BRC-IoP-EN

ISA Netherlandsp.a. Industrieweg 168131 VZ WijheNederlandTel.: +31 (0)570 524 688Fax.: +31 (0)570 524 453

BRC/IoP Global Standard Food Packaging and Other Packaging Materials -

Version 2

Issue 2

Auditor: J. Quirijnen

2007-2228-BRC/IoP

This report shall not be reproduced in part without the permission of ISACert The Netherlands

of 26

of

Euro Pool System International BV

on

19 and 20 February 2007

Detailed Audit

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Part 1 - Audit summary

Audit detailsAuditor: Signature: Audit Date: Date of intial audit:

Repeat audit

J. Quirijnen 19 and 20 February 2007

18 and 28 September 2006

Country:België

Supplier name: Euro Pool System International BVAddress, Postal Code, City: Industrie zone 4, Broekooi 170, 1731 Zellik

Emailaddress:[email protected]

Scope of the AuditPurchase, receiving, cleaning, storage and distribution of returnable

hard plastic crates intended for the direct and indirect storage of food

Tel. Nr: Fax. Nr.:0032 2 464 9602 0032 2 464 96 01

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Ope

ning

Doc

umen

tre

view

Fact

ory

visi

t

Clo

sing

mee

ting

xx x x x

x x x

x x x x

x x x

x x x

xx

xx x

food.

Present at Audit (X)Name Function

Mr. L. Selleslags Chief Operational Officer

Category:B

Mr. G. Luyts Operations Manager BeneluxMr. L. Haaksman Technical services

Mrs. van der Meer Corporate Quality ManagerMr. P. Thijs Depot manager Zellik

Mr. D. Janssen Operator Mr. K. Wtavir Forklift truck driver / sorter

Mr. N. Bernaerts Process engineerMr. Komlan Operator

Audit started at Date 2 9:00 h Audit ended at Date 2 15:30 h

Mr. D. Samaey Service providerAudit started at Date 1 9:00 h Audit ended at Date 1 13:30 h

Result of the AuditInternational Supplier Auditing bv has established that the processes of the Company on date 19 and 20 February 2007 for the scope as stated above did fulfil the requirements for the BRC-IoP Standard.

repeat audit 12 months

Previous Evaluation Grade B Evaluation Grade B

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Euro Pool System is a rental company for returnable packaging for fruit and vegetables and other packed food products. The company is originated from three auctions. The head office of Euro Pool System is located in Leidschendam, the Netherlands. In Zellik Euro Pool System does has got a plant where dirty crates are cleaned and shipped to customers. In totally Euro Pool Systems does have 40 clean installations all over Europe, which are all outsourced with the exception of the cleaning location at Zellik. In totally Euro Pool Systems does have approximately 100 employees. Per year 30 million crates are cleaned in Zellik and 400 million in total in Europe. In Zellik the cleaning process is a 3 shift operation during 5 days / week. The plant is 3 years old. The production organisation in Zellik is outsourced but the depot manager and technicians are working for Euro Pool System. Euro Pool system does have 2 types of crates, crates which can fold in and crates which are fixed. During the audit the cleaning of foldable crates was carried out.

General Company Information

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Dear reader,

Aim of the report:

This impression is based on:1. Audit from a production day (s) (sample)2. Assessment against the selected technical standard3. The professional opinion of the auditor

The auditor can judge the non-conformities found as: critical, major or minor.

To gain the maximum benefit from this information, we advise you to read the following:

To obtain a reliable impression in how the supplier meets the production process controls, concerning the specified requirements for product quality and food safety.

Weighing of the non-conformities is never totally objective and the auditor decides the seriousness of non-conformity found.

Tips for the reader of this report

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The ISA report contains:· Information about the auditee · The result of the audit· Summary of the non-conformities found· Improvement plan of the auditee to solve the found non-conformities· Detailed audit report with an overview of all the findings of the auditor

If there are any questions, please let us know.

Experience has taught us that every reader has there own ideas about scoring of a non-conformance and the gravity of it. This will be due to culture, own experiences, education and background.

The ISA Report gives transparency to the reader. The auditee prepares a corrective action plan based on all the non-conformities found. You will find the corrective action plan after the summary of performance in the audit report. Besides this corrective action plan, the auditee must obtain objective evidence for solving those non-conformities. This objective evidence must be send to ISA and will be judged by the auditor.

ISA wants to add confidence in the chain by creating transparency and working against high standards.

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ISA-Audit ReportPart 2 – Summary of performance

Section of Standard2 ORGANISATION:

3 HAZARD AND RISK MANAGEMENT SYSTEM:

4 TECHNICAL MANAGEMENT SYSTEM:

Euro Pool System has a organisation chart including descriptions of responsibilities. \The quality policy includes product safety and hygiene aspects. Top management is clearly involved. Responsibilities are defined. A covering during absence is organised. The management review is carried out yearly and is including the evaluation of the HACCP system. During the audit no non-conformities regarding organisation are established.

Euro Pool System does have implemented a HACCP system. The risk assessment is based on a "likelihood x severity" system resulting into 4 possible risk categories. Euro Pool System did not established CCP's but several "control points" relating to hygiene are part of the HACCP system (pre requisite program), such as cleaning procedures, pest control and glass policy. Verification is carried out. During internal audits "CCP's" are audited. During the audit no non-conformities regard the hazard and risk management system were established.

The quality policy is clear and includes food safety and hygiene aspects. During the audit it ti d th t thi li i d t d b th l Th Q lit l i ti l

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was noticed that this policy is understood by the personnel. The Quality manual is operational and does include a cross reference list BRCIoP. Record keeping, document- and specification control is conform requirements. A product recall procedure is available. Non conform product is handled correctly. During the audit a traceability test was conducted; results were conform. The process control of the rinsing of crates is highly automated and conform requirements. Calibration on the conductivity equipment (concentration of cleaning detergent) is carried out. Complaint procedures are implemented. The control of outsourced service providers is clear and includes regular audits and other verification systems. Corrective actions are taken. A monitoring on microbiological aspects is implemented as well as a visual verification system based on DIN 10522. During the audit no non-conformities regarding the technical management system were established.

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The perimeter and grounds are well maintained. The City forbids Euro Pool System to remove plants against the outer wall of a part of the factory but plants are kept as small as possible. The product flow goes from dirty to clean and prevents cross contamination. The factory is only a few years old and of a good standard. The preventive maintenance of equipment is organised very well and is based on an inspection system carried out regularly by an external company. Euro Pool System does not use food grade lubricants but during the audit it was noticed that on one spot the risk of product contamination was possible. A clearance procedure after maintenance is implemented. The house keeping and hygiene rules are clear and implemented. The general hygiene of the factory is very high. Non conformities regarding a broken door, lubricants and the labelling of cleaning chemicals were noticed.

Foreign body control is controlled well, due to the high hygiene standard of the factory. A glass procedure is implemented and glass audits are recorded. The use of sharps is adequately controlled. Chemicals are correctly stored. Pest control is outsourced and complies to the standard. Transport is outsourced. During the audit no non-conformities regarding contamination control are established.

7 PERSONNEL:

6 CONTAMINATION CONTROL:

Personnel enters the building via dedicated routes. Personnel facilities are adequately designed and maintained. This includes toilets and hand washing facilities. The personnel

5 FACTORY STANDARDS:

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g g phygiene rules includes demands on health / sickness, jewellery and other personal items. Protective clothing is organised. Personnel washed protective clothing at home. Training on hygiene is given out for all personnel and records of these training are being kept. During the audit one non conformity regarding the hygiene rules for contractors was established.

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MAJOR NON-CONFORMITIES Foundation Level

Nr. Reference Level Requirement BRC-IOP Global Standard Clarification Date

MINOR NON-CONFORMITIES AB Level


1 5.3.1 AB External walls shall be well maintained and of sound construction.

N External door at the back of the factory is broken. Door blocked with means of pallets (but this is not 100 % closed). E t t t l

ISA-Audit ReportPart 3 – Non-conformities / Schedule of Action

CRITICAL NON-CONFORMITIESNo critical non-conformities were established

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Extra pest control measures implemented. Other door at the back was slightly damaged (small opening under the door which could allow mouse to enter the building).

2 5.5.10 AB Cleaning chemicals shall be fit for purpose, suitably labelled, secured in closed containers and used in accordance with manufacturers' instructions.

N Close to the palletiser a white plastic bottle without label detected. In the first floor in the "storage area" a orange extract stored for the removal of labels. In the "dirty crate area" a red box with brush detected. the content of this box is not clear.

3 7.1.5 AB Contractors and visitors shall be made aware of all hygiene procedures for the premises and made especially aware of the requirements of the areas they are visiting.

N External contractors do not sign in at the entrance and therefore do not receive the correct version of the hygiene rules.

MINOR NON-CONFORMITIES B Level


1 5.4.5 B A planned preventative maintenance programme for plant and machinery shall be in place and shall address the risks of contamination.Compressed air that comes into contact with the product should be filtered to prevent any contamination.

N At the grease points "kantelbakken" no food grade lubricants are being used, although a risk of product contamination does exist at this point.

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Section

Leve

l Intention BRC IOP Version 2

Motivation

22.02.0.0 »» There shall be an organisational structure, which clearly

defines job function, responsibility and reporting relationships of those staff whose activities affect the implementation and compliance with the Standard.

Y Responsibilities are described in ORG 201. Seen job description Corporate Quality manager.

2.1 AB The responsibility for the implementation and maintenance of the principles contained in this standard shall rest with the most senior on-site management team

Y During the audit it was noticed that the senior management team is fully involved in the development, implementation and maintenance of the quality system. This is demonstrated via the quality policy GEN 120 dated 110706, signed by the director as well as the involvement of the management during the whole audit.

2.2 AB There shall be verifiable, written evidence that the team acknowledges this responsibility, has assigned the appropriate resources and given sufficient priority to the continued compliance of the site with the Standard.

Y The involvement of the top management is demonstrated by the quality policy. Also during the audit the active involvement of the management was clearly demonstrated

2.3 AB The control of the system implementing the Standard shall rest with a suitably competent person (the

Y The Quality manager is responsible for the implementation of the standard During the audit

Organisational structure

Part 4 – Detailed Audit Findings

ORGANISATION

shall rest with a suitably competent person (the designated manager). The designated manager shall be able to draw from expertise of suitably competent personnel either from within the company or from a third party. The designated manager shall be sufficiently senior to have direct operational responsibilities compatible with the priority stated in 2.1 by the management team.responsibilities compatible with the priority stated in 2.1 by the management team.

implementation of the standard. . During the audit it was sufficient demonstrated that she does have the requested knowledge regarding HACCP / general hygiene demands.

2.4 AB The designated manager shall have a designated suitably competent deputy to provide support and cover for absence.

Y During absence of the corporate quality manager her responsibilities will be covered according the descriptions in the "absence matrix".

2.5 AB A management review team consisting of relevant operations managers, including the designated manager, shall meet at a pre-determined frequency, to ensure the effective maintenance of this Standard. This team shall report compliance to the senior management team. The management review team shall, identify need for change and make recommendations on appropriate action. There shall be verifiable evidence of the proceedings of these meetings and the completion of any actions arising.

Y Seen management review may 2006 about 2005. The review of 2006 is being prepared. Review is carried out yearly.

2.6 AB The senior management team shall ensure that processes are in place to determine their customers' needs and expectations, clearly define their requirements and ensure that these requirements are fulfilled.

Y Euro Pool system has a procedure implemented to determine the needs and expectations of customers.

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Section

Leve


Motivation

33.03.0.0 »» The company shall keep recorded exemption to the

Standard under review. Production of satisfactory documentation at subsequent evaluations shall lead to continued acceptance of the exemptions

Y Seen cross reference chart dated 181006.

3.1.1 AB The company shall conduct a formal hazard analysis on production processes considering microbiological, foreign objects and chemical contamination, product integrity, legality and defects critical to consumer safety. The hazard analysis will be based on the range of uses of the packaging products promoted by the company.

Y Seen hazard analysis GOH 406 risk analysis and determination of CCP's and CP's. Euro Pool System does note have CCP's identified. Only CP's with relation to hygiene procedures are identified.

3.1.2 AB Upon a request in writing from a customer, the company shall conduct a supplementary hazard analysis specific to a use of a product of the company that is outside the promoted range os uses, and this shall be specific to that use and for that customer only.

NA There is no customer with a specific request on hazard analysis.

3.2 »» The Hazard analysis should incorporate the following steps:

Y See items listed further.

3 2 1 AB Established a precise validated plan of process flow(s) Y Seen flow chart GOH 404 version 2

A formal hazard and risk management system shall be in place to ensure that all hazards to HAZARD AND RISK MANAGEMENT SYSTEM

3.2.1 AB Established a precise, validated plan of process flow(s). Y Seen flow chart GOH 404 version 2.

3.2.2 AB Identify and record hazards associated with each process step and the controls required.

Y Seen hazard analysis GOH 406.

3.2.3 AB Assess the risk level for each hazard based on the likelihood of the occurrence and severity of outcome.

Y The risk assessment is based on likelihood and severity, resulting in four risk categories.

3.2.4 AB Identify those steps witch are critical to the process (critical process steps)

Y Euro Pool System does not have identified CCPs. Several Control points relating to hygiene have been established.

3.2.5 AB Decide which sections in 5, 6, and 7 are not applicable to the company using hazard analysis, and document the reasons for their exclusion.

Y Three items are declared not applicable and motivated through the hazard analysis.

3.2.6 AB Confirm the process control and monitoring procedures appropriate to the level of risk.

Y Validation procedure is available. Last validation on may 2006.

3.2.7 AB Establish the documentation for all the procedures and records necessary to maintain process control.

Y Documentation regarding HACCP system is available. Registration of the control of "CP's" regarding hygiene are seen during the audit.

3.2.8 AB The controls required by the hazard analysis shall be regularly reviewed, verified and validated to ensure they are still functioning efectively and to ensure that they are still up to date and reflect current knowledge.

Y Verification procedure is available. Seen verification of the HACCP system 2005. Verification of 2006 is being developed (as part of the management review).

3.3 AB Following the completion of this analysis, measures to monitor the critical process steps shall be implemented, maintained and reviewed.

NA Euro Pool Systems did not established CCP's. For CCP's an operational program is established.

3.4 AB The hazard analysis, and resulting procedures, shall have senior management commitment, and shall be implemented through the company's documented management systems.

Y During the audit is demonstrated that Euro Pool System did implement the HACCP system.

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Section

Leve


Motivation

3.5 AB Procedures relating to the monitoring of critical process steps shall be included in internal audits against the Standard (section 4.9).

Y Seen internal audit dated 121006 including e.g. . hygiene.

44.04.0.0 »» This shall include all Quality and Hygiene systems

throughout the organisation's site(s).Y The Quality management system is operational.

4.14.1.0 »» Senior management shall define the company's Quality

and Hygiene policy ensuring that it is documented, implemented, maintained and communicated to all employees.

Y The Quality mission statement and Quality policy, code GEN 120, is dated 110706.

4.1.1 AB The policy shall state the company's intention to meet its obligations to produce safe and legal products and its responsibility to its customers.

Y The policy does mention the intention of Euro Pool System to deliver safe and legal products.

4.1.2 AB The policy shall be understood by all supervisory and relevant personnel and has been implemented accordingly.

Y During interviews with the Depot manager and the technical service manager, it is demonstrated that the policy is understood.

4.1.3 AB The policy shall be communicated throughout the company and regularly reviewed.

Y The Quality policy is yearly explained towards personnel in a formalised meeting. Last explanation has been carried out in January 2007.

Technical Management Policy

TECHNICAL MANAGEMENT SYSTEMTechnical management system

4.24.2.0 »» The company shall have a manual that states its

commitment to Quality and Hygiene and has a scope which covers the requirements of this Standard.

Y The Quality manual describes how the requirements of the standard are being met.

4.2.1 AB A manual shall be maintained as an essential element of demonstrating compliance with this Standard.

Y Seen cross reference list GOH 413.

4.34.3.0 »» The company shall maintain records to demonstrate the

effective control of product safety, legality and quality.Y Euro Pool System does have a procedure for the

control of records.

4.3.1 AB Records shall be maintained in order to prove that technical and hygiene procedures have been followed.Records shall include as a minimum the following:- Records supporting product compliance- Training- Cleaning schedules and cleaning records- Instances of foreign-body contamination or other such breakdown of sysstems- Receipt and investigation of customer complaints- Internal auditing- Pest control reports and records- Maintance and engineering work records- Controle of non-production glass an brittle plastics- Controle of blades and sharp objects- Product recall (if applicable)- Non-conforminf goods records- Tracebility

Y During the audit Euro Pool System demonstrated the control of all required records.

Quality Manual

Record Keeping

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Section

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Motivation

4.44.4.0 »» The company shall establish and maintain documented

procedures to control all documents and data that relate to the requirements of this Standard.

Y Procedure "document control, describes the control of documents and data related to the standard.

4.4.1 AB All documents in use shall be properly authorised and be the current version.

Y Version control is electronically. After approval of the management team and/or HACCP team documents are published.

4.4.2 AB Documents shall be clearly legible, unambiguous and sufficiently detailed to enable their correct application by appropriate personnel and shall be readily accessible at all times.

Y During the audit no non conformities are established regarding the application of documents. Documents are available for the personnel.

4.4.3 AB All changes and amendments to documents critical to product safety, legality or quality system procedure and covered by the Standard's requirements shall be recorded.

Y During the audit no deviations regarding the control of documents are spotted. Seen electronically control of versions.

4.4.4 AB A procedure shall be in place to ensure that obsolete documentation is rescinded and, if appropriate, replaced with a revised version.

Y Obsolete documents are removed by the head of department .

4.4.5 AB Documentation and records shall be retained as defined within the company quality manual, and the period of record retention shall relate to the end use of the packaging.

Y The retain period of document is related to the shelf life of the packaging.

Documentation Control

4.54.5.0 »» The company shall ensure that appropriate

specifications exist for:- raw material (including product packaging) - intermediate product - finished product- any product or service which could affect the integrity of the finished product.

Y During the audit Euro Pool System showed that appropriate specifications exists.

4.5.1 AB Material specifications shall be maintained, which ensures that the components or articles that come into contact with food shall be suitable for their intended use.

Y Seen specifications model 610 drawing BEKU-27.12.06 and o4-BP-24-08; specification product data 610 and technical datasheet "folding and rigid reusable3 containers. Colours used according 1935/2004. Specifications are conform requirements.

4.5.2 AB Specifications shall be adequate, accurate and ensure compliance with relevant safety and legislative requirements.

Y Specification of " model 610 is accurate and sufficient.

4.5.3 AB Specifications shall, where appropriate, be formally agreed with relevant parties.

Y Above mentioned specification is formally approved.

4.5.4 AB Trademarks for application on packaging materials shall, where appropriate, be formally agreed with relevant parties.

NA Euro Pool System does not have trademarks on their crates.

4.5.5 AB The company shall operate a specification review procedure.

Y Seen PRO 339.

4.64.6.0 »» The company shall have effective control of incidents in

order to ensure that all potential risks to the quality and hygiene of products are controlled.

Y Euro Pool System did establish a procedure for incidents and recalls.

Specifications

Management of Incidents and Product Recalls

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Section

Leve


Motivation

4.6.1 AB The company shall provide written guidance to relevant staff regarding the type of event that would constitute an 'incident' and a documented incident reporting procedure shall be in place.

Y Seen PRO 337 130706 which includes guidance to relevant staff regarding incidents.

4.6.2 AB Procedures shall exist to ensure that customers are notified should an incident take place, which has potentially contaminated the product that has been delivered to the customer.

Y Procedure regarding the notification of customers where part of the recall procedure.

4.6.3 AB An effective documented "Product Recall" procedure shall be in place.

Y Seen PRO 337 130706.

4.6.4 AB Clear procedures for the control of out-of-specification, non-conforming materials, including rejection, acceptance by concession or, regarding an alternative use, shall be in place and understood by all authorised personnel.

Y A Procedure for the control of non conforming materials was implemented.

4.6.5 AB Corrective actions shall be implemented to avoid recurrence of the non-conformance and adequate documentation of the action taken.

Y Corrective actions are part of above mentioned procedure.

4.6.6 AB All non-conforming products shall be handled or disposed of according to the nature of the problem and/or specific requirements of the customer. The method of disposal and/or destruction of trademarked goods shall be agreed with the trademark holder.

Y During the audit is was demonstrated that non conforming products are rejected out of the process automatically and by the personnel. Trademarks are not relevant for Euro Pool System.

4.6.7 AB The company shall establish and maintain a documented procedure to ensure that a product that does not conform to requirements and could become a hazard is prevented from unintended use.

NA Abuse of crated is described within the HACCP system. Euro Pool System is not responsible for this abuse.

4.74.7.0 »» A system shall be in place to trace and follow materials

through all stages, including purchasing, processing, distribution and customers.

Y Euro Pool System does have a traceability system implemented. During the audit a traceability test was conducted on "M-bak '96-9". Results conform requirements.

4.7.1 AB The company shall ensure that its suppliers have appropriate traceability systems in place.

Y During audits at suppliers verification of tracking and tracing takes place.

4.7.2 AB An appropriate system shall be in place to ensure the customer can identify a product.

Y All crates are coded. This code relates towards the "production" of the crates at the supplier.

4.84.8.0 »» Procedures shall be in place to ensure effective control

of all operations throughout the process relating to critical product defects.

Y Euro Pool System could demonstrate the control of all critical activities (CP's). Euro Pool System does not have identified CCP's.

4.8.1 AB The company shall ensure that there are sufficient and appropriate process controls to prevent the occurrence of critical defects.

Y Euro Pool System does have sufficient and adequate process control implementer in order to prevent critical defects; e.g. non conforming crates (damaged) are automatically sorted out, cleaning process is automated with temperature and concentration control of detergents.

PROCESS Control

Traceability

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4.8.2 AB In order to prevent contamination, procedures shall be in place to appropriately segregate raw materials, work in progress and finished products.

Y Contamination risks are limited by the process flow as well as through the implemented procedures (e.g. cleaning procedures). Their is a clear distinction between the area with dirty crates and rinsed crates.

4.8.3 AB The company shall operate procedures that verify that the processes and equipment used are capable of consistently producing safe and legal products with the desired quality characteristics.

Y Euro Pool System does have procedures to confirm processes and equipment are capable of producing safe and legal products within the specified quality e.g. monitoring of bacteriological results on crates, visually inspection of crates according DIN 10522.

4.8.4 AB Measuring equipment used to monitor critical manufacturing process points and the product's compliance with relevant legal requirements, shall be calibrated and where possible, traceable to a recognised national standard.

Y There is a system for calibration of measuring equipment. Only the conductivity measure equipment is calibrated externally. Seen calibration report dated. 170107.

4.8.5 AB Raw material monitoring of all incoming materials for hygiene and technical criteria shall be specified. Inspection method, frequency and procedures shall be specified and documented. Suppliers of incoming materials, as appropriate, shall provide evidence of guarantees,

NA There is no control of incoming crates. They are dirty and will be washed during the process.

certifications/declarations of analysis or certificates of conformity.

4.8.6 AB Incoming goods shall, where appropriate, be subject to checks to ensure that the integrity of the materials is not compromised

NA There is no control of incoming crates. They are dirty and will be washed during the process.

4.8.7 AB Non-conforming materials or returned products shall be subject to inspection and positive release.

Y Together with the empty dirty crates also "non conforming food" is returned. This food is directly segregated and removed into a closed waste bin several times a day.

4.94.9.0 »» The company shall audit those systems, procedures

and operations that are a requirement of the Standard.Y During the audit Euro Pool System showed with

procedure PRO 326 that is has got an internal audit system.

4.9.1 AB Nominated adequately trained personnel shall carry out internal auditing at specified regular intervals.�A documented audit procedure shall be in place taht will include the frequency of internal audits. Frequency is based on hazard analysis. Where internal auditing has indicated that corrective action is required, action indicated and taken shall be documented.

Y Auditors are trained personnel. Audits are carried out by the

4.9.2 AB Internal auditors shall be carried out by competent auditors, who shall be independent of those personnel having direct responsibility for the activity being audited.

Y Auditors are independent and trained.

4.9.3 AB Deficiencies and details of non-conformances shall be notified to appropriate supervisory staff and corrective action implemented within a specified and appropriate time period.

Y Seen non conformity dated 220806, which was communicated towards the appropriate personnel. Seen corrective action.

Internal Audits

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Motivation

4.9.4 AB The management team shall review a summary of audits and ensure corrective action has been taken.

Y Internal audit results are part of the management review.

4.104.10.0 »» Monitoring, reviewing and taking action on complaints

shall be carried out as an essential part of an effective quality system to prevent re-occurrence.

Y During the audit Euro Pool System could show that she does have a system for the control of complaints.

4.10.1 AB All complaints from external sources shall be recorded, investigated and the results of the investigation recorded. The management team shall review an analysis of complaints to identify trends and the corrective action required.

Y Seen overview 2nd half of 2006. Seen results of investigation and corrective action on complaint dated 121006. Seen corrective action 1107016.

4.10.2 AB Corrective actions shall be formulated and approved by the designated manager who shall ensure that such action is fully implemented and is effective in preventing a recurrence

Y Above mentioned corrective actions are approved by authorised personnel.

4.114.11.0 »» The company shall operate procedures for approval and

monitoring of its suppliers. This shall include transport, warehousing and suppliers of materials and services to the company where appropriate to this Standard.

Y Euro Pool systems does have a purchase procedure which described the purchase of products and services. PRO 338.

Complaint Procedure

Supplier Monitoring

4.11.1 AB The company shall evaluate and select suppliers based on their ability to supply products in accordance with the company's requirements. Criteria for selection, evaluation and re-evaluation shall be established. Records of the results of evaluation and any necessary actions from the evaluation shall be maintained.

Y Above mentioned procedure mentions criteria for selection, evaluation an re-evaluation. During the audit supplier evaluations were demonstrated .

4.11.2 AB As part of hazard assessment, and where appropriate, suppliers of materials shall be certified to this Standard. Where this Standard is not implemented, the company shall be responsible for ensuring their suppliers are undertaking adequate technical practices which are maintained, audited and documented.

Y Euro Pool systems does not ask for BRCIoP standards for suppliers. Therefore suppliers are monitored (score card) in order to verify adequate technical practices.

4.124.12.0 »» Procedures shall be in place for the effective control of

sub-contractors.Y Seen PRO 311 selecting suppliers of depot and

washing services RF 2.1.003.

4.12.1 AB Where any production processes are subcontracted, the risks to the product from this process shall form part of the hazard analysis. On the basis of the hazard analysis it may be a requirement for the sub-contractor to be certificated under this Standard.

Y Seen actual overview of depots. Euro Pool System system uses a checklist to evaluate depots RF 2.1.019. HACCP / Hygiene is a part of this checklist.

4.12.2 AB Assessment of sub-contractors shall be undertaken by a competent person who shall ensure technical standards are appropriate, effectively audited and documented.

Y Every quarter depots are verified by the sales manager based on the depot checklist RF 2.1.019. Seen checklist depot "Valencia". Seen corrective action 1910063.

Sub-contracting of Production

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Section

Leve


Motivation

4.134.13.0 »» The company shall undertake or subcontract analyses

critical to product safety, legality and quality, using appropriate procedures and facilities

Y Seen microbiological evaluations Analysis are outsourced. Seen evaluations of the effectiveness of cleaning of crates. Visual control of 10 crates / day. Reference are available (DIN standards).

4.13.1 AB Procedures shall be in place to ensure reliability of test results.

NA Euro Pool System does not carry out themselves specific tests.

4.13.2 AB Personnel undertaking analyses shall be suitably qualified and/or trained and shall be competent to carry out the analyses required.

NA Euro Pool System does not carry out specific tests themselves .

4.13.3 AB Where the company undertakes or subcontracts analyses critical to product safety or legal compositional verification to a laboratory, the laboratory shall use agreed and documented test methods and sampling procedures.

Y The Analyses carried out at the external laboratory are accredited.

4.13.4 AB Subcontracted laboratories shall be independently accredited by a recognised or agreed competent body.

Y The external laboratory is accredited by an agreed competent body.

4.13.5 AB Quality checks shall be carried out to demonstrate that the product is within the tolerances laid down in the agreed product specification.

Y During the process appropriate quality controls are carried out in order to control products are conforming specification. Seen control of conductivity and control of temperature wash

Product Analysis

water.

55.15.1.0 »» All grounds within the site shall be finished and

maintained to an appropriate standard.Y The grounds are well maintained and finished.

5.1.1 AB The external areas shall be kept in good order and free from litter.

Y The grounds are well maintained and free of litter.

5.1.2 AB Where possible, a clean and unobstructed area shall be provided along the external walls of buildings used for production and/or storage.

Y A clean and unobstructed area is provided with the exception of a part where some plants are located. It is demonstrated by Euro Pool System that the " City" does not allow the removal

5.1.3 B Where eating of food is allowed outside during breaks, this shall be done in suitable designated areas with appropriate control of waste.

NA personnel is not allowed to eat outside.

5.1.4 AB External silos, pipe work or other access points for product and/or raw materials shall be appropriately sealed so as to prevent pest entry.

Y During the audit no non conformities are established regarding external silo's, pipe work etc.

5.1.5 AB Drains shall be properly trapped or otherwise protected so as to prevent entry of pests.

Y During the audit no deviations are spotted regarding drains.

5.1.6 AB Where natural drainage is inadequate, external drainage shall be installed.

Y During the audit no non conformities are seen regarding natural drainage.

5.1.7 B External traffic routes shall be suitably surfaced. Y External traffic routes are surfaced.

5.1.8 AB Where external storage of raw materials is necessary items shall be protected from contamination.

NA There is no external storage.

5.1.9 AB External storage of refuse shall be undertaken in designated areas.

NA There is no external storage.

Perimeter and GroundsFACTORY STANDARDS

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5.25.2.0 »» Premises and plant shall be designed, constructed and

maintained so as to control the risk of product contamination.

Y Premises and plant are such constructed to prevent the risk of contamination.

5.2.1 AB The process flow shall be such as to prevent cross-contamination of the product.

Y The process flow is able to prevent cross contamination. Dirty crates are completely separated from the clean crates area.

5.2.2 B Work in progress shall be kept in designated areas and adequately protected.

Y There are clear working procedures to prevent contamination.

5.2.3 B Sorting or other activities involving the direct handling of product shall take place in areas that have the same standards as production areas.

Y Sorting activities takes place in area's who are conform the hygiene standard.

5.2.4 AB Entry into production areas shall be via properly designated entry routes and access points.

Y There is no "free access" to the production areas.

5.35.3.0 »» The fabric of the site, buildings and facilities shall be

suitable for the intended purpose.Y Premises and plant are such constructed to

prevent the risk of contamination.

5.3.1 AB External walls shall be well maintained and of sound construction.

N External door at the back of the factory is broken. Door blocked with means of pallets (but this is not 100 % closed). Extra pest control measures implemented. Other door at the back was slightly damaged (small opening under the door which could allow mouse to enter the building)

Building Fabric

Layout and Product Flow

could allow mouse to enter the building).

5.3.2 AB Suspended ceilings shall be accessible for inspection and cleaning where required.

Y There was sufficient access to suspended ceilings.

5.3.3 AB Suitable and sufficient lighting shall be provided so as to permit effective inspection of product and effective cleaning.

Y The lighting was sufficient.

5.3.4 AB Walls, floors, ceilings and pipe work shall be maintained in good condition and shall be capable of being kept clean.

Y Walls, floors, ceilings and pipe work are constructed and in good order and are kept clean.

5.3.5 B Walls in production areas shall be suitably finished so as to permit thorough and effective cleaning.

Y Walls in production areas are constructed and maintained in such a way that effective cleaning can be carried out.

5.3.6 AB All internal drain openings shall be suitably trapped or otherwise protected against the entry of pests and odour.

Y During the audit no non conformities regarding internal drains are noticed.

5.3.7 AB Suitable and sufficient ventilation shall be provided. Y During the audit no exceeding condensation or dust forming was noticed.

5.45.4.0 »» Equipment shall be suitably designed and maintained

for the intended purpose and shall be used so as to minimise the risk of contamination of the product.

Y The equipments are fit for the intended purpose.

5.4.1 AB Equipment, including fixtures and fittings, shall be maintained in such condition as to minimise the risk of product contamination.

Y During the audit no non conformities where noticed.

5.4.2 AB Wooden desks, chairs, tables and other items shall be kept clean, in good condition and free from splinters or other sources of physical contamination.


Maintenance of Equipment

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5.4.3 B Wooden equipment including desks, chairs, tables, etc. shall be properly sealed so as to enable them to be effectively cleaned.

Y During the audit no wooden equipment without "sealing" noticed.

5.4.4 AB Where open notice boards are present, loose fastenings such as drawing pins and staples shall not be used.


5.4.5 B A planned preventative maintenance programme for plant and machinery shall be in place and shall address the risks of contamination.Compressed air that comes into contact with the product should be filtered to prevent any contamination.

N At the grease points "kantelbakken" no food grade lubricants are being used, although a risk of product contamination does exist at this point.

5.4.6 AB Temporary 'engineering and modifications' using adhesive tape, cardboard or similar materials shall not be permitted, except in emergencies.


5.4.7 AB When temporary 'modifications' are made these shall not become permanent and shall be properly monitored and controlled.

Y During the audit no temporary modifications were noticed.

5.4.8 AB Persons undertaking maintenance activities shall comply with site hygiene requirements, including those relating to protective clothing, hand washing and personal hygiene generally.

Y During the audit the technical employee new the hygiene requirements.

5 4 9 AB Contractors involved in maintenance or repair activities Y External technical personnel is under supervision5.4.9 AB Contractors involved in maintenance or repair activities shall be under the supervision of a nominated person.

Y External technical personnel is under supervision of the internal technical personnel.

5.4.10 AB On completion of any maintenance work, machinery and equipment shall be clean and free from contamination hazards.

Y During the audit no non conformities were noticed regarding cleaning of equipment after maintenance.

5.4.11 B Maintenance work shall be followed by a documented hygiene clearance procedure, which records that contamination hazards have been removed from machinery and equipment and/or controlled where there is a risk to contamination to the product.

Y Euro Pool System does have implemented a clearance procedure. Seen clearance registration dated 081106.

5.4.12 AB Where appropriate, lights shall be protected from breakage to minimise the risk of glass contamination.

Y Euro Pool System does have covered lights with plastic covers.

5.4.13 B All lights shall be fully enclosed with protective covering. Fluorescent tubes shall be protected by protective covering or shatter-proof coatings

Y Euro Pool System does have covered lights with plastic covers.

5.55.5.0 »» Housekeeping and Cleaning systems shall be in place,

which ensure that appropriate standards of hygiene are maintained and that risks of contamination are minimised.

Y Euro Pool Systems does have procedures and equipment operation for cleaning activities.

5.5.1 AB Good standards of housekeeping shall be maintained and include a "clean as you go" policy.


5.5.2 AB All internal surfaces of the buildings shall be kept free from excessive dust, dirt and cobwebs.


5.5.3 AB All internal surfaces of buildings shall be subject to documented scheduled cleaning.

Y There is a documented cleaning schedule for all departments. This includes internal surfaces.

Housekeeping and Cleaning

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5.5.4 AB Cleaning shall be undertaken in accordance with documented cleaning schedules, which covers all areas of the site with particular reference to production and storage areas.

Y There is a documented cleaning schedule for all departments.

5.5.5 AB Effective cleaning schedules shall be provided for all equipment.

Y There is a documented cleaning schedule for all equipment

5.5.6 AB Tools and other maintenance equipment shall be cleared away after use and stored in designated areas or lockers.

Y The used detergents are stored in a separate closed area.

5.5.7 AB Workstations shall be kept in good order and potential physical contamination hazards are properly controlled.

Y During the audit workstations where well maintained.

5.5.8 B Workstations shall be provided with suitable storage for stationery and loose items such as pens etc. Items such as paper clips, staples etc shall not to be used.

Y On workstations storage facility were available for loose items.

5.5.9 AB Records shall be kept to ensure the cleaning operations are carried out in accordance with the cleaning schedules.

Y Cleaning records were evaluated during the audit. Seen cleaning registration; per department the amount of hours is recorded which shows a significant amount of hours spend on cleaning. In practice the hygiene standard of the plant is very high.

5 5 10 AB Cleaning chemicals shall be fit for purpose suitably N Close to the palletiser a white plastic bottle5.5.10 AB Cleaning chemicals shall be fit for purpose, suitably labelled, secured in closed containers and used in accordance with manufacturers' instructions.

N Close to the palletiser a white plastic bottle without label detected. In the first floor in the "storage area" a orange extract stored for the removal of labels. In the "dirty crate area" a red box with brush detected. the content of this box is not clear.

5.5.11 AB Materials and equipment used for cleaning toilets shall be segregated from those used elsewhere.

Y Materials for the cleaning of toilets is stored separately.

5.65.6.0 »» Suitable facilities shall be provided for the storage and

disposal of process and other waste.Y Euro Pool System does have an operational

system for the control of waste.

5.6.1 AB Suitable and sufficient refuse and waste containers shall be provided and thet shall be emptied at appropriate frequencies and maintained in an adequately clean condition.

Y Waste was sufficiently controlled.

5.6.2 AB Where agreed with the customer, suitable and sufficient containers shall be provided for collection of substandard trademarked materials. Where agreed such materials shall be rendered unusable through a destructive process. All materials disposed of shall be recorded.

NA Euro Pool Systems does not have trademarks on their crates.

5.6.3 AB If substandard trademarked materials are transferred to a third party, that third party shall be in the business of appropriate waste disposal and shall be provide records of material destruction.

NA Euro Pool Systems does not have trademarks on their crates.

5.6.4 AB Where appropriate, the third-party waste disposal contractor shall be licensed

Y Waste removal is carried out by an licensed contractor.

Waste and Waste Disposal

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66.16.1.0 »» All practicable steps shall be taken to identify, avoid,

eliminate or minimise the risk of foreign-body contamination.

Y There's a procedure implemented to prevent product contamination.

6.1.1 AB Training shall be given to all relevant staff in the avoidance and detection of foreign bodies.

Y During the audit Euro Pool System showed that relevant training has been given.

6.1.2 AB A written policy and documented controls shall be in place for:- non-production glass- brittle plastics- all materials used in the construction, fixture and fittings of the production area which could be confused with packaging materials

Y A glass procedure was available which included inspection of glass, hard plastic and materials that could be confused with packaging materials.

6.1.3 AB There shall be no unnecessary glass or brittle plastic which may pose a risk of contamination.

Y During the audit no unnecessary glass hard plastic has been observed.

6.1.4 B All non-production glass or brittle plastics shall be controlled and logged. All necessary non-production glass and brittle plastics are recorded on a register and checked for damage at an appropriate frequency. The register shall be kept up to date as necessary.

Y Seen instruction glass and registration of glass inspections No non conformities observed during the audit.

Foreign Body Control.CONTAMINATION CONTROL

6.1.5 B Where damage occurs that poses a risk of contamination, a responsible person shall be placed in charge of the clean-up operation and ensures that no other area is allowed to become contaminated due the breakage.

Y Euro Pool System has organised that after an incident cleaning procedure are followed in order to prevent further spread of contamination.

6.1.6 AB Any product that has become contaminated shall be segregated and disposed of. A relevant quarantine procedure applies after any incident.

Y A "on hold" procedure for contaminated product could be shown.

6.1.7 AB All breakages that pose risk of product contamination shall be recorded in an incident report.

Y Until now no incidents with glass have occurred.

6.1.8 AB There shall be a documented policy for the control of the use of 'sharps'.

Y There is a procedure for the control of "sharps".

6.1.9 B All sharp cutting instruments shall be further controlled as follows:a) All sharp knives, blades, and instruments used in the manufacture of packaging materials shall be suitably controlled both into and out of the factory for use and disposed of in a sealed container when no longer usable.b) No sharp object or loose tools shall be left on machinery or equipment.

Y All sharp cutting instruments are being effective controlled to prevent contamination.

6.1.10 AB Snap-off blade knives shall not be used. Y Snap-off blade knives are not used.

6.26.2.0 »» Controls shall be in place to prevent contamination from

any chemical or biological hazard.Y There's a procedure implemented to prevent

product contamination.

6.2.1 AB Chemicals including cleaning materials, lubricants and adhesives shall be so controlled as to prevent their contamination of the product.

Y The facilities for the storage of chemicals are adequate.

Chemical and Biological Control

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6.2.2 B Where aseptic controls are required, then a complete range of environmental controls (identified through hazard analysis) may be necessary to prevent microbiological contamination.

NA Aseptic controls are not required.

6.36.3.0 »» Controls shall be in place to prevent actual or potential

infestation and the resulting contamination from rodents, flying and crawling insects, birds and other pests.

Y Euro Pool System does have an operational system for the control of pests.

6.3.1 AB A formalised preventive pest control programme shall be maintained at manufacturing and storage facilities.

Y The pest control program does in include all production and storage areas.

6.3.2 AB Effective precautions shall be in place to prevent pests entering the premises.


6.3.3 AB Unless competent in-house expertise exists, a competent pest control company shall be contracted to carry out pest control systems. Written procedures and activity documentation shall be maintained.

Y A contract with a specialised pest control company could be shown.

6.3.4 AB Controls shall be documented on baiting points and flying insect control devices. Flying insect control shall not be positioned in areas where electrocuted insects

Y A detailed report of the pest control inspection could be shown. Last inspection conducted January 2007.

Pest Control

pcan contaminate packaging materials.

y

6.3.5 AB In the event of infestation, immediate action shall be taken in accordance with the procedures to eliminate the hazard and the need for 'quarantine and qualify' actions should be considered.

Y During the audit Euro Pool Systems showed that corrective actions were taken. Seen corrective actions regarding mouse activity in one corner of the factory.

6.3.6 AB The building shall be suitably proofed against the entry of all pests including the ducts and cable entry points.


6.46.4.0 »» The transport, storage and distribution of raw materials

and finished products shall be undertaken in such a way as to minimise the risk of contamination.

Y Euro Pool System does have an operational system to prevent contamination during transport, storage and distribution.

6.4.1 AB All finished products shall be protected from contamination during transit and storage by appropriate external packaging.


6.4.2 B Materials transferred between premises during production shall be similarly protected.

NA There are no materials transferred between premises.

6.4.3 B All pallets should be checked and unacceptable pallets discarded. Wooden pallets, which come into direct contact with finished products or raw materials shall not be allowed to contaminate the product.

Y Euro Pool System does have procedures for the selection of unacceptable pallets. This is done automatically. Broken pallets are taken out of the system electronically / automatically.

6.4.4 AB Contracted transport, storage and distribution shall be undertaken in such a way as to prevent raw materials or product being exposed to the risk of contamination, including taint or odour.

Y A procedure for the control of contracted transport, was operational.

Transport, Storage and Distribution

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6.4.5 B Contracted transport, storage and distribution shall comply with written standards/specifications, which ensure that product is not exposed to any risk of contamination, including taint or odour.

Y Seen signed contracts 171006.

6.4.6 AB Vehicle drivers shall comply with site rules. Y A random check during the audit showed no non conformities.

6.4.7 AB All vehicles used for deliveries ashall be kept clean and in such a condition as to minimise the risk of product contamination.

Y The inspected vehicles were fit for use.

6.4.8 B All company-owned vehicles used for deliveries shall be included in the documented cleaning schedules.

NA Euro Pool System does not have company-owned vehicles.

6.4.9 All delivery vehicles shall be subject to a hygiene checking procedure before being loaded.

Y A random check during the audit showed no non conformities.

6.4.10 AB Storage including off-site storage shall be controlled to ensure no cross contamination from any other material can occur. Where off-site storage is used the same requirements apply as for on-site storage.

NA Euro Pool System does not have off-site storage

77.17.1.0 »» The company shall ensure that access and movement Y Euro Pool System did implement procedures to

Access and Movement of PersonnelPERSONNEL (Raw material handling, processing, preparation,

7.1.0 »» The company shall ensure that access and movement of personnel, visitors and contractors shall not compromise standards or product safety and ensure compliance to the requirements of this section.

Y Euro Pool System did implement procedures to prevent contamination by personnel, visitors and contractors.

7.1.1 AB All personnel shall enter any part of the site through designated entrances.

Y The personnel enters the site and building via designated entrances.

7.1.2 AB Security shall be so maintained as to prevent the entry of unauthorised persons to the premises.

Y There is no free entrance to site and buildings

7.1.3 AB If it is necessary to allow access between non-production areas, personnel shall use designated walkways provided there is adequate segregation from materials.

NA There is only one building.

7.1.4 All facilities shall be designed and positioned so that movement of personnel is by simple, logical routes.

Y The lay out of the building / process is to prevent contamination.

7.1.5 AB Contractors and visitors shall be made aware of all hygiene procedures for the premises and made especially aware of the requirements of the areas they are visiting.

N External contractors do not sign in at the entrance and therefore do not receive the correct version of the hygiene rules.

7.27.2.0 »» Staff facilities shall be designed and operated so as to

minimise the risk of product contamination.Y Euro Pool System does have designed staff

facilities in such a matter as to prevent the risk of product contamination.

7.2.1 AB Lockers shall be provided for all personnel who work in raw-material handling, processing, preparation, packing and storage areas.

Y Suitable locker rooms are available.

7.2.2 B Locker rooms shall be accessed without the need to enter production areas unless appropriately segregated walkways are in place.

Y Locker rooms gives direct access to the production areas.

Locker Rooms

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7.2.3 AB Eating, drinking and smoking shall not be allowed in locker rooms.

Y Eating, smoking and drinking in locker rooms is not allowed.

7.2.4 AB Facilities for visitors and contractors shall be such as to enable compliance with the company's hygiene policy.

Y The facilities for visitors and contractors are adequate.

7.2.5 B Company-issued protective clothing and personal clothing shall not be stored in the same locker or locker compartment.

Y Company clothing and personnel clothing are segregated sufficiently.

7.37.3.0 »» Toilets and Hand washing facilities shall be adequate

and be maintained in a clean and hygienic condition.Y The toilet at the entrance was in the beginning of

the morning very dirty. Re-checked at 12:00 h. The toilet was cleaned and complied with the demands.

7.3.1 AB Toilets shall be provided with hand-washing facilities comprising basins with water available at a suitable temperature.

Y Euro Pool System has provided for adequate hand washing facilities.

7.3.2 AB Advisory signs shall be in place to prompt hand washing. Adequate facilities for hand drying shall be provided.

Y Advisory signs are in place at the hand washing facilities.

7.3.3 AB All personnel, visitors and contractors shall wash their hands prior to entering production areas, after using the toilet, eating, smoking, drinking (unless drinking only water in accordance with the conditions set out in


Toilets and Hand-washing Facilities

water in accordance with the conditions set out in section 7.4) and whenever otherwise necessary.

7.3.4 B Hand washing shall be carried out by all personnel when entering a production area.

NA Hand washing when entering the production area is not necessary. This is based on a risk assessment.

7.3.5 B Hand-washing facilities shall be provided at the entrance to production areas, outside localised eating and drinking facilities, and elsewhere so that employees have ready access during the course of their work.

Y Euro Pool System has provided for an adequate hand wash facility at the entrance of the production area (at the toilets and the locker rooms).

7.47.4.0 »» Rest and break facilities shall be of a suitable standard

to promote good hygiene practices.Y During the audit the Rest and break facilities were

under control.

7.4.1 AB All equipment and surfaces shall be clean, well maintained and of suitable construction.�Eating (including the eating of confectionery and chewing of gum or tobacco), drinking, and smoking shall not be allowed in the production or packing areas. If it is impractical for personnel to leave their work area, local controlled facilities (such as a fully walled area with hand-washing facilities if appropriate) shall be provided.


7.4.2 B Employers shall be provide facilities for adequate storage of food and drink, including that brought from home. Drinking of water from purpose-made dispensers and/or by using only disposable conical cups may be allowed provided it is confined to a designated area away from equipment.


Facilities for Eating, Drinking and the Use of Tobacco Products

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7.4.3 AB Designated, enclosed and controlled smoking areas shall be isolated from production areas to an extent that ensures smoke cannot reach the product. Sufficient extraction to the exterior of the building shall be ensured. Adequate arrangements for dealing with smokers' waste shall also be provided at smoking facilities, both inside buildings and at exterior locations. Facilities shall be available, with adequate reminders, for hand washing after smoking.

Y Smoking is organised in the general hygiene rules. Were smoking is prohibited, extraction to the exterior is available.

7.4.4 AB Canteen and food waste shall be stored in suitably lined and lidded containers.


7.4.5 AB All food brought into manufacturing premises shall be held in a controlled area which is kept in a clean and hygienic state.

Y There are adequate storage faculties for food for the personnel.

7.57.5.0 »» Illnesses or injuries likely to adversely affect product

safety shall be monitored and controlled.Y Euro Pool System has procedures to prevent

product contamination by illness of injuries.

7.5.1 AB Personnel shall report if they are suffering from, or have been in contact with any disease likely to be transmitted through food, from infected wounds, skin complaints or diarrhoea Employees and visitors suffering from any of

Y The hygiene rules include mentioning of diseases.

Personal Health

diarrhoea. Employees and visitors suffering from any of the above shall be excluded from work involving contact with food packaging as long as the symptoms persist.

7.5.2 B Visitors and contractors shall be required to fill in a health questionnaire prior to being allowed into production areas covered within the Standard.

Y During the audit the auditor was asked to fill in a health questionnaire.

7.5.3 AB Minor injuries such as cuts shall be covered with waterproof blue self-adhesive plasters incorporating a metal detectable strip.

Y Euro Pool Systems gives detectable blue plasters. They are stored at the office of the manager of the depot.

7.67.6.0 »» The company shall have in place an effective policy for

the control of jewellery and personal items.Y There is a policy regarding jewellery. Seen

"hygiene rules Zellik" 2.2.023iw.

7.6.1 AB Jewellery and wristwatches shall not be worn, unless for ethnic, medical or religious reasons in which case these are one piece or appropriately controlled to minimise the risk of contamination.�Badges, pendants, brooches, jewellery with stones or gems, or jewellery and other adornments liable to breakage or contamination shall not be worn.

Y During the audit no non conformities were noticed.

7.6.2 B Wristwatches shall not be worn. Y During the audit no non conformities were noticed.

7.6.3 AB Company policy shall clearly specify the type of jewellery allowed to be worn and the controls to be in place to minimise the risk of contamination.

Y Company hygiene rules does specify the type of jewellery allowed.

7.6.4 AB Rings and studs in exposed parts of the body such as noses and eyebrows shall not be worn.

Y Rings and studs are not allowed.

Jewellery and Personal Items

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7.6.5 AB Procedures shall be in place to control the use of personal medicines to minimise the risk of contamination.

Y The use of medicines is organised in the company hygiene rules.

7.6.6 B False nails and nail varnish shall not be used. Y False nails and nail varnish is not allowed.

7.77.7.0 »» Appropriate protective clothing shall be worn to

minimise the risk of product contamination.Y During the audit protective clothing was worn by

personnel and contractors.

7.7.1 AB Appropriate protective clothing that cannot contaminate the product shall be worn.

Y During the audit no non conformities were noticed regarding clothing.

7.7.2 B The clothing shall have no external pockets on the upper body garments, and be fitted with press-studs, not sewn-on buttons. Changes of such clothing shall be available at all times as required. Where appropriate, snoods for beards and moustaches shall be worn. Protective clothing worn in production areas shall provide adequate covering of scalp hair and upper torso. These garments shall not be worn to and from home.

Y During the audit no non conformities were noticed regarding clothing.

7.7.3 AB Self-care shall be permitted provided adequate controls and appropriate guidelines are in place.

Y Euro Pool System did establish rules regarding self care.

7.7.4 B Controlled laundering of clothing shall be carried out. A system shall be in place to ensure the effectiveness of l d i

NA Based on risk assessment Euro Pool System concluded that controlled laundering is not

f th t f d t Aft i i /

Protective Clothing

laundering process. necessary for the type of products. After rinsing / cleaning of crates personnel does not touch the crates anymore (fully automated process).

7.7.5 AB Clean and dirty clothing shall be segregated and controlled to prevent cross contamination.

Y Clean and dirty clothing is segregated.

7.87.8.0 »» The company shall ensure that all employees are

adequately trained, instructed and supervised commensurate with their activity.

Y Euro Pool System could demonstrate that personnel is trained, instructed adequately.

7.8.1 AB All personnel including temporary personnel and contractors shall be appropriately trained prior to commencing work and adequately supervised throughout the working period. Induction training shall include the company hygiene rules.

Y During the audit no non conformities regarding training / instruction of temporary personnel and contractors was noticed.

7.8.2 B All personnel shall be provided with formal basic hygiene training commensurate with their activity, and where appropriate further in-depth training shall take place.

Y A random check during the audit showed that all operators did received a basic hygiene instruction in January 2007.

7.8.3 AB Records of training shall be kept for all current and recent employees.

Y Records of training are available. Seen training records of basic hygiene training and personnel safety training of January 2007.

7.8.4 AB A programme of refresher hygiene training shall be in place.

Y There was a programme of refresher hygiene training in place.

Training Raw-materials Handling, Preparation, Processing, Packing and Storage

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Documents

Transcript of BRC-IoP-EN