1.2.1 The company shall have an organisation chart demonstrating the management structure of the company. The responsibilities for the management of activities which ensure food safety, authenticity, legality and quality shall be clearly allocated and understood by the managers responsible. It shall be clearly documented who deputises in the absence of the responsible person.
Interpretation Organisational charts and assignment of responsibilities
An organisational chart must be available, clearly indicating reporting lines for all managers on the site and, where applicable, relationships to the company head office roles. The chart would normally be expected to show both a position and the named person occupying that position. Where the chart shows job titles only, other documents must indicate the person occupying each position.
Interpretation
continued The chart or associated documentation needs to clearly indicate the responsibilities of each relevant member of staff with responsibility for the management of food safety, authenticity, legality or quality. Examples include technical managers, quality assurance staff, section heads/managers (e.g. those accountable for overseeing production and cleaning activities (i.e.
those responsible for ensuring the correct standards are maintained)), any on-site laboratory staff and product development teams.
Responsibilities must be defined for key aspects of the food safety and quality management system, including, for example, decisions on corrective actions, non-conforming products, process deviations, finished product release, document control and customer complaints.
It is usual for specific responsibilities to be defined within the job descriptions of key staff (especially for management and supervisors); however, they may instead be described within site procedures (e.g. responsibility for decisions on corrective action may be incorporated into the site’s corrective action procedure).
It must be clearly documented who is expected to deputise in the absence of a manager.
Deputies would usually be identified on the organisational chart and/or in job descriptions, but documentation could also be in the form of an additional table. The responsibility may be assigned to either a more senior or more junior person, as long as the deputy has the knowledge and ability to adequately cover for the absent manager. Deputies may be appointed for the whole role or particular responsibilities may be deputised to different people; as long as this is clearly defined.
The auditor will be looking for both documented responsibilities and evidence that the responsible person is able to fulfil the role (clause 7.1.7 requires the company to review the competencies of staff and ensure that any necessary training, mentoring or experience is provided).
1.2.2 The site’s senior management shall ensure that all staff are aware of their responsibilities and demonstrate that work is carried out in accordance with documented site policies, procedures, work instructions and existing practices for activities undertaken. All staff shall have access to relevant documentation.
Interpretation Staff roles and responsibilities
The objective of this clause is to ensure that all staff, including temporary staff and employment agency staff, are able to work effectively and ensure that food safety, authenticity, legality and quality are maintained.
Consistent application of these systems relies on the correct and established processes being documented, accessible by relevant staff and used in practice. This will usually be established by the auditor discussing roles with the employees themselves during the audit.
There is no requirement for a detailed job description; however, staff should be aware of their particular responsibilities. Where the role or an activity that makes up part of the role covers a food safety, authenticity, legality or quality issue described within a procedure (e.g. a CCP or prerequisite programme), the staff must understand what is expected and be able to access the relevant procedure.
1.2.3 Staff shall be aware of the need to report any risks or any evidence of unsafe or out-of- specification product, equipment, packaging or raw materials, to a designated manager to enable the resolution of issues requiring immediate action.
Part II Appendic es
Interpretation Reporting product safety risks and non-conforming product
Where a food safety risk is identified by a staff member, the reporting function and subsequent activity should be sufficiently rapid and effective to mitigate any food safety risks.
Identified risks may be associated with, for example, raw materials, work in progress, final product, packaging or equipment. Good practice is to encourage staff to report as wide a range of situations as possible, including out-of-specification results, damage, errors or when the staff member is concerned that something does not look right or as it normally does.
The transfer of information from staff to senior management regarding unsafe or out-of- specification situations is an example of a good food safety culture. If staff feel supported and empowered to identify and report issues and make positive changes, this will typically be reflected in the effectiveness of the site’s product safety management systems.
1.2.4 If the site does not have the appropriate in-house knowledge of food safety, authenticity, legality or quality, external expertise (e.g. food safety consultants) may be used; however, the day-to-day management of the food safety systems shall remain the responsibility of the company.
Interpretation External expertise
Where external food safety consultants have been used as the main source of technical knowledge for a specific activity (e.g. to lead the development of the food safety plan or HACCP plan) it is essential that day-to-day responsibilities are under the control of the site and that it has personnel in place with working knowledge of the product safety systems, who can operate effectively even when the consultant is not available.
For example, the requirements of clause 1.2.1, regarding deputies and documented procedures, apply even where a food safety consultant is used.
A food safety consultant is seen as a service provider to the site and is therefore subject to the requirements of section 3.5.3.