NQA ISO 22000 Implementation Guide
NQA ISO 22000 Implementation Guide
53,000
CERTIFICATES TRANSPARENT 100
GLOBALLY
Contents
Introduction to the standard P04
The Annex SL was initially approved in 2012. This section standards. This made it difficult for organizations to integrate Organizational planning and control
of the ISO/IEC Directive describes the common structure of the implementation and management of multiple standards;
all ISO management systems standards in which the new or Environment, Quality, Health and Safety and Food safety being
updated standards must be focused on when developing the among the most common.
relevant requirements. PLAN (FSMS) DO (FSMS) CHECK (FSMS) ACT (FSMS)
This structure tries therefore to eliminate confusions, 4. Context of the organization 8. Operation 9. Performance 10. Improvement
Prior to the adoption of Annex SL there were many differences duplications and conflicts from the different interpretations of 5. Leadership evaluation
between the clause structure, requirements, terms and management system standards. 6. Planning
definitions used across the various management system 7. Support
(Including control of externally provided
processes, products or services)
Risk-based thinking
The best way to consider frequency of audits is to look at the
risks involved in the process or business area to be audited.
Any process which is high risk, either because it has a high
SECTION 1:
that will help to better understand its requirements:
A Food Safety Management System
• ISO 22004:2014 - Guidance on the application
is primarily intended to ensure food of ISO 22000
is safe for consumption. It does
SCOPE
this through the application of the • ISO 22005:2007 Traceability in the feed and food
chain - General principles and basic requirements
processes determined by you as
for system design and implementation
necessary for your operations, as well
as the processes determined by the • ISO/TS 22002-1:2009 PRP on food safety
standard as necessary for continual - Food manufacturing
improvement. A FSMS aims to assure • ISO/TS 22002-2:2013 PRP on food safety
conformity to applicable statutory, - Catering
regulatory and customer requirements. • ISO/TS 22002-3:2011 PRP on food safety
The 2018 version includes also feed producers - Farming
and animal food producers within the scope. • ISO/TS 22002-4:2013 PRP on food safety
- Food packaging manufacturing
The Scope section of ISO 22000 sets out:
• the purpose of the standard; • ISO/TS 22002-6:2016 PRP on food safety
• the types of organizations it is designed - Feed and animal food production
to apply to; and • ISO/TS 22003:2013 FSMS - Requirements for
• the sections of the standard (called bodies providing audit and certification of Food
Clauses) that contain requirements Safety Management Systems
that an organization needs to comply
with in order for the organization to be • ISO 10012:2003 Measurement management
certified as “conforming” to it (i.e. being systems - Requirements for measurement
compliant). processes and measuring equipment
• ISO/TR 10013:2001 - Guidance for quality
ISO 22000 is designed to be applicable
management system documentation
to all organizations in the food chain,
regardless of size and complexity; this • ISO 1015:1999 Quality Management
includes organizations that are directly or - Guidelines for training
indirectly involved in one or more stages of • ISO 19011:2018 - Guidelines for auditing
the food chain. Small and/or less developed management systems
organizations can implement and maintain a
FSMS that complies with ISO 22000. • ISO 31000:2018 Risk management - Guidelines
DEFINITIONS
the Standard it is important that as with past ISO 22000 versions, the word “shall”
indicates the mandatory requirements that an organization must meet and external
auditors, such as NQA, are required to verify conformance and effectiveness against.
In order to understand how each of the following clauses applies to each other the
remaining text applies to this diagram:
This section sets out the terms and definitions that are used in the Standard which may need
further clarification in order to apply the Standard to a particular organization. Some of them PLAN DO CHECK ACT
also include notes that seek to provide further information and clarity.If an electronic version
of the Standard has been purchased the definitions are hyperlinked to other definitions so 4 9
5 6 7 8 10
that there interrelationship can be seen. Context of the
Leadership Planning Support Operation
Performance
Improvement
organization & evaluation
ORGANIZATION
expectations of
interested parties
The concept of customer has SHAREHOLDERS
disappeared to introduce the term of
This is a new concept in terms of ISO 22000:2018. This section requires the organization to analyse interested party. This section requires
its context, determine its interested parties, define the scope of the food safety management system the determination of interested parties SUPPLIERS LANDLORDS
and a clear focus on the processes and requirements needed to achieve the food safety objectives. (commonly known “stakeholders”)
that can influence FSMS positively
The clause is sequential as there is a need to understand the organization and context (4.1), prior to identifying interested parties and negatively. Once it has been
and understanding their needs and expectations (4.2), the output of both 4.1 and 4.2 allows determination of scope (4.3), and then decided which interested parties are
ultimately designing the FSMS (4.4): relevant and significant, their needs
and expectations within the FSMS
Clause 4.2 should be addressed.
Clause 4.1 Clause 4.3 Clause 4.4 COMPETITORS REGULATORS
Understanding the needs
Understanding the organization Determining the scope Food Safety They will probably be shareholders,
and expectations of
and its context of the FSMS Management System
interested parties landlords, regulators, customers,
employees, trade associations,
competitors, suppliers, distributors, FSMS
Understanding the context of the organization is usually conducted by top management with information about the business and and consumers, among others.
activities gathered at every level of the organization. Discussion points focus on internal and external issues which have an impact
on the FSMS system. You need to identify all those parties
and analyse how they can affect the
CONSUMERS DISTRIBUTORS
achievement of the main objective of a
4.1 Understanding the these issues can be positive or negative, but equally considered
to define our context. Once the context is determined, this will
FSMS that is to ensure food is safe.
organization and its context facilitate the establishment of food safety objectives. Some needs and expectations of our
interested parties are mandatory and
This section implies an analysis of the risks or issues that can There are numerous methodologies that can be used to incorporated into law and regulatory
impact our business, not just the internal but also the external determine context, such as the SWOT (Strengths, Weaknesses, requirements therefore must be
issues that can affect the capability of the management system Opportunities and Threats) analysis, the CPM (Competitive considered. The identified interested TRADE
CUSTOMERS
to get the intended results. As external issues we could include Profile Matrix) or PEST (Political, Economic, Socio-cultural and parties and their requisites must be ASSOCIATIONS
social, cultural and political trends, legal changes, technology Technological) analysis, among others. obviously revised when defined and
advancements, etc. that can influence the achievement of the also when changes apply to the
Even though documented information is not required with EMPLOYEES
established food safety objectives. organization. Having defined who
regard to context, this is extremely useful when your system is your Interested Parties are, ISO 22000
As these issues may vary, its revision must be done regularly audited and to demonstrate your understanding and analysis requires that you determine their
and now it is also mandatory as an input during your periodic of the mentioned issues, i.e.: meeting minutes, graphics, data potential and actual effects.
management review meetings. We also must bear in mind that analysis, etc.
For example:
‘The fermentation, carbonation and packing of red wine into
glass bottles’
Using this example, you can see that each step will incorporate
many processes including workers, machinery, regulatory
requirements, external providers, customers (end users) and
competence which will be audited.
New consideration for
4.4 F
ood safety climate change
management system ISO has made changes to ISO 22000 to emphasise the
As a result of the previous clauses, an organization then has importance of addressing the effects of climate change
to establish, implement, maintain and continually improve a within the framework of organisational management
FSMS. systems.
This section mentions the need of focusing in the interaction of To enhance organisational awareness and response
processes. All processes and their interactions included in the to climate change, ISO has introduced two critical
scope of the FSMS must be determined and controlled in order changes within Clause 4:
to get the intended results in accordance with the strategic
direction of the organization and the food safety policy. Original Clause 4.1:
“Understanding the organisation and its context. The
organisation shall determine external and internal
issues that are relevant to its purpose and that affect
its ability to achieve the intended result(s) of its XXX
management system.”
LEADERSHIP
roles, responsibilities and authorities throughout the
context of your organization. organization. Top management shall also ensure that all
responsibilities and authorities have been assigned and
The top management commitment with respect to the
understood.
FSMS must be visible and palpable. A good way to
demonstrate commitment to clients, operators and general All personnel must know what it is expected from them
public is to ensure your food safety policy is visible and (responsibilities) and what top management allows
also well communicated in any or all of the following: them to do (authorities). This can be easily implemented
The standard states that top management shall demonstrate leadership and commitment through an organigram and job descriptions of all staff
• Recruitment packs
with respect to the FSMS. But who is top management? According to ISO 22000, top • Induction packs
of the organization with their duties and authorities
management is the person or group of people who direct or control an organization at the described.
• Supplier evaluations
highest level. • Supplier contracts ISO 22000 does specify a requirement for a nominated
food safety team leader that ensures the system is
• Notice boards on site
established, implemented, maintained and updated
• Website / intranet site
Demonstrating leadership • Annual staff appraisals
when required.
and commitment Setting the food safety It certainly makes life easier for an external auditor to
have a clear point of contact, and this person must
There is no longer an excuse for top management not being
policy Don’t forget your food safety policy must be available and
maintained as documented information. have suitable authority to manage the system, ensure
present during a certification audit. An external auditor will the work is managed as well as the relevant training
Practically this requirement has not changed with
expect to discuss leadership with those who manage the and competencies of the food safety team, report
respect to the previous version. A policy contains the
organization. on the effectiveness and suitability of the FSMS and
intention and direction of an organization as formally
make continual improvements as determined by top
expressed by its top management.
The previous version of ISO 22000 already included management.
examples of how leadership can be demonstrated within The food safety policy is approved by top management
the FSMS management system: and will drive the controls that are in place and the
• Establishing the food safety policy actions that are carried out to improve it.
• Demonstrating that food safety is supported by the
The standard specifically requires that the food
objectives of the organization
safety policy, which shall be appropriate to the
• Provision of appropriate and sufficient resources
purpose and context of the organization, must
• Facilitating the culture of continual improvement
include commitments to:
• Communicating appropriately amongst interested parties
• Ensuring the integration of the FSMS requirements into the • Provide a framework for setting and reviewing
organization’s business processes objectives of the FSMS
• Leading the management review meetings • Satisfy applicable food safety requirements, including
statutory and regulatory requirements and mutually
Additionally, the 2018 version states that top management
agreed customer requirements related to food safety
shall also:
• Address internal and external communication
• Ensure that the strategic plans of the organization and the • Continual improvement of the FSMS system
food safety objectives are compatible and integrated within
• Ensure competencies related to food safety
the organization
• Ensure the integration of the FSMS requirements into the
organization’s business processes
SECTION 6:
PLANNING
Planning is one of the key components of any management system. This section sets out a
framework that asks an organization to analyse itself to determine the risks and opportunities
of its activities and then how to address them.
• What will be done In light of this, clause 6.3 expects that any changes that you
• What resources will be required (to the best of your determine are necessary to the food safety management
understanding at the time) system are carried out in a planned manner. This should take
• Who will be responsible into account the extent of the changes deemed necessary, the
• When actions will be completed potential impact on the existing system, how you will resource
• How results will be evaluated the changes and any effect this may have on current roles,
responsibilities and authorities.
Putting these into a simple matrix can help to
clarify the objectives, however if you already
record this type of information somewhere else,
there is no need for you to duplicate.
OPERATION
needed to categorize them to be managed as OPRP activities is not the same one that conducts their
or CCP, so you need to evaluate: monitoring. Through verification you will be able to
• the probability of failure and how easy is to keep it make sure that:
under control
• its severity when failing and what effect can cause the • Input to hazard analysis is updated
measure implemented • PRPs are implemented and updated
• its location with respect to other activities • OPRPS and CCPs are implemented and effective
This is the core of a FSMS, where mostly all HACCP principles are integrated and the implemented to reduce specific hazards • Hazard levels are within identified acceptable levels
• whether it’s specific for that particular hazard • Every implemented procedure you established
moment when “doing” is the key after being planning your system. is effective
• if other measures are required to reduce the hazard to
an acceptable level
All these verification results must be assessed
• the viability to establish measurable critical limits and/
Annex SL only provides a common requirement, operational procedures in place and challenge its effectiveness, so you by the defined food safety team, so this will give
or action criteria
planning and control, the rest of clauses are specific to will be able to see if they work when needed. The documented you information with regard to how your system is
• the feasibility of monitoring to detect failures on the
each standard. evidence of these tests will be retained for a defined period not performing.
applicable determined limits and also corrections in
less than the shelf-life of the product/s provided.
Therefore, the first step is to ensure you have fully understood case of failure
all the requirements for your product or service. This will Bear in mind that if traceability is an important factor in your
Don’t forget to maintain this decision-making process
involve liaising with customers as well as implementing product or service delivery, then you must ensure that all
measures to ensure all applicable legal requirements are monitoring and measuring equipment is fit for the activities
and results as documented information!
Control of non-conforming
met. This means, establishing criteria for your processes. It is
essential that you determine and review your organization’s
undertaken and is suitably calibrated and maintained. You
must maintain documented evidence of such equipment being
Your hazard control plan must contain, as a
minimum, the following information for all identified
products and processes
ability to meet the necessary requirements before you commit fit for purpose. CCPs and OPRPs: We must start this section ensuring all staff responsible for
to anything. • what food safety hazard are you controlling with this corrections and corrective actions must be competent and
At this point, the ISO/TS 22005:07 may be of help as it will
CCP or OPRP have the authority to carry out these activities.
All controls you previously planned, that may be supported provide you guidelines for the establishment of a good
• what measure have you put in place to do so
by PRPs, OPRPs and/or your HACCP plan, must be now in traceability system. Within section 8 of the ISO 22000 standard, the specified
• the critical limit/s or action criteria in place that can’t
place and all relevant documented evidence will be available to corrective actions and corrections are focused at the
be exceed
demonstrate you did act as planned.
Hazard control • how do you monitor this activity operational level, so this will include all immediate actions to
• which corrections and corrective actions will be be taken when limits established for OPRPs and CCPs are
Prerequisite programmes There is no much difference between the requirements carried out if critical limits or action criteria is not met exceeded and also actions that will be done to avoid their
established by the HACCP principles developed by Codex
(PRPs) Alimentarius and the information you will find in this section.
• who is responsible for this activity (defined
responsibilities and authorities)
recurrence.
The food safety team will collect, maintain as documented • what records do you maintain as monitoring evidence When critical limits for a CCP or action criteria for an ORP are
2018 version suggests the use of specific ISO/TS 22002 series and update preliminary information to continue with this point, not met, you must treat the product as potentially unsafe from
depending on the sector you are working on, to determine such as scientific documentation, regulations applicable to the As mentioned in section 3 when talking about entering the food chain. These products must be identified and
the PRPs applicable to your organization that will assist in sector, customer needs, historical data of food safety hazards definitions, the critical limits established for CCPs must retained at your organization at all times until its evaluation and
controlling food safety hazards. associated with the product or service, etc. be measurable. Likewise, the action criteria defined for disposition is determined.
The idea is to implement PRPs that are appropriate to your the OPRPs must be also measurable or observable.
Before carrying out the analysis of hazards, do not forget to You need to define why you have selected those Where monitoring shows that critical limits at CCPs are
context, size and activities conducted. These prerequisites will establish a multidisciplinary team with a defined leader. This not met, you shall not release these products; instead their
be established before conducting the hazard analysis, and its specific critical limits and action criteria and establish a
is the first step of HACCP, and although ISO 22000 does not monitoring system to defect any failure. disposition must be documented and authorized ensuring:
selection, implementation, monitoring and verification must be specify this requirement in this section, it is mandated as part
also documented. of the responsibilities of top management. If visual inspections from staff are implemented as a • their reprocessed to ensure the food safety hazard is
monitoring system for a specific OPRP, you need to reduced to an acceptable level,
The standard provides a list of PRPs that every organization Once established the characteristics of raw materials, end • other use that do not jeopardize food safety in the food
shall consider, easy and quite straight to the point, do not miss define what instructions or specifications were provided
products, intended use and a very detailed flow diagram/s, to personnel in order to ensure the system will be chain, or
any of them! as the standard now requires, it’s time to carry out the hazard • their destruction or disposal as waste
effective.
analysis. You can find some notes that make clear from where
Be ready to expect the the identification of hazards can be obtained, for example the As usual, at this point, any failure will be considered Likewise, when defined action criteria for an OPRP are not
met, the identified non-conforming products won’t be released
unexpected experience that can refer to information from internal staff or
experts in the matter.
non-conformity and you must follow it up establishing
immediate corrections, retaining unsafe products unless all established monitoring activities demonstrate that
under control, analysing the cause and implementing control measures were effective, the combined effect of control
Have you established a traceability system and also a The evaluation of hazards, based on their severity of harm and measures make the product suitable, or other verification
corrective actions to ensure recurrence is prevented.
procedure to respond to emergency situations? Let’s prove it! probability of occurrence, will include the establishment of activities can demonstrate the product/s conform/s to
specific measures or combination of them to prevent or reduce Now that the PRPs, hazard control plan and all related acceptable levels for the specific food safety hazard.
Examples of emergency situations could be natural disasters,
the significant food safety hazards to acceptable levels. But requirements are established and documented when
an earthquake, sabotage, blockage of main utilities, If they are already out of your premises, then you must initiate
make sure all implemented measure/s worked as expected! necessary, look back and make sure the preliminary
environmental accidents, etc. a withdrawal or recall and notify all relevant interested parties.
(Remember how validation is defined in section 3 of this guide) information to enable the hazard analysis is still
When previously ISO 22000 did not require a test for these adequate!
activities, now it is crystal-clear. Implement a system with
Process performance actions must be taken without undue delay. If a long-term fix
requires significant planning and maybe funding approval,
As an organization you will need to decide what you need to consider whether a short-term fix is possible and appropriate.
monitor and measure in order to be assured that your processes
are operating as intended. You will also need to establish how Management review
often you will monitor and measure, what resources will be
required, how results will be recorded, analysed and evaluated Management Review is an essential element of the FSMS.
and who will carry out these evaluations. This often results in a The aim of the review is for Top Management to assess the
series of Key Performance Indicators (KPIs) which relate directly performance of the management system to ensure it has been
to your food safety objectives (set in section 6). You will need effective, adequate and suitable for the needs of the business,
to retain documented information as evidence of the results ultimately preventing unsafe food products or services to
of performance evaluation and use them as an input to the consumers. The management review is also a planned activity to
management review and the updating of the FSMS. review objectives including compliance and to set new objectives.
The Standard says that this process should be documented. There are various ways to achieve this but usually this comprises
a “Corrective Action Request” (CAR) for each corrective action and a “log” which is essential to record and manage the CAR’s.
This is especially useful where numerous corrective actions are raised.
Audit date NC description Responsibility When due Action taken Date of closure
More complex systems can “code” different types of nonconformity. This can then be used to generate trend data that can be
useful in on-going performance appraisal of the EMS and the Management Review process.
1. To have an effective FSMS ensure that 6. Review your monitoring and measuring
“Top Management” is committed to its devices are calibrated at specified
establishment, implementation, update frequency to ensure reliable results.
and continual improvement.
7. Remember your suppliers. Some
2. Get everyone involved. Top suppliers will help you enhance your
Management for context, requirements, FSMS, some will increase your risk. You
policy and objectives setting; food need to ensure any high-risk suppliers
safety team and assigned personnel have controls in place that are at least
with valuable competence for hazard as good as yours. If they don’t then look
analysis and risk assessment, process for alternatives.
control and procedure writing.
8. Food Safety concepts are likely to
3. Make sure your system includes be new for many or most of your
two PDCA cycles at operational employees. People may need to change
and organizational levels, and habits ingrained over many years. A
communication between them is single awareness briefing is unlikely to
established and maintain at all times. be sufficient, so focus on your personnel
competence as a fundamental key for
the implementation of a good FSMS.
4. Remember to identify how you have
selected the applicable food safety
hazards within your system; these are 9. Remember to allocate sufficient
specific to each process and product resources to routinely test your controls.
and also depending on applicable The threats your organization faces will
regulations and customer needs, so this constantly change and you need to
information is not interchangeable! test whether you are able to respond to
those threats.
5. When changes to products or
processes occurred, either planned
or unintentionally, ensure your system
is reviewed and established control
measures still effective for the intended
purpose of the FSMS.
HABC Level 2 Award in HACCP for Food Manufacturing (RQF) - In-House 1 1 Day £1595
HABC Level 3 Award in HACCP for Food Manufacturing (RQF) 2 2 Days £625
We have been The professionalism Since being certified
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Consultants as our ISO from CBO Associates 14001 we have relied
ISO 22000:2018 Lead Auditor Training 3 5 Days £1550 external auditor for the showed during our on Martin Giddens
past couple of years ISO 9001 process from Morton Hodson
HABC Level 4 Award in HACCP for Management (CODEX Principles) (RQF) 3 5 Days £1395 and I wish that we had was excellent. Clark for support with our
done so much earlier! is a professional annual process auditing.
We have found them in his delivery, a Martin understands our
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providing not only a that offers a high advises us of which
comprehensive audit level of service which changes to guidance
report but additional makes him an ideal and regulations apply
ideas for improvement QHSE Consultant. and what we need to
and contacts for our His ideas and do to implement them.
company that we delivery are both Martin’s expertise
could additionally creative and effective. ensure that staying
benefit from. CLARK-IT,
compliant is simple.
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Authored on behalf of NQA by: Marta Vaquero, NQA Food Safety Certification Manager
www.nqa.com