21 Sep My Food Control Plan for MPI food safety
The My Food Plan (MFP) has been evaluated to ensure compliance with the Food Act 2014 (including the requirement to identify and control all hazards), Food Regulations 2015, and all applicable Food Notices. An additional Hazard Analysis and Critical Control Point (HACCP) plan is not required as the ‘Do’ and ‘Show’ sections of the plan adequately meet the requirements of sections 42 (g) and (h) of the Act.
As with all Food Act templates, operators will need to tailor the plan to their operation. They will need to fill in the blanks, choose between options, keep records and be able to demonstrate
their knowledge of the plan and their responsibilities during verification.
All MFP businesses will receive the ‘Knowing your processes and controls’ card. This card requires operators to:
• Identify their ingredients and inputs for each product;
• Write down their process for making each product;
• Identify the hazards that will need to be controlled when making each product;
• Identify and/or set regulatory limits, and follow their documented process every time to ensure safe and suitable food is produced.
Verifiers will be able to ask to walk through the business and have the operator identify the different processes that are used in their business, ask about process control steps and the types
of hazards that have been identified and are being controlled.
Verifiers can also ask how operators meet the regulatory requirements from the Australia New Zealand Food Standards Code, and for a record of the processes and limits operators have identified.
1. Identify their ingredients and inputs for each product;
Each of your food suppliers should be registered under the correct risk based measure. You can request a copy of their registration certificate. Alternatively, the Public Register of Food Control Plans and National Programmes can be viewed to check whether their registration is current.
The register is helpful in providing a Search Criteria box. An address, or just a street name can be input and the register will list all food businesses in the street. Useful if the exact address is not known. If a business has supplied you their initial registration certificate, the registration ID can be entered to check its currency. The register also lists their scope of operations and trading operations.
Occasionally a registration may be expired, and in these cases the supplier should be contacted. The registration authority will have sent the supplier a registration renewal reminder, and this needs to be processed. If a supplier allows their registration to lapse, they will need to begin the registration process again from the start, including full payment.
Before purchasing a raw material ingredient you should request a raw material specification from the supplier. This will provide important information about the content of the food product. You are required to know what is in the ingredients that you are using so that your product specification is accurate, and so that your labelling can be accurately produced. It is critical that food allergens are identified. If allergens are not declared then the food will cause an allergic reaction in some consumers and a food recall will result. Your own customers may require this information either by their own supplier audit of your business, or when you are tendering for distribution via a supermarket. And you will need to demonstrate that you know what is in your food product by showing your verifier this evidence.
The most useful method for gathering the ingredients and inputs information is by developing a finished product specification. The specification template can often be obtained from your wholesale customer or distributor. The wholesale customer will often have a compliance management system and will supply various forms and Codes of Practice.
A product specification has content including:
– Product Name and description
– Intended use
– Shelf Life
– Storage Conditions
– Directions for Use
– Dietary suitability
– Nutrition Information
– Microbiological, Physical and Chemical Properties
– Regulatory and label compliance
– Manufacturer details
– Method of preservation
– GMO Status
– Country of Origin
– Document control including issue date
– Method of traceability
The product specifications are very important in communicating finished product attributes with not only your customer but with your own food handlers and production personnel. They will form the core of a documented food safety plan.
Food safety documentation is often based around the principles of HACCP (Hazard Analysis: Critical Control Points). Prior to developing and applying HACCP, the food business needs to have appropriate programmes and systems in place to manage general hazards from inputs and the environment.
From the Codex Alimentarius:
A full description of the product should be drawn up, including relevant safety information such as: composition, physical/chemical structure (including Aw, pH, etc), microcidal/static treatments (heat treatment, freezing, brining, smoking, etc), packaging, durability and storage conditions and method of distribution. Within businesses with multiple products, for example, catering operations, it may be effective to group products with similar characteristics or processing steps, for the purpose of development of the HACCP plan.
2. Write down your process for making each product;
This is best presented by a list of all process steps accompanied by a description of the actions taken at each step. This may be in the form of a flow chart. The process step descriptions may be listed separately. Staff can be involved at this development stage so that all information is captured and it is accurate.