Part II Appendices4.11.5The cleanliness of equipment shall be checked before equipment is released back
4.12 Waste and waste disposal
Part II Appendic es
Interpretation
continued • In most situations, negative results are seen as good news and lead to an assumption that all systems are operating correctly and within permitted parameters. However, if results are continuously and consistently negative and there is a long history of negative results, this may be indicative that the site should review its programme to consider whether the correct locations are being tested, in the correct way, for the correct organisms. The aim of the programme is, after all, to identify areas of concern.
Interpretation Waste storage
Waste collection containers and rooms housing waste facilities must be managed to minimise the risk of contamination of products. Particular consideration must be given to:
• identification of waste containers and storage areas to ensure waste is collected only in designated containers/areas
• ease and effectiveness of cleaning (see section 4.11)
• keeping facilities well maintained
• emptying at appropriate frequencies
• keeping external waste containers covered or room doors closed, thus ensuring that waste cannot fall out of containers or stray out of designated rooms to cause a contamination
• riskthe pest control implications of external waste collection areas.
4.12.3 Waste removal from open product areas shall be managed to ensure that it does not compromise product safety.
Interpretation Removal of waste from open product areas
Waste should be removed from open product areas to minimise the risk of product contamination (for example, from allergens, pathogens, taint, non-compliance with claims).
A number of considerations may be needed when planning waste handling, including:
• risk assessment – to identify the risks associated with specific products or production areas
• process flow – for example, the movement of product, waste and staff
• identification of suitable equipment – for example, are lidded or sealed containers needed; are there different types of waste that need to be segregated or handled differently?
• scheduling of waste removal – for example, how frequently is waste removed; is removal completed during or after the production run?
4.12.4 If unsafe products or substandard trademarked materials are transferred to a third party for destruction or disposal, that third party shall be a specialist in secure product or waste disposal and shall provide records which include the quantity of waste collected for destruction or disposal.
Interpretation Unsafe and trademarked waste
Requirements for the disposal of trademarked waste must be defined within a contract with the waste disposal contractor. Records of destruction or disposal must be maintained. The objective is to ensure that waste products do not re-enter the food supply chain once sent for disposal. If unsafe products are transferred to a third party for destruction, the third party must be a specialist in secure product or waste disposal and must provide records which include the quantity of waste collected.
Part II Appendic es
Effective processes shall be in place to ensure the safety and legality of by-products of the primary processing activity of the site.
Interpretation
All products intended for the human food chain must not be injurious to health, and must be fit for human
consumption. Therefore the site’s procedures to control the handling and storage of surplus food and by-products must ensure that safety and legality are maintained.
Similarly, by-products or other materials intended for animal feed must meet the relevant requirements for safety and legality pertaining to those supply chains.
Clause Requirements
4.13.1 Surplus customer-branded products shall be disposed of in accordance with customer- specific requirements. Customer brand names shall be removed from packed surplus
products under the control of the factory before the product enters the supply chain, unless otherwise authorised by the customer.
Interpretation Surplus customer-branded products
This clause covers the situation where surplus product is not required by the intended customer (e.g. because of a fall in predicted orders), but is still suitable for sale to alternative customers. It does not include sales to staff or donations to charity, which are covered separately in clause 4.13.2.
The release of surplus product to alternative customers must only take place in accordance with the original brand owner’s specific requirements. For example, in many cases the product packaging (or associated documentation) will refer to the brand owner and these brand names will need to be removed before the product leaves the site.
4.13.2 Where customer-branded products which do not meet specifications are sold to staff or passed on to charities or other organisations, this shall be with the prior consent of the brand owner.
Processes shall be in place to ensure that all products (own-branded and customer- branded) which are sold to staff or passed on to charities or other organisations are fit for consumption and meet legal requirements, and that their traceability is maintained.
Interpretation Staff shops and donations of products to charity
Many companies sell products to staff or donate them to charity when they are not required by the intended customer (e.g. because of a fall in predicted orders, minor cosmetic damage to packaging, or failure to meet the brand owner’s specification).
In many cases the product packaging (or associated documentation) will refer to the brand owner and therefore release to charity or staff must only take place with the prior consent of the brand owner. It is not necessary for the site to obtain this consent for each individual batch of product or on each occasion that the product is sent to a charity; however, the brand owner’s policy or permission must be defined (e.g. in a policy document or within the company’s contract).
Interpretation
continued All products (customer-branded and own brand) must still be safe, be legal (e.g. meet legal requirements for labelling), maintain traceability and be fit for consumption; therefore the site should have documented procedures which detail the product assessment and release process. Staff responsibilities, including which staff have authorisation to release products for staff sale or charitable donation, should also be made clear.
4.13.3 By-products and downgraded/surplus products intended for animal feed shall be segregated from waste and protected from contamination during storage. Products for animal feed shall be managed in accordance with the relevant legislative requirements.
Interpretation Food for animal feed
In many parts of the world, there are specific regulations relating to the suitability of products and by-products for inclusion in animal feed (e.g. EU legislation on animal by- products and the control of transmissible spongiform encephalopathies). It is essential that, where products and by-products are supplied for animal feed, the site is aware of, and complies with, the relevant legislation. There are several recognised feed schemes and, where applicable, certification to such a scheme may be required. The animal feed contractor must also be appropriately licensed.
Materials for inclusion in animal feed must be segregated from other waste streams and managed to prevent contamination, and should be labelled accordingly.