conduct the hazard analysis?
Has any external requirements that may influence the choice of
relevant control measures or rigorousness of application been
identified (eg regulatory authorities, customers)?
Are specifications kept up to date?

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Evidence of
implementation

Clause
No

Clause

7.4

Hazard analysis

7.4.1

General
Has the Food safety Team conducted the hazard analysis to determine
degree of control and combination of controls required for food safety?

7.4.2

Hazard identification and determination of acceptable levels

7.4.2.1

Are all food safety hazards identified and recorded?


Is the identification based on:
- preliminary information and data collected?
- experience?
- external and historical information?
- external information from the supply chain?
Are the steps (from raw materials, processing and distribution) at
which each food safety hazard may be introduced indicated?
7.4.2.2

When identifying hazards, were the following considered:


- steps preceding and following the specified operation?
- process equipment, utilities/services and surroundings?
- preceding and following links in the food chain?

7.4.2.3

Has the acceptable level of food safety in the end product been
determined for each food safety hazard identified considering:
- established regulatory requirements?
- customer food safety requirements?
- experience?
- intended use by customer?
Has this acceptable level identified been recorded and justified?
7.4.3

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Hazard assessment
Has a hazard assessment been conducted for each food safety hazard
identified?
Has this assessment determined if elimination or reduction of the
hazard to acceptable levels is essential for safe food?
Has this assessment determined if control of this hazard is needed for
defined acceptable levels to be met?
Also has each food safety hazard been evaluated and categorised
according to its severity and likelihood of occurring?
Has this methodology used for hazard assessment been described?
Have the results of hazard assessment been recorded?

Evidence of
implementation

Clause
No

Clause

7.4.4

Selection and assessment of control measures


Have control measures been selected for food safety hazards
identified?
Has the effectiveness of each control measure been reviewed for the
identified food safety hazard?
Have PRPs been identified amongst the combination of controls (as
not required for acceptable levels of hazards to be met)?
Where the controls have been identified for acceptable levels of
hazards to be met, have these then been further categorised as
managed either through OPRPs or the HACCP Plan (CCP) based on:
- the effect on the hazard relative to the strictness applied?
- the feasibility for monitoring (e.g. for immediate action to be
taken)?
- the place within system/process relative to other control measures?
- likelihood of failure in functioning of control or processing
variability?
- severity of consequences in case of failure of the control?
- whether the control measure is specifically established or applied to
significantly reduce the hazard?
- synergistic effects (interaction effect higher than sum of individual
effects)?
Are control identified as CCP managed through the HACCP Plan
(7.6)?
Are OPRPs implemented and managed according to 7.5 ?
Is the methodology and parameters used for categorisation described in
documents?
Are the results of the assessment recorded?

7.5

Establishing the operational PRPs


Have the operational PRPs been documented with the following
information for each one:
- food safety hazards to be controlled?
- corresponding control measures ??
- monitoring procedures to demonstrate OPRPs are implemented?
- corrections and corrective actions to be taken if not in control?
- responsibility and authorities ?
- records of monitoring?

7.6

Establishing the HACCP Plan

7.6.1

HACCP Plan

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Evidence of
implementation

Clause
No

Clause

Is the HACCP Plan documented and does it contain the following for
each CCP :
- food safety hazard to be controlled?
- the corresponding control measure?
- monitoring parameters showing the control measure is functioning?
- critical limits?
- monitoring?
- corrective action if critical limits are exceeded?
- responsibility for monitoring?
- records of monitoring?
7.6.2

Identification of CCPs
Have all CCPs been identified for those control measures?

7.6.3

Determination of critical limits for CCPs


Have critical limits been identified for the monitoring of all CCPs?
Are the critical limits established to ensure the identified acceptable
level of the food safety hazard in the end product is not exceeded?
Is the rationale for the chosen critical limits documented?
Are any subjective critical limits (eg visual inspection) supported by
procedures, specifications or specific training?

7.6.4

System for the monitoring of CCPs


Has a monitoring system been established for each CCP?
Does each monitoring system comprise of relevant procedures,
instructions and records that cover:
- measurements or observations for results in an adequate time
frame?
- monitoring devices used?
- applicable calibration methods?
- monitoring frequency?
- responsibility and authority related to monitoring and evaluation of
monitoring results?
- record requirements and methods?
Are monitoring methods and frequency capable of isolating product
prior to use/consumption should critical limits be exceeded?

7.6.5

Actions when monitoring results exceed critical limits


Has immediate corrective action to address the nonconformity and
longer term action to address the root cause of the nonconformity been
specified in the HACCP Plan for each CCP?
Do the actions ensure nonconformity is identified, parameters brought
under control, recurrence prevented?
Are there documented procedures to address the handling of potentially
unsafe products to ensure not released prior to evaluation?

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Evidence of
implementation

Clause
No

7.7

Clause

Updating of preliminary information and documents specifying the PRPs and


the HACCP plan
Following the establishment of operational PRPs and/or the HACCP
Plan, if necessary, has the organisation updated:
- product characteristics?
- flow diagrams?
- process steps?
- control measures?
If necessary, has the HACCP Plan and the procedures and instructions
specifying the PRPs been amended?

7.8

Verification planning
Is verification of the HACCP Plan documented?
Is the purpose, methods, frequencies and responsibilities for the
verification activities defined?
Does verification confirm:
- PRP are implemented?
- analysis of hazards is continually updated?
- operational PRPs and the HACCP Plan are implemented and
effective?
- hazard levels are within acceptable levels?
- any other procedures are implemented and effective?
Are records for verification defined?
Are verification results recorded and communicated to the Food Safety
Team?

7.9

Traceability system
How does the organisation identify product?
How is raw product traceable back to the supplier?
How is end product traceable?
Are traceability records retained? For how long?
Are the traceability records consistent with the shelf life of the
product?

7.10

Control of nonconformity

7.10.1

Corrections
Is corrective action initiated when critical limits are exceeded and
when operation PRPs are not adhered to?
Are nonconforming products affected identified and controlled in
regards to their use?

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Evidence of
implementation

Clause
No

Clause

Has a documented procedure been established defining


- identification and assessment of affected end products to determine
proper handling and
-a review of corrective actions carried out?
Are products which have been manufactured when critical limits have
been exceeded handled as unsafe product?
Are products which have been manufactured under conditions where
OPRPs have not been conformed with been evaluated?
Have these evaluations been recorded?
Are all corrections approved by the responsible person and recorded
with details of nonconformity, cause, consequence and relevant
information to trace to affected lots?
7.10.2

Corrective actions
Are monitoring records of CCPs & OPRPs evaluated by designated
personnel with sufficient knowledge and authority to initiate corrective
action?
Are documented procedures in place to identify and specify
appropriate actions to handle nonconformities, including:
- reviewing customer complaints and nonconformities?
- reviewing trends in monitoring and verification results?
- determining the causes of nonconformities?
- evaluating the need for preventive action?
- determining and actioning corrective action?
- records of results of corrective action?
- reviewing corrective action to ensure it is effective?
Are corrective actions recorded and signed by the responsible person?

7.10.3

Handling of potentially unsafe products

7.10.3.1

General

Does the organisation prevent nonconforming product being passed on


to customers?
Is there a documented procedure for dealing with potentially unsafe
products (including controls, related responses and authorisation)?
How does the organisation ensure that nonconforming product which
has been re-evaluated and cleared is safe?
How does the organisation ensure nonconforming product is controlled
to prevent distribution and handle distributed product for withdrawal?
7.10.3.2

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Evaluation for release

Evidence of
implementation

Clause
No

Clause

Is each lot of product affected by the nonconformity only released as


safe when:
- evidence other than the monitoring system demonstrates that the
control measures have been effective?
- evidence shows that the combined effect of the control measures
for that particular product complies with the performance intended?
- the results of sampling, analysis and/or other verification activities
demonstrate that the affected lot of product complies with the
identified acceptable levels for the food safety hazards(s)
concerned?
7.10.3.3

Disposition of nonconforming products

Following evaluation, if the lot of product is not acceptable for release,


is it handled by one of the following:
- reprocessing or further processing within or outside the
organisation to ensure that the food safety hazard is eliminated or
reduced to acceptable levels?
- destruction and/or disposal?
7.10.4

8
8.1

Withdrawals
Does the organisation have a documented procedure for notifying
interested parties of product withdrawal?
Does the product withdrawal procedure establish:
- the authority to initiate a withdrawal and execute a withdrawal
appointed by top management?
- notification to interested parties?
- handling of withdrawn products and affected products still in
stock?
- the sequence of actions to be taken?
- records required?
How does the organisation ensure withdrawn product is not used
inadvertently?
In the case of a withdrawal, has the cause, extent and result been
recorded and reported to top management as input to the management
review?
How does the organisation verify the effectiveness of the withdrawal
program (e.g. mock/practice withdrawal)?

Validation, verification and improvement of the food safety


management system
General
How is the FSMS verified, validated and updated, particularly:
- to demonstrate compliance?
- ensure updating of the FSMS?

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Evidence of
implementation

Clause
No

8.2

Clause

Validation of control measure combinations


Does the organisation ensure control measure combination works
effectively upon initial development of the HACCP Plan and
operational PRPs, and on their amendment?
Do validation activities include:
- critical limits for CCPs are capable of achieving safe food?
- control measures are effective?
Does the organisation ensure control measures are modified and
reassessed if either of the above fails?

8.3

Control of monitoring and measuring


How does the Company identify measurements and assign suitable
measuring devices?
Are processes established to ensure monitoring and measuring is
consistent with specified requirements?
Does the organisation ensure measuring equipment is:
- calibrated or verified at specified intervals or prior to use?
- such calibration is traceable to national or international standards?
- adjusted as required?
- identified?
- safeguarded from inadvertent adjustments?
- protected from damage or deterioration?
Are calibration and verification results recorded?
When equipment is found to be out of calibration are the possible
effects of this fully investigated for impact on equipment and product
and appropriate action taken? Is it recorded?
Is computer software used for monitoring and measurement and how is
this verified as adequately performing?

8.4

Food safety management system verification

8.4.1

Internal audit
Are internal audits planned to determine if the FSMS:
- conforms to this Standard and the FSMS documented
requirements?
- is effectively implemented and updated?
Does the audit program consider the status and importance of
processes and the results of previous audits?
Are audit criteria, scope, frequency and methods defined?
Are auditors impartial?
Do they audit their own work?
Are responsibilities for planning and conducting audits, and for
reporting results and maintaining records documented in a procedure?
Is corrective action resulting from discrepancies found during internal
audits taken without undue delay?
Is this corrective action verified?

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Evidence of
implementation

Clause
No

Clause

Are results of internal audits reported to top management?


8.4.2

Evaluation of individual verification results


Are the individual results of planned verification systematically
evaluated by the Food Safety Team?
Where verification does not demonstrate conformity, how does the
organisation take action to ensure conformity including review of:
- procedures and communication channels?
- hazard analysis, operational PRPs and the HACCP Plan
- PRPs?
- effectiveness of resource management and training?

8.4.3

Analysis of results of verification activities


Does the Food Safety Team analyse the results of verification
activities, including the results of the internal and external audits?
Does this analysis:
- confirm that the overall performance of the system meets the
planned arrangements and the FSMS requirements?
- identify the need for updating or improving the FSMS?
- identify trends to indicate high incidence of potentially unsafe
products?
- establish information for planning of the internal audit program
concerning the status and importance of areas to be audited?
- provide evidence that any corrections and corrective actions that
have been taken are effective?
Are the results of this analysis and resulting activities recorded and
reported to top management as input:
- to the management review?
- For updating the FSMS?

8.5

Improvement

8.5.1

Continual improvement
Is the effectiveness of the FSMS continually improved through the use
of:
- communication?
- management review?
- internal audit?
- evaluation of individual verification results?
- analysis of results of verification activities?
- validation of control measure combinations?
- corrective actions?
- FSMS updating?

8.5.2

Updating the food safety management system

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Evidence of
implementation

Clause
No

Clause

Does the organisation ensure the FSMS is updated in a timely manner,


when required?
Does the Food Safety Team evaluate the FSMS at planned intervals?
Does the Food Safety Team consider whether it is necessary to review:
- the hazard analysis?
- the established operational PRPs?
- the HACCP Plan?
Do FSMS evaluating and updating activities include
- communication (external and internal)?
- other information concerning the suitability, adequacy and
effectiveness of the FSMS?
- Output from analysis of verification activities?
- management review?
Are FSMS updating activities recorded and reported to top
management as input to the management review?

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Evidence of
implementation

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