CODE OF PRACTICE FOR CONDUCTING QUALITY...Associated British Foods CODE OF PRACTICE FOR SUPPLIERS OF FOOD PRODUCTS, INGREDIENTS, DRINK, AND PACKAGING Incorporating the Code of Conduct

Associated British Foods

CODE OF PRACTICE FOR SUPPLIERS OF FOOD PRODUCTS,

INGREDIENTS, DRINK, AND PACKAGING

Incorporating the Code of Conduct of Associated British Foods plc

March 2014

European Legislation Version

March 2015

Issued on behalf of ABF’s UK Vendor Assurance Working Group for Global use

ABF CODE OF PRACTICE FOR SUPPLIERS OF FOOD PRODUCTS, INGREDIENTS, DRINK, AND PACKAGING incorporating the Code of Conduct of Associated British Foods plc

Issued March 2015 Page 2 of 47

Contents

Acknowledgement 1. Introduction & Scope

2. Code of Practice

• Business Management System

• Hazard Analysis Critical Control Point (HACCP)

• Raw Material Supplier Approval

• Raw Material Receipt, Storage and Handling

• Process Control

• Quality Assurance

• Laboratory Testing

• Finished Product Assessment, Handling and Despatch

• Contamination Prevention

• Site Construction and Maintenance

• Plant Hygiene

• Personnel and Training

• Good Manufacturing Practice

• Site Catering

• Pest Control

• Ethical Trading and Environment Policy • Minimum Security Standards

• ABF Code of Conduct

3. Appendix 1 – Legislation & References

4. Appendix 2 – Allergens

5. Appendix 3– Maize & Soya Derivatives

6. Appendix 4 – Rigid Packaging Checks



Service Administration

ABF Suppliers This Code of Practice will be distributed to suppliers to assist supplier approval questionnaire completion and as a component of the initial site assessment and also following each substantial revision.

Additional electronic copies of this Code of Practice may be obtained, free of charge, by contacting:- Food Safety, Allied Technical Centre, Vanwall Road, Maidenhead, Berkshire, SL6 4UF. Tel: +44 (0)1628 507300. Fax: +44 (0)1628 507390. Email: [email protected] ABF Sites Only ABF staff may obtain additional copies of this Code of Practice via the ABF Intranet or directly from the Food Law Programme VAWG Home Page. Latest sector Specific Information regarding contaminants may be found via the ABF Intranet or directly from the Food Law Programme Home Page.

mailto:[email protected]

https://www.abfintranet.com/abfintranet/abfintranet2010.nsf/main?readform

https://www.abfintranet.com/compliance/foodlaw.nsf/archive?openview&title=Codes%20of%20Practice&type=cat&cat=Vendor%20Assurance&cat2=Codes%20of%20Practice&count=y

https://www.abfintranet.com/abfintranet/abfintranet2010.nsf/main?readform

https://www.abfintranet.com/compliance/foodlaw.nsf/archive?openview&title=On-line%20databases&type=cat&cat=Current%20Topics&cat2=On-line%20databases&count=y



Introduction & Scope

This Code of Practice outlines the expected standards of product safety, quality and integrity expected of all sites (including co-packing operations) supplying or intending to supply food products, materials, ingredients, packaging or associated services to Associated British Foods Operating Divisions.

The principles outlined in this Code of Practice apply equally to food products, raw materials, ingredients, and packaging or associated services to Associated British Foods UK’s Divisions. ABF staff undertaking vendor assessments may utilise their judgement to determine the applicability or otherwise of the clauses in this standard. For suppliers of packaging (Flexible film e.g. LLDPE; Converted flexible film; PE thermoformed e.g. PVC, APET; Oxygen barrier laminates for frozen or thermal treatments; Blow and Injection moulding of mono-layer & barrier plastics; Paper/Card Packaging and fibre board; Glass and Metal) additional guidance pertinent to the expected QA activities is detailed in Appendix 4.

This Code of Practice is subject to annual review, but may, if required, be updated in the interim following significant changes in corporate requirements, legislation, and or Retailer, Certification or Accreditation Body Codes of Practice.

As a part of the contract to supply, it is expected that all suppliers adhere to the appropriate sections of this Code of Practice, which are based upon general principles of Good Manufacturing Practice and Industry Standard Codes; for example the current issues of IFST GMP guidelines, the BRC Global Standard – Food, the BRC Agents & Brokers Standard and the BRC Storage and Distribution Standard.

This document may also be supplemented by a number of sector specific guidance Codes of Practice which relate to specific industry sectors or material types. Where appropriate these codes will be supplied as required.

Details of reference sources are appended.

All applicable elements of the standard should be reviewed and will be included in any ABF assessment.

ABF Companies, who currently subscribe to the requirements of this Code of Practice, are: -

AB World Foods

Allied Bakeries

Allied Mills

The Jordans, Dorset Cereals & Ryvita Co.

Allied Technical Centre

British Sugar

AB Mauri

Westmill Foods

Silver Spoon

Speedibake

Twinings-Ovo



Code of Practice Terminology The following terms are used to reflect the level of food safety risk control associated with the stated requirement:

Must – a legal requirement, high food safety risk, or Corporate and Social Responsibility requirement. Dependent on the degree of non-compliance, a critical or major rating would be assigned.

Should – A medium food safety risk. Dependent on the degree of non-compliance, a major or minor rating would be assigned.

May – A low food safety risk or best practice, if non-compliant, a minor rating would be assigned.

Definition of Non-Compliances Non-compliances will be at three different levels, depending on how serious their potential effect on food safety or legality:

A Critical rating would be assigned for the following non-compliances:-

• Evidence that legal requirements are not being met.

• Evidence of serious food safety issues (e.g. actual product contamination, adulteration, imminent risk of product contamination, under-processing of high-risk foods, likelihood of cross-contamination of high-risk foods) that would render the product unsafe.

• Failure to meet customer mandatory requirements for product protection (e.g. where sieving of ingredients or metal detection of products are required, or where nut-free status is required).

• Absence of HACCP and/or Business Management System.

• Evidence that Corporate and Social Responsibility requirements are not being met.

A Major rating would be assigned for the following non-compliances:-

• Failure to operate systemic requirements to demonstrate control of food safety, quality and legality (e.g. present but badly flawed HACCP, glass control regimes, process control, product protection, personal hygiene policies, nut control policies, internal audits/reviews, product testing), Corporate and Social Responsibility, food fraud or authenticity.

A Minor rating would be assigned for the following non-compliances:-

• Flaws, that do not directly threaten product integrity, found in existing formal systems and practices, which are otherwise considered acceptable.

• Minor flaws in Good Manufacturing Practices (GMPs).

Assessment Notification The first assessment will be scheduled to take place on a mutually convenient date, with due consideration given to the amount of work to be done to meet the requirements of the Code of Practice. Subsequent surveillance either by audit, questionnaire or certification monitoring will be carried out at intervals, determined by an assessment of risk and supplier performance monitoring. The assessment will typically take one day, and will consist of the following elements:

• Opening meeting.



• Site tour.

• Review of Business Management System, Procedures and Records.

• Compilation by the Auditor of non-compliances noted.

• Closing Meeting.

During the assessment, notes will be made of the site’s compliance with the various aspects of this Code of Practice. These notes will form the basis for the assessment report. The Auditor will evaluate the nature, significance and implication of any issues identified.

At the closing meeting, the Auditor will present the findings, and will discuss all non-compliances that have been identified and advise the site of their assigned assessment rating; ideally, leaving the auditee of the list of non-compliances recorded, signed by both parties.

Assessment Outcome The site will be assigned one of the following assessment ratings on the day of the assessment:-

• Approved – No Critical, Major or Minor non-compliances noted or Minor non-compliances only noted.

• Provisionally Approved – No Critical non-compliances noted. Easily rectifiable Major and Minor non-compliances noted.

• Provisionally Unapproved – Rectifiable Critical and or Major Non-compliances noted.

• Unsatisfactory – Critical and or Major non-compliance(s) noted.

The site should respond to all non-compliances raised within twenty working days of the assessment/assessment report if not completed on the day of the assessment. Submitting an action plan where any non-conformances were raised. Objective evidence indicating the complete closure of any Critical or Major issues should also be submitted with the plan e.g. photographs, completed reviewed record sheets, reviewed procedures or training records.

Sites receiving an Unsatisfactory or Provisionally Unapproved rating will be advised, in writing, when or if they are to be reassessed and of any limitations placed on the supply of goods, pending confirmation of rectification of the non-compliances noted.

Upon receipt of the corrective action plan, the auditor who undertook the assessment, will review the supplied documentation and determine if any alteration to the assessment rating originally assigned is required. Failure to supply an action plan, within a reasonable timescale, may result in an Unsatisfactory rating being assigned to the site.

Questionnaires There are some instances (e.g. for reasons of confidentiality, low volume, low risk) where a site will receive a questionnaire instead of a physical site assessment; the need for this will be determined by the ABF based company leading the supplier approval concerned. Where an ABF company approves a supplier solely by self-assessment questionnaire this must be refreshed or renewed at least each three years. A number of questionnaire formats have been developed that are specifically related to different types of supplier. Those supplier sites that are sent a questionnaire will need to make reference to this document when answering the questions. All questionnaires will be reviewed by the originator who is also responsible for ensuring all of the relevant information is provided and that all relevant questions are answered.



The following are the potential outcomes, following a questionnaire review:

• Approved by Questionnaire

• Audit Required

• Unapproved

Failure to reply to a questionnaire within a reasonable timescale may result in an Unapproved rating being given to the site.



1 Business Management System

1.1 Suppliers of food products must be able to demonstrate that they are registered with the local, regional or national authority as a food company.

1.2 ABF Companies supplied must be made aware of any enforcement/improvement or prohibition notices served on the Supplier within the last 3 years.

1.3 The Supplier should have a Business or Quality Management System appropriate to the size and complexity of the organisation and the processes undertaken on site. This must be integrated with the other safety critical systems on site e.g. HACCP, pre-requisite monitoring, positive release and traceability. The effectiveness of this system should be evident from retained records of production and other processes undertaken.

1.4 A Quality Manual should be maintained which contains up-to-date information relating to the Business Management System (BMS) including:-

• Quality Policy,

• Organisational chart,

• Job descriptions detailing clear designation of responsibility for Food Safety, Legislation, Quality, Health & Safety, and Environment.

• Work instructions relating to achieving the requirements of the BMS and a description of how the achievement of these responsibilities is monitored,

• How key responsibilities would be covered in the event of personnel absence,

• This manual should be made available to key employees.

1.5 Accreditation to the ISO Business Management series and/or GFSI recognised standards is highly desirable and for some ABF companies a pre-requisite for the supply of goods. The BMS should, however, cover all factors related to product safety, legality, and quality and customer requirements and be subject to a formal regime of assessment and review.

1.6 Membership of the Supplier Ethical Data Exchange (SEDEX)/or ABF company specified alternative and compliance with the ABF Code of Conduct is pre-requisite requirement for the supply of goods to ABF. SEDEX website data completion shall be reviewed during supplier assessments.

1.7 Internal Audits

• Internal audits should be carried out by appropriately trained, competent and experienced personnel who are ideally independent of the area being audited; these shall be scheduled at a frequency determined by risk assessment of the activities to be assessed and scheduled throughout the year. The audit programme shall be fully implemented, with core food safety systems e.g. HACCP and Pre-requisite programmes covered at least annually.

• Records of internal quality system audits should incorporate appropriate closing out of non-compliances, and communication of agreed corrective actions to relevant personnel. Information relating to the support of and monitoring of the BMS should be available to relevant personnel at all times. Review of internal audit reports should support the Supplier’s commitment to continuous improvement.

1.8 The Supplier should have formally appointed personnel who have ultimate responsibility for maintaining the Quality System and ensuring compliance with legislation. These personnel should be able to demonstrate their ability to access up-to-date information



relating to legislative, food safety, scientific and technical advances in the appropriate product field.

1.9 The Supplier’s Senior Management must review the effectiveness of the BMS and HACCP systems (Formal Management Review) on a regular basis. This review should incorporate internal and external/third party audits, achievement of defined quality objectives, non-conforming product control, customer feedback, product safety and legality, the adequacy of the supplier’s resource, food security and consideration of fraud. These reviews should be documented and decisions made communicated to appropriate employees.

1.10 There must be a documented system for Crisis Management, with the appropriate training for members of the Crisis Management Team.

1.11 Crisis Management must include a documented procedure for recalling product from customers. Formally documented mock recall exercises or appropriately detailed traceability exercises should be conducted at least annually. Post incident reviews should be undertaken to establish areas for improvement. Regimes should be such that the location/destination of all affected products is established within 2 hours.

1.12 Customer complaints should be recorded and analysed. The measures implemented to prevent their recurrence should also be recorded, and their effectiveness reviewed (trending of complaints).

1.13 Relevant ABF customer/retailer CoP’s and/or specifications must be held on site; regimes shall be in place to pass this information to the supply base.

2 Hazard Analysis Critical Control Point (HACCP)

2.1 A fully-documented Product Risk Analysis study (e.g. HACCP) must be in place and available for review for all products supplied. This should be developed and managed in accordance with World Health Organisation (WHO)/Food and Agriculture Organisation (FAO) Codex principles and must include:-

• Product safety within its scope; the potential for Chemical, Physical, Microbiological and Allergenic Hazards must be considered at all process stages.

• The establishment and maintenance of an effective Pre-Requisite Program (e.g. cleaning and sanitising, pest control, maintenance, personal hygiene, staff training, purchase and procurement, transportation, and allergen control).

• All relevant product lines with a current process flow diagram for each.

• All activities from raw material sourcing to product despatch.

• Critical Control measures, tolerances and monitoring procedures, along with a record of how the Critical Control Points (CCPs) were identified (e.g. the decision tree).

• The corrective actions to be taken in the event of a deviation from the HACCP plan. The plan should identify immediate actions and corrective actions to avoid reoccurrence.

• Assignment of responsibility.

• A system of verification that the HACCP system, including signed flow diagrams, is in compliance with the HACCP plan.



2.2 A multi-disciplinary HACCP Team must be established with a formally HACCP trained Team Leader.

2.3 The HACCP study should be subject to validation reviews annually, and also in the event of any relevant plant, processing, production changes or product recall.

2.4 The HACCP shall be supported by protocols demonstrating the supplier has also considered malicious contamination, sabotage, misuse of products and potential food fraud.

2.5 For suppliers manufacturing high-risk products suitable separation of materials, staff, equipment and utilities must be in place and subject to risk assessment.

3 Supplier Approval

3.1 Raw materials, ingredients and packaging materials should be purchased only from approved suppliers; a formal supplier approval and monitoring process should be evident. The process must consider the supplier’s trading history (recalls & prosecutions) and include controls on initial or exceptional sourcing requirements.

3.2 Approved suppliers must, if applicable, be able to demonstrate that they operate from premises and undertake operations approved/certified by the relevant authorities.

3.3 There should be a process for the continued assessment of supplier performance.

3.4 A list of approved suppliers, and evidence supporting the approval and monitoring process should be available e.g. supplier audit / questionnaire and monitoring records.

3.5 To gain approval, production sites of critical raw materials, ingredients and packaging (identified by Hazard Analysis) should receive formal site audits, covering management control, factory hygiene and GMP. The maintenance of certification to an appropriate third party standard, for example BRC, BRC/IOP may be an acceptable initial or surveillance alternative.

3.6 Factored goods (supplied via an agent) may not be approved solely by reviewing the supplier’s approval methodology, but each potential sub-contracting supplier must be independently verified and records of these reviews retained.

3.7 Manufacturing sites of non-critical raw materials, ingredients and packaging should also be assessed; however, this may be achieved by use of an assessment questionnaire. This should cover the same subject headings as an on-site audit.

3.8 Raw material and packaging specifications, of sufficient detail to ensure that the safety, legality, integrity and authenticity of products are not compromised, should be held and formally controlled by an authorised manager. These specifications should be reviewed and agreed with the supplier at an appropriate frequency.

3.9 For each raw material, ingredient and packaging group or food safety critical service supplier a risk assessment for physical, chemical, allergenic, microbiological contamination, the potential for substitution or fraud and quality considerations shall be in place and included in approval and monitoring systems. Risk assessments shall be reviewed at least annually.

3.10 In the event that key production activities are outsourced by the supplier, these must be formally reviewed separately and be in accordance with the requirements of this CoP.



3.11 Where non GFSI certificated suppliers are approved solely on questionnaires, the supplier’s traceability activity must be challenged at least every 3 years.

4 Material Receipt, Packaging Storage (inc. Third Party) and Handling

4.1 All incoming materials destined for inclusion into product must be checked to ensure their listing on the site’s Approved Suppliers List.

4.2 Incoming materials should be checked externally before being brought into raw material storage areas. Materials should be checked for compliance with purchase order and also evidence of:-

• Damage,

• Pest contamination or infestation,

• Other indications of contamination e.g. glass, dampness, tampering, inappropriate materials or other spilled materials,

• Potential allergenic contamination.

4.3 The scope of any additional checks on incoming materials on arrival or before use required to ensure the safety, legality or integrity of products made must be formally documented.

4.4 Delivery trailers or tankers should also be checked for condition, cleanliness, relevant cleaning records (i.e previous load certificates) and intact security seals/lock, if used or signs of tampering.

4.5 Temperature checks must also be carried out where material or ingredient temperatures are critical, as defined by HACCP. Higher-risk ingredients or packaging should be sampled and tested, and a formal positive release system should be used, where appropriate.

4.6 All audit, sampling, acceptance and rejection procedures must be fully documented and results recorded.

4.7 Incoming materials, including those delivered in bulk and in packaging, must be incorporated into the site traceability system at intake using supplier batch codes, bulk transfer or internal coding systems.

4.8 Batch specific certificates of analysis / conformity / authenticity may be accepted as a means of reducing checks on incoming materials. They should not replace visual assessment or, if necessary, material identification.

4.9 Segregation, either physical or systematic should be applied to all batches of incoming materials until formally approved for use.

4.10 Identity preserved materials (e.g. Organic, RSPO) must be traceable and reconcilable within stock control and traceability systems.

4.11 Raw materials and ingredients should be segregated from packaging materials and finished products in storage.

4.12 If any material fails to meet the required standard, it should be placed in quarantine i.e. segregated with clear identification to prevent use until its disposal or return can be arranged.



4.13 Raw materials and ingredients must be stored under conditions which maintain their quality and integrity.

4.14 Raw materials and ingredients must, at all times, be stored in their original sealed packaging, or be transferred to covered food-grade containers, which are clearly labelled as to their contents. These must be kept off the floor at all times.

4.15 Deboxing should be conducted in a segregated area. Outer wrappings should not be taken into exposed product areas.

4.16 All materials must be subject to a formal system of stock rotation and traceability. Any material, which exceeds its shelf-life, must be identified and quarantined pending a decision as to its fate.

4.17 Storage of all materials or equipment should be far enough away from facility walls to allow cleaning, pest control device location and audit.

4.18 Where a third-party storage facility is used, storage conditions should be monitored regularly as part of a formal schedule, there should be full records of regular GMP audits at these facilities, including closing out of any issues identified. An assessment frequency as determined by risk assessment should be maintained.

5 Process Control

5.1 A robust New Product Development (NPD) process which assures the safety, legality and quality of products intended to be manufactured must be in place. For packaging this must include bar code, colour and labelling text validation, and migration test data for the intended product. The new product sign-off shall interface effectively with the site HACCP systems and scope and comply with allergen declarations.

5.2 All critical processing conditions (e.g. those for product safety and quality - identified by Hazard Analysis or the BMS) must be monitored and recorded at an appropriate frequency, to demonstrate compliance with the BMS and any relevant legislative requirements.

5.3 Records of critical processing conditions must be stored in a readily retrievable manner and be retained for a minimum period taking into consideration both the shelf-life of the material and also the final product being manufactured (which may be extended by the customer by freezing).

5.4 For “High-risk” operations, stringent barrier disciplines coupled with the physical separation of raw or unprocessed materials from processed materials is essential to minimise the risk of cross-contamination.

5.5 Key process monitoring and measuring devices, as identified by HACCP and the BMS, should be clearly identified for calibration purposes and included in a Calibration Register; which should detail the calibration tolerance for each item. The calibration status of each item must be shown, along with the date when the next calibration is due. Certificates of calibration should be available on site.

5.6 Automated process control and process monitoring equipment must be routinely checked for accuracy, within agreed parameters, at a predetermined frequency. Accuracy checks should be carried out more frequently than calibrations. Appropriately calibrated reference standards should be kept for this purpose and full records retained.



5.7 Temperature and/or time recording equipment, where identified as critical to product safety, quality or legality, should be linked to an effective failure alarm system, and monitored manually on a regular basis.

5.8 Actions to be taken in the event of out-of-tolerance conditions occurring including when equipment is found to be inaccurate or out-of-calibration must be fully documented, and records of any incidences should be maintained.

5.9 The following documentation should be controlled and available for reference in appropriate areas of the site:

• Formulations/Recipes,

• Plant operating procedures/work instructions,

• Plant operating settings.

5.10 Any rework generated must be used in accordance with documented procedures that ensure the safety, legality, quality and consumer expectation of the finished product. Traceability must be maintained accordingly.

5.11 Quantity checking e.g. by weight or volume must be verified according to relevant legislative requirements, with adequate records maintained for an appropriate period. Effective weight control and the accuracy and reliability of the system used must be demonstrated. Where bulk materials are distributed this must include the weighbridges or flow-meters used.

• Documented corrective action procedures should be followed in the event of underweight or low volume packs.

• If the product is packed at a fixed weight or average weight, appropriate weight profiles from past production runs must be available to confirm adherence to legislative requirements.

6 Quality Assurance (QA)

6.1 A controlled QA manual should be available, which should include the following:

• Documented start-up checks for production and packing operations.

• Instructions for conducting scheduled process equipment validation routines for key plant or equipment e.g. ovens, retorts, pasteurisers. Supporting records are to be available,

• Sampling regimes and protocols,

• Test methods and frequencies,

• Calibration techniques and frequencies,

• Testing equipment instructions.

6.2 Compliance with the parameters detailed within the product specification or on pack/marketing claims must be demonstrated. For packaging this should, if applicable, include absence of taints, Bar code, colour and labelling text verification.

6.3 The number of QA staff should be adequate for the work required, and to cover the factory work-pattern in operation. CCP-related QA data must be kept up to date and verified by a member of the technical staff at Supervisor level or above.

6.4 Adequate quality checks, monitoring of product intermediates and in-process materials should be made and recorded during the manufacturing process.



6.5 There should be a documented procedure, which describes the action to be taken in the event of out-of-specification material being produced. This procedure should include how the safety status of the product is established before release, if appropriate.

6.6 Unsatisfactory results must be highlighted to an appropriate member of the management team and appropriate corrective action taken and recorded.

6.7 When non-conforming product has been produced, the effectiveness of the corrective actions must be reviewed.

6.8 A formal process for the handling, control and security of non-conforming product must be in place, this should detail the levels of authority required for decision making on disposal and the methods of disposal undertaken.

7 Laboratory Testing

7.1 Analysis may be carried out on-site; however, the use of specialist laboratories may be necessary for certain testing activities. Any laboratory used to undertake analysis related to food safety or legality (e.g. pathogens, heavy metals, pesticides) must be ISO 17025 or otherwise nationally accredited.

7.2 All laboratories should be sited away from exposed product areas to minimise the risk of product contamination. For microbiology laboratories this is imperative, and strict precautions must be taken with respect to staff and material movement.

7.3 Unless a microbiology laboratory is totally isolated from the factory and storage areas, including ventilation and drainage systems, pathogen testing must not be conducted on site.

7.4 All laboratory testing must be conducted by fully trained and competent personnel, whether in on-site or contract laboratories.

7.5 On-site laboratories should have achieved recognised formal accreditation and should take part in recognised performance assessment or proficiency testing schemes (e.g. QM, Smart QA, and Senate).

7.6 Records of all test results should be held on site and be available for assessment. Where electronic results are presented these should be traceable to the testing laboratory and its accreditation.

8 Finished Product Assessment, Labelling and Despatch

8.1 Ensuring the legality of labelling on retail packs remains the responsibility of individual ABF Companies; unauthorised amends or over-labelling are not permitted.

8.2 Product specifications should be subject to formal document control.

8.3 Adequate quality checks should be conducted on all finished products and recorded in full. These should be checked and verified and should, where appropriate, include:

• Visual or organoleptic assessment.

• Dimensional and or functional assessment.

• Chemical, microbiological and physical assessment.

• Volume or weight assessment.

• Packaging or seal assessment.



8.4 Specifications should be available for reference where the quality checks are performed.

8.5 In cases were food safety related testing (e.g. pathogen) is undertaken prior to release Finished product must be segregated, either physically or systematically, until the results of appropriate QA tests confirm compliance with the product specification.

8.6 Reference samples should be retained for the duration of the product’s shelf life, and appropriate records maintained.

8.7 Certain QA test results (e.g. microbiological) may only become available after the product has been despatched and are therefore retrospective. In this instance, appropriate instant indicator tests should be carried out before despatch e.g. α amylase tests, wherever possible.

8.8 All packed retail products must be labelled/coded. Labelling should include the following:-

• Product type/name of the food,*

• The name or business name, or the office of the manufacturing site, packer or seller (if established within the EU, indicate appropriate EU number, if appropriate)*,

• Best Before or Use-by duration marking*,

• Product weight/volume (if applicable)*,

• Ingredients (if applicable),

• Storage temperature/requirements and conditions of use (if applicable)*,

• Any major allergens that might be contained in the product*,

• Nutritional Information,

• Batch number/date and time of manufacture*.

* Should be detailed on packed ingredient bags.

8.9 Products must be despatched within a controlled stock rotation system.

8.10 The system of traceability must be maintained beyond the point of despatch, linking production codes to despatch and transportation records.

8.11 Packaging outers should be inspected for cleanliness, absence of contaminating substances, damage and leakage, before despatch.

8.12 Loading bays should be separate from staff entrances and covered to protect product.

8.13 The cleanliness and integrity (and temperature, where relevant) of all transfer equipment, vehicles/ transport containers must be confirmed and recorded before loading. Vehicles and trailers used for the transport of food materials shall be subject to appropriate recorded maintenance, inspection, certification and control. Bulk carrying vehicles should ideally be designated for “Food Use” only and subject to certificated cleaning/last load check regimes.

8.14 Temperature-controlled vehicles must be fitted with permanent, calibrated, continuous temperature monitoring and recording equipment. Such vehicles must be pre-chilled before loading. Trace heated or insulated vehicles used for the transportation of



products at elevated temperatures (e.g. chocolate or palm olein) should be appropriately controlled.

8.15 Contract hauliers used for despatching products must be formally approved for carrying food products and be issued with a specification detailing the requirements demanded for the safe and hygienic handling of food or food-related materials.

9 Contamination Prevention

9.1 Fraud

9.1.1 It is expected that the supplier will be able to demonstrate via provision of documentation that they are able to keep appraised of ongoing issues associated with the materials being purchased. Information on food fraud/authenticity can be found at the European Food Standards Agency RASFF portal. Assessment information may also be available from Trade Associations, other government sources or private resource centres. Fraud shall be deemed to include:-

• Unapproved enhancements • Counterfeiting • Dilution • Substitution • Concealment • Mislabelling • Grey market purchasing

9.1.2 Suppliers must be able to demonstrate that raw materials, ingredients or packaging susceptible to fraud (e.g. spices, maple syrup, honey, meat, fish,) have been formally identified via a vulnerability assessment process and are supplied with suitable certification and routinely tested by a reputable third-party to ensure their authenticity.

9.1.3 Where specific claims on origin, variety or supply chain / chain of custody (e.g. RSPO, Non-GM, Organic / Free-Range) are made verification records shall be required for each batch supplied. An appropriate routine of verification testing shall be in place where substitution risks are identified.

9.1.4 The blending of batches containing contaminants above legally/CODEX specified limits must not be blended to produce compliant material.

9.2 Premises

9.2.1 Premises, plant and services shall be laid out in such a way as to limit the chances of cross-contamination from chemical, microbiological, physical or allergenic contaminants. Stationery such as staples, paperclips and pins, brittle plastics must not be used in production areas.

9.2.2 To support training activities, areas with different levels of risk from contamination shall be mapped and personnel, material and waste routes formally defined.

9.3 Foreign Body Control

9.3.1 Adequate and appropriate devices (in-line sieves, magnets, optical-sorts, metal detectors e.t.c.) must be installed for dry and liquid ingredients in the process and be operational.

https://webgate.ec.europa.eu/rasff-window/portal/?event=notificationsList&StartRow=1

https://webgate.ec.europa.eu/rasff-window/portal/?event=notificationsList&StartRow=1



9.3.2 Sieves and filters must be checked for integrity and contents at a predetermined frequency, and records maintained must show that they function suitably at the declared critical limits. Target sieve and filter sizes are detailed below:-

Suggested Target Sieve/Filter Sizes Ingredient Examples

0.5mm Water

1mm White wheat flour Baking powder Liquid Glucose

2.5mm Salt Bread Improvers Compound Seasonings Corn Flour Dextrose Granulated Sugar Fine Wholemeal Flour Icing Sugar Maize Rice Flour Rusk Rye Flour Semolina

6mm Seasoning/Herb blends Granary Flour Rice Coconut

9.3.3 Unscreenable materials such as dried fruit should be inspected manually before use in a manufacturing process. Where dried or vine fruit processing is the operations core activity appropriately controlled washing, screening, aspiration, cascade-destoning, optical, laser and or X-ray and manual inspections followed by metal detections are expected.

9.3.4 Where in-line rotary nylon sieves are used, these should be colour coded, however, the preferred alternative is considered to be punched plate stainless-steel, metal-detectable sieves.

9.3.5 All finished packed products should, where appropriate, be passed through a metal detector or x-ray system. Pipeline metal detectors are acceptable where tunnel metal detection is inappropriate. In canning or metallised packing operations, effective metal detection must be carried out either just before packing, e.g. with throat metal detectors, or as near to the packing stage as possible. The metal detectors should be tested with the appropriate test pieces inside or amongst the product, to correctly represent metal contamination. With in-line metal detectors, testing must also indicate that the rejection or alarm / belt stop system is working correctly when metal is detected.

9.3.6 The metal detector/x-ray tests must demonstrate that all required aspects of the unit work correctly e.g. belt stop synchronisation, bin full, search head overload, reject failure, low air pressure, sequential metal contamination rejection. Test methods should be risk assessed and controlled to minimise potential for product contamination.



9.3.7 Metal detector/x-ray test packs may be made up and clearly identified as a test pack (indicating the test piece size and type) to reduce product wastage. Test packs or product containing test pieces must be allowed to enter the reject bin.

9.3.8 Suggested metal detector test pieces sizes are detailed below:-

Suggested Maximum Test Piece Size - mm Ferrous Non-Ferrous Stainless

Steel Product Height on belt - mm

25 1.5 2.0 2.5 75 2.0 2.5 3.5

125 2.5 3.0 4.0 >175 3.0 3.5 4.5

In-line pipe internal diameter - mm 50 1.5 2.5 3.0

50 - >100 2.5 3.0 4.0 Freefall aperture diameter - mm

Up to 100 1.5 1.5 2.0 Up to 150 1.5 2.0 2.5 Up to 200 2.0 2.5 2.5

> 250 2.0 2.5 3.0 Large metal test-piece

20

9.3.9 Metal detector test pieces used should be of three types, ferrous, non-ferrous and stainless steel or determined by risk assessment. In primary processing a detectors function may require other controls or tests e.g. removal of lead-shot contaminated fruit before comminution.

9.3.10 X-ray test packs should if applicable include other types of contaminants being sought (e.g. glass, hard plastics, stone).

9.3.11 Metal detector/x-ray reject bins should be kept locked and be accessible to authorised personnel only.

9.3.12 The re-screening of rejected materials for further processing is not recommended under any circumstances.

9.3.13 In the event of a malfunction of an anti-contaminant device, product must be rechecked up to the time of the last correct check or rejected. Appropriate records of action taken should be kept.

9.3.14 When foreign bodies are removed from the process by an anti-contaminant device (e.g. metal detector reject), every effort should be made to determine the source of the contaminant and investigation records maintained. This may not be feasible where the detector is a primary control.

9.3.15 Formal procedures must be in place for any anti-contaminant device operation, synchronisation, testing, and training purposes. For magnets these shall include scheduled strength and integrity checks.

9.3.16 Water that comes into contact with product or equipment must come from a recognised potable source. The quality of ingredient water, steam and ice should be tested routinely (i.e. microbiological, chemical and organoleptic). If the factory



conducts water-treatment (e.g. chlorination), dosing levels must be monitored routinely. Intake air supplies for spray-driers, instantisers, granulators, over pressure air conditioning systems or similar applications in high-care areas must be equipped with appropriately controlled filtration.

9.4 Genetically Modified Organisms (GMOs)/Protein Engineering

9.4.1 Unless contractually agreed with each ABF division supplied, the provision of any ingredient, additive or processing aid derived from genetically modified or protein engineered components is prohibited. This restriction extends to any derivative including the products of bio-fermentation using rice, soya or maize as substrates. For a list of known soya and maize ingredients and derivatives, please see the appendix.

9.4.2 Supplier assurance must be sought and updated appropriately of GMO status ingredients or derivatives used. Copies of GM test certificates or a written statement declaring the raw material is non-GM must be held, where appropriate.

9.4.3 The “EU approved” GM-derived content of an Identity Preserved (IP) ingredient must be below the 0.9% threshold for adventitious contamination. Traceability documentation must be held that demonstrates compliance with this threshold. Documented mass-balance tests must be conducted each six-months or at the defined incidence to meet the IP scheme requirements. There are no exemptions for non-EU approved GM materials.

9.4.4 A documented GMO policy must be on file.

9.4.5 Companies handling raw materials should be aware when genetically modified varieties exist. Where possible companies should work towards securing future supply, sourced from non-GM, identity preserved material.

9.5 Contaminants (e.g.) Pesticides/Mycotoxins/Heavy Metals/Food Contact

9.5.1 A formal documented policy/risk assessment detailing screening/monitoring regimes for all EU legislated contaminants should be in place.

9.5.2 Where appropriate, to ensure compliance with legislation and product specifications, known/likely contaminants (e.g. pesticide residues, mycotoxins, heavy metal, veterinary residues, antibiotics) levels in raw materials and finished products should be evaluated at agreed frequencies. Where local limits are not specified Codex Guidelines should be used.

9.5.3 Where materials intended for manufacture into food contact packaging or direct food contact conveying equipment (e.g. belts) are used, suppliers must be able to demonstrate the material’s compliance with the relevant Food Contact legislation.

9.5.4 In primary production of dried fruits and nuts, controls on crop habit and husbandry together with in-process sorting and other controls on mould are required to minimise mycotoxin levels in finished products. For such high-risk materials per-batch mycotoxin testing and certification regimes are essential.

9.5.5 Where appropriate, suppliers should be able to demonstrate compliance with European Union regulation concerning the Registration, Evaluation, Authorisation and restriction of Chemicals (REACH).



9.5.6 If applicable, the absence of contaminants/taints/ residual solvents must be demonstrated at pre-defined frequencies.

9.6 Allergens

9.6.1 When referring to allergens, this Code of Practice covers those allergens listed in EU legislation only; however, globally allergen listings vary. A listing of currently EU legislated food allergens is contained in Appendix 2. The relevant allergen list for the country where the material is used/sold must be applied.

9.6.2 Ideally, legislated food allergen based/containing materials should only be used when no alternatives are available.

9.6.3 Supplier assessments shall ascertain the suitability of the allergen control regimes (HACCP Verification & Validation, Pre-requisite Program, Risk Assessment, Management and Communication) in place within the supplying sites and where appropriate the supply base. Ingredient suppliers, where practical and appropriate, are required to identify clearly their materials as containing allergens.

9.6.4 Where dry flushing is used, data showing a decline in the level of allergen shall demonstrate the efficacy of cleaning. The supplier should be able to demonstrate that:-

• Flush material has been tested for masking properties.

• High levels of salt and sugar were not used as flush material as it inhibits detection of the protein.

9.6.5 The practice of positively releasing materials potentially containing allergens is not good practice and must not be used, unless it is used to substantiate the adequacy of other validation/verification activities.

9.6.6 The supplier must be able to demonstrate that their allergen controls are based on either

• Risk assessment; and acted upon accordingly, where no data is provided refer to ABF Company for guidance.

or based on reputable Governmental or sector guidance, examples include:-

• Campden Guide 59 – Validation of Cleaning to remove food allergens • Campden Guide 71 – Food allergens; practical risk analysis, testing

and action levels • FSA Guidance on Allergen Management and Consumer Information

http://multimedia.food.gov.uk/multimedia/pdfs/

9.6.7 It is expected that the supplier will be able to demonstrate, via provision of test data, that they are independently able to keep appraised of which Raw materials, Ingredients or Finished Product received or produced contain allergenic ingredients.

9.6.8 Where an allergen is not incorporated into all products, suitable control measures must be in place for its management.

9.6.9 All allergens require specific handling. The Supplier must be able to demonstrate that specific risk assessment studies have been performed on all allergen-

http://multimedia.food.gov.uk/multimedia/pdfs/



containing ingredients, with particular attention to ingredients containing nuts, sesame seeds and dairy products. These assessments must:-

• Identify the allergens on site and which products are at risk.

• Identify potential allergen cross-contamination from suppliers.

• Define the Process Steps.

• Assess the risk of Allergen Cross-contamination.

• Implement Allergen Controls.

9.6.10 A formal policy for handling allergens must be held. Sites must be able to formally declare their allergen status e.g. nut/dairy-free.

9.6.11 Procedures and Practices designed to prevent allergen cross-contamination issues to other non-allergenic materials in place must include:-

• Controlled storage/sampling of incoming raw materials and ingredients - e.g. by the use of segregated, clearly designated storage areas, colour-coded containers and equipment.

• Dispensing activities.

• Production activities and equipment design.

• Rework controls.

• Cleaning - if insufficient volumes of a product containing allergen(s) are made to dedicate a line or building to its production, then the production run containing the allergen(s) should be scheduled at the end of the week or day, before a major clean-down of the line and related equipment. Records of this deep cleaning and any subsequent assessment must be retained.

• The efficacy of cleaning must be confirmed by both product testing and plant swabbing regimes, re-verified annually. Procedures must exist to deal with spillage of allergen-containing ingredients/products.

• Allergen awareness training to all relevant staff.

• NPD controls.

• Packaging controls.

• Internal and External verification activities (e.g. audits and customer complaint reviews).

• Oils/creams containing nut derived materials must not be used on plants or for hygiene purposes.

9.6.12 Retail product labelling must be in compliance local legislation or the export countries legislation; i.e. Where an allergen is present in a raw material and ingredient suitable precautionary labelling must be applied to finished product packaging, or where it might be present, validation testing is undertaken to confirm the need for a “May Contain” label.

9.6.13 Suppliers must inform the relevant ABF division as soon as it becomes aware of a change in the allergen status of products supplied.

9.6.14 Ingredients supplied for further processing should be clearly marked regarding allergen content.



9.7 Irradiation

9.7.1 Unless contractually agreed with each ABF division supplied the provision of any ingredient, additive or processing aid subjected to irradiation is prohibited.

9.7.2 This Code of Practice does not consider routine X-ray screening of materials to constitute irradiation.

9.8 Animal Origin

9.8.1 Where vegetarian/vegan products are specified formal controls must be in place to prevent inappropriate cross-contamination.

9.9 Controlled raw materials

9.9.1 Ideally, where controlled materials (e.g. IP Soya, RSPO palm or organic certificated products) are used on site, non-controlled variants of the same material should not be available on site. Where both controlled and non-controlled variants of the same or similar materials are held on site, formal regimes for their segregation, supported by regular traceability exercises, must be in place.

9.10 Religion

9.10.1 Where religious based processing requirements are specified these must be demonstrably evident.

9.11 Glass and Hard Plastics

9.11.1 The Supplier must have a documented glass/hard plastics policy, an audited glass/hard plastics register and an appropriate glass/hard plastics breakage clearance procedure. The policy should include a requirement that facility personnel, contractors and visitors do not bring unauthorised glass items into work.

9.11.2 Complete records must be maintained in the event of a glass or fragmentable plastic incident detailing at least the persons responsible for dealing with the incident, the actions taken in clearance and any disposals or additional controls made.

9.11.3 The use of glass/hard plastics on site must be kept to a minimum. Light fittings must either incorporate shatterproof tubes or be appropriately protected (e.g. with diffusers).

9.11.4 All glass fittings used in electronic fly killers must be enclosed or be appropriately protected.

9.11.5 All structural glass or windows within product areas must be protected against breakage or fragmentation (e.g. with protective film). Where present Northern Lights (glass roof) panels in process, packaging or storage areas must be subject to periodic recorded inspection for damage.

9.11.6 The frequency of checking glass or hard plastics should be determined by risk assessment, with any high-risk items ideally being audited at shift changeover or set up.

9.11.7 Where finished product is packed into glass containers or glass containers are manufactured robust and highly developed systems and control to prevent glass contamination are a pre-requisite.



9.12 Lubricants

9.12.1 All lubricants used where there is potential to contaminate food products should be shown to be of a food grade type (e.g. via US National Sanitation Foundation standard (NSF). The NSF H1 classification certifies that lubricants used in food and beverage processing equipment are safe and do not cause any harm if consumed accidentally. The NSF H2 classification certifies lubricants for applications where no contact with food products is expected.

9.12.2 Food and non-food lubricants should be stored separately.

9.12.3 Clear documented guidance on the use of lubricants should be available.

9.12.4 Mineral based oils should not be used as release agents.

9.13 Knives, Blades and Sharps

9.13.1 The use of knives, blades and sharps on site should be subject to appropriate management control. This should ensure that the type of knife or blade used is appropriate to its intended function and is subject to issue, registration, breakage notification and periodic recorded audit routines.

9.13.2 The use of “snap-off-blade” knives is not acceptable.

9.13.3 Where blades or sharps (e.g. bag stitching needles) are used in exposed product areas or in direct contact with food or food contact materials, a formal issue, audit, breakage notification, reconciliation and disposal system is required.

10 Site Construction and Maintenance

10.1 Structure

10.1.1 Premises must be sited so as not to be exposed to reasonably conceivable risks from their surroundings and constructed to limit the damage posed to them and personnel by regional natural phenomena (e.g. floods and earthquakes).

10.1.2 Buildings must be suitably designed and constructed or converted for their intended purpose. It is preferable that buildings are leased/owned in their entirety by the supplier, not sublet, and structurally maintained by either the tenant or the owner.

10.1.3 It is preferable that operations are undertaken in dedicated buildings.

10.2 External

10.2.1 A secure fence or boundary wall should enclose the site. If this is not possible appropriate site security services should be maintained to prevent unauthorised access.

10.2.2 All roadways and paths within the perimeter should be permanent and well drained.

10.2.3 Perimeter areas should be kept clean and free from rubbish, overgrown vegetation and disused equipment. Storage of materials and equipment directly against building walls should be avoided.



10.2.4 External storage of refuse should be in enclosed containers and well segregated from the main activities of the site.

10.3 Buildings

10.3.1 Site buildings must be well maintained and fully proofed against the elements and the ingress of pests, with adequate access for cleaning and inspection.

10.3.2 All internal surfaces (floors, walls, ceilings, doors etc.) should be impervious, easy-to-clean, and in sound condition. These should be of an appropriate colour such that the standard of cleanliness can be demonstrated.

10.3.3 Building materials, including paint or other treatments, must not present a risk of tainting.

10.3.4 Where necessary, floor to wall and similar junctions should be coved. Severe angling should be avoided.

10.3.5 Floors should be well maintained and adequately drained.

10.3.6 Drainage systems must be adequate to cope with peak loads without flooding and allow adequate access for cleaning purposes. Interceptor pits and fat traps should be included on the routine cleaning schedule.

10.3.7 Where necessary, wall and door surfaces should be adequately protected against mechanical damage (e.g. metal kick plates, bump-bars).

10.3.8 Where gantries or oversteps are provided these should be fitted with adequate kick plates to prevent the contamination of surfaces below.

10.3.9 Cavity walls, the base of all lift shafts and also false ceiling voids should be accessible for, and subject to pest control audits and cleaning.

10.3.10 Adequate ventilation must be provided to minimise the formation of condensation, and allow comfortable working conditions.

10.3.11 Ventilation systems in “High Risk” areas should be designed to create the required positive pressure.

10.3.12 Air inlets should be suitably filtered. Filter cleaning or changing should be included in the cleaning or preventative maintenance (PM) schedule.

10.3.13 Electric cabinets, cables and similar should be situated far enough from the wall and off the floor to allow adequate access for cleaning. Routine preventative maintenance checks on such equipment may incorporate cleaning tasks, to help prevent pest harbourage.

10.3.14 Electrical cables may be carried on an open vertical tray rather than in enclosed conduits.

10.4 Equipment

10.4.1 Equipment used in food production areas should be constructed with careful attention to hygienic design.



10.4.2 All equipment should either be sited far enough off the floor and away from the wall to ensure that adequate access is provided for cleaning, or fixed firmly to the wall or floor with no gap.

10.4.3 Preparation tables adjoining walls should have backs to prevent food/ingredient contact with building fabric.

10.4.4 Joints between equipment and walls/floors should be coved/sealed. Food handling surfaces must be smooth, non-porous and inert to the food being produced. Spot or tack welds must not be used.

10.4.5 Motors and similar equipment must be sited so that there is no danger of oil or grease contaminating food. Where no alternative location is possible, effective catch trays should be installed, with provision made for regular emptying.

10.5 Maintenance

10.5.1 A formal Planned Preventative Maintenance (PPM) programme should be in place, including scheduled preventative tasks divided by area and individual pieces of machinery or equipment. All areas containing plant machinery should be incorporated into the programme.

10.5.2 Plant Maintenance (PM) tasks should be scheduled at a predetermined frequency.

10.5.3 Appropriate records should be maintained of work completed, with a sign-off to indicate that the area has been left free-from potential contaminants.

10.5.4 Major engineering work must be screened from the rest of the production plant. Following such work, production plant must be signed-off as being clean and safe and formally released for use.

10.5.5 All plant maintenance work must be formally recorded.

11 Plant Hygiene

11.1 All plant, equipment and the factory environment must be kept clean, well maintained and in sound decorative order at all times.

11.2 Factory hygiene must be subject to appropriate management or supervisory control.

11.3 The Supplier must have Hygiene Documentation. This should include the following:

• Cleaning schedule,

• Cleaning records,

• Cleaning procedures, including any required maintenance or engineering support for cleaning access and routines for inspection, verification and release back to production following cleaning activities,

• Material Safety Data Sheets (MSDS) records; including acceptability for use assessment.

• Personal hygiene policy

11.4 The Cleaning Schedule should incorporate daily, weekly and less frequent cleaning, with clear divisions into areas. Cleaning tasks should be detailed for:-

• Product contact areas and equipment,



• Production area walls and floors,

• Storage area floors, walls, and racking,

• High level cleaning,

• Redundant/stored plant,

• Specialised cleaning tasks, such as internal silo cleaning.

11.5 Cleaning procedures should be on file for all areas and plant, and detail:-

• Methodology

• Cleaning chemicals & concentration

• Tools

• Personal protective equipment

11.6 Cleaning records must be maintained in conjunction with the schedule.

11.7 Where Cleaning-in-Place (CIP) systems are used, each cleaning cycle must be monitored and recorded, temperatures reached and detergent-dose used (preferably on the return cycle) must be recorded. The efficacy of the CIP system should be formally validated post installation/plant changes. An inspection report shall be available to indicate compliance with hygienic design criteria including, system drain efficiency, spray-ball effectiveness, separation from production flows.

11.8 Decorative finishes must be of a nature, and condition that enables effective cleaning.

11.9 Production debris and spillages should be cleaned promptly and disposed of adequately. A ‘clean as you go’ policy should supplement the routine cleaning.

11.10 Wherever possible, the factory environment should be kept dry.

11.11 Where relevant, there must be a documented ‘product-change’ procedure, designed to ensure that carryover and cross-contamination is avoided.

11.12 Recorded Good Manufacturing Practice (GMP), facilities and hygiene audits should be carried out regularly by appropriately trained and experienced staff. The findings should be used to review the effectiveness of the cleaning, hygiene and maintenance systems used in the factory and to implement documented improvement plans.

11.13 The efficiency of cleaning of production lines, CIP systems and factory environment should be monitored, where relevant, by microbiological swabbing, rinse water analysis or other means. For high-risk areas & plant limits of acceptable cleaning must be defined (e.g. microbiological or ATP bioluminescence). For low-risk areas and plant visual appearance may be used as an indicator of cleaning effectiveness.

11.14 Cleaning equipment should be well maintained and used in a controlled manner. Cleaning utensils should be colour coded by functional contact area to prevent the potential for cross contamination, particularly from amenity or special products to food contact areas.

11.15 Manufacturers’ instructions must be strictly adhered to when using cleaning chemicals.

11.16 Non-food chemicals must be clearly labelled and securely stored separately from food and packaging materials.



11.17 Cleaning hoses should be kept coiled and off the floor when not in use.

11.18 Cleaning utensils for use in High-Risk areas must be clearly dedicated for the purpose.

12 Personnel and Training

12.1 All personnel must undergo a full induction process, on commencement of employment, which describes the Supplier’s personnel procedures and conditions, together with health screening and an introduction to the concepts of food hygiene, food safety, health & safety and the formal Quality System. Records of the inductions should be retained.

12.2 All staff including temporary or agency staff must receive an appropriate level of training in:-

• Personal Health & Safety – Manual Handling, Personal Protective Equipment (PPE) etc.,

• Basic food hygiene,

• Principles of GMP,

• Task specifics,

• CCP/Pre-Requisite Programme (PRP_ monitoring activities /HACCP awareness,

• Allergen controls,

• Colour blindness.

Records of this training must be maintained for due diligence purposes. It should be possible to verify by signature that any employee has received this training. Where non-native speakers are employed appropriate provision of multi-lingual trainers / interpreters, documentation and signage should be in place.

12.3 Staff training needs should be subject to regular review and full records of training activities including refresher training maintained.

12.4 Adequate changing facilities and locker-space should be provided for factory staff, visitors and contractors outside production areas. Personal items (e.g. phones- unless company supplied, money, magazines) must not be taken into production areas. Permitted personal items may include registered emergency medical supplies and spectacles. Such items should be stored in clearly designated locations.

12.5 Staff facilities and toilets must be kept clean, tidy and in a good state of repair. Access from the production areas to the toilets must be via a ventilated space and enclosed by doors either side. Signage to remind personnel to wash their hands after visiting the toilet should be clearly displayed.

12.6 Staff entrances should be separate from despatch or incoming material entrances and should be fitted with signs displaying the requirements for personal hygiene in food-handling areas.

12.7 Key entrances to production areas must be equipped with hand-washing facilities, which are provided with ‘hand hot’ water, non-perfumed, bactericidal liquid soap and adequate drying facilities. For certain applications e.g. printing and colour manufacture, dedicated hand care facilities are expected together with appropriate hand sanitising products.

12.8 All visitors and contractors must be made aware of the Supplier’s personal hygiene requirements, and formally acknowledge their understanding and compliance.



12.9 All food contact / material handlers must wash / sanitise their hands when entering production areas.

12.10 Hand-washing or sanitation facilities should also be provided in the production areas, as required, including at hearing protection insertion points. These should be clearly dedicated to the purpose.

12.11 The effectiveness of hand washing / sanitising should be monitored.

12.12 All personnel in product areas must wear clean protective clothing that covers all personal clothing above the knee and suitable footwear. Protective clothing should be without buttons –i.e. pop fittings; and external pockets and must be removed before leaving the site. Where external pockets are unavoidable, these should be stud-fastened, and ideally, below waist level. Where high-visibility attire is required to be worn in food areas this must be both clean and in good condition.

12.13 Workwear for production based staff should be kept captive to the site. There shall be adequate provision of separate storage for personal or outerwear and clean and dirty work wear.

12.14 Workwear should be removed by production staff before entering the toilets or canteen unless risk assessment concludes otherwise.

12.15 Protective clothing must be laundered either on the premises or by an approved professional external laundry. Where possible, the use of a laundry service provider utilising segregated ‘food industry’ facilities should be considered. The practice of launderette laundering & the use of domestic dry cleaning providers for workwear should be avoided. Home laundering is undesirable. Ideally, workwear should be uniquely coded for traceability purposes.

12.16 Laundered protective workwear must be: - Free from loose soiling, vegetative pathogenic bacteria, foreign bodies, infestation or soiling by pests and cross contamination with legislated and non-legislated allergenic materials, mineral oils and other potentially injurious substances, including cleaning chemical or enzyme residues.

12.17 The availability of overalls must be adequate to allow changing immediately in the event of heavy soiling.

12.18 In all production and storage areas, where there is a risk of product or ingredient contamination hair must be fully enclosed by a hat and hairnet/snood. A snood must also enclose beards. Hairnets or mobcaps should be brightly coloured and ideally metal-detectable. Hairnets or mobcaps must be worn over the ears, covering the whole hairline.

12.19 Eating and chewing must be strictly prohibited in all production and storage areas, and permitted in designated areas only.

12.20 Workplace smoking controls must be compliant with local legislation and if not totally forbidden confined to an appropriately controlled designated external area.

12.21 Smoking whilst wearing workwear should be prohibited.

12.22 Drinking should take place only in controlled areas away from production lines, or from appropriately sited and controlled drinking fountains.

12.23 There must be a policy (including where required registration) on the wearing of jewellery in the factory. Watches and jewellery (except medical alert bracelets, a plain wedding



bands and one piece ethnic jewellery such as bangles or ankle bands) must be prohibited in all food-handling areas.

12.24 Excessive use of make-up and strong-smelling perfumes should be prohibited.

12.25 False-eyelashes, false nails and nail varnish/art must not be worn.

12.26 Fingernails should be kept short and clean.

12.27 Blue (or other highly visible) metal detectable plasters must be used in food handling facilities. Issue of plasters should be formally controlled; a representative sample from each batch of plasters should be screened via a metal detector to confirm their detectability.

13 Good Manufacturing Practice 13.1 There should be a well-defined product-flow through the factory, from raw material intake

to product despatch. Product crossover should be minimised.

13.2 Procedures should exist to deal with plant or production breakdowns and other stoppages, which may affect product safety, quality or integrity. Records of corrective actions taken should be retained.

13.3 Products requiring specific storage conditions (e.g. temperature-controlled) should be returned to those conditions when not being prepared, or if awaiting transfer to processing areas for a significant period of time (as defined by Hazard Analysis).

13.4 Rework should be collected in dedicated covered containers/sealed bags and clearly identified. The use of rework must also be taken into account for traceability purposes.

13.5 There must be adequate provision for the hygienic removal of waste materials generated during the manufacturing process. Containers used should be covered and clearly designated for the purpose. Co-Products/By-Products designated for animal feed shall be segregated from waste, and controlled to comply with legislation.

13.6 Branded goods/packaging must be disposed of in compliance with the requirements of the purchasing ABF Company.

13.7 The nature of the preparation/processing equipment and the procedures used should be suitable for the product being prepared.

13.8 Production equipment must be free from unsuitable fastenings and temporary repairs, and ideally should not incorporate glass in its construction. Temporary repairs in production areas must be subject to integrity checks and a timescale for rectification established.

13.9 The presence of wood in food-handling areas should be kept to a minimum. Where presence is unavoidable wood shall be ‘continually monitored’ to ensure it is in good condition.

13.10 The use of wood-handled, user modified or improvised implements should be prohibited in food-handling areas.

13.11 Rough-hewn single use white wooden pallets must not be taken into production areas. Wooden pallets should be used only in dry areas, for fully enclosed ingredients and products. An interleaving, protective sheet should always be used between bagged items and the pallet below, and between the top of bagged items and the pallet above, if double stacked. Wooden pallets for product despatch must be heat-treated initially,



sound, infestation and contamination free, stored appropriately and inspected prior to transfer to the packing area. The References give the EU legislation applicable to phytosanitary controls.

13.12 Storage conditions should be appropriate for the product being stored, complying with all relevant legislation and accepted industry standards.

13.13 Materials which may give rise to a risk of tainting or other form of product contamination must be segregated from food materials.

13.14 Rejected products and returned goods must be clearly labelled as such and stored in a clearly designated area.

13.15 Stored /slow moving products should be inspected at least monthly for signs of damage/deterioration/pest harbourage.

13.16 All food products must be kept off the floor at all times.

14 Staff Catering

14.1 There should be a documented risk assessment undertaken for all catering / vending operations associated with staff catering. This should be kept up to date, regularly reviewed and should identify all critical controls, monitoring procedures, people responsible and actions to take where controls are not operating.

14.2 Catering operations should be subject to recorded monitoring /audit by site management or an appropriate (local) authority.

14.3 Catering staff should be appropriately trained in food safety, to a level commensurate with their role. It is expected that all staff should hold the equivalent of a basic food hygiene certificate and for unit managers to hold the equivalent of an intermediate certificate.

14.4 All areas associated with staff catering/mess rooms should be kept clean and tidy. There should be a documented cleaning record held for catering and vending operations.

14.5 Where high-risk foods are stored, appropriate temperature control must be maintained and temperatures regularly recorded throughout the day. All temperature control devices should be calibrated and for probe thermometers, must be sanitised between uses.

14.6 The potential for cross contamination must be reduced by the use of separate storage and preparation areas where practicable. Where this cannot be achieved, cooked items must always be stored above raw and there should be a clearly defined use of colour-coded chopping boards.

14.7 Reheating of products should be avoided. Where reheating does occur it must only be undertaken once.

14.8 Where a site declares itself as “nut-free” and or “sesame-free” it will be expected that this declaration also includes the canteen and all associated vending machines.

14.9 Self-catering sites should provide hygienic facilities for breaks and refreshments including a safe means of storing and heating food.



15 Pest Control

15.1 The primary aim of any pest control programme must be to achieve a site, pest free status and as a minimum to ensure the elimination of any uncontrolled pest activity.

15.2 An in-depth pest control programme must be in place, using appropriately trained and experienced staff or a reputable contractor. In addition to monthly scheduled inspections an in-depth Field Biologist survey should be conducted at least four times (twice for packaging suppliers) each year to verify controls and management.

15.3 A current service contract must be held, detailing pests covered and the frequency of service and assessments, if a contractor is used. Full details of the follow-up programme to be adopted by the contractor in the event of a rodent infestation should also be included.

15.4 For sites holding Organic certification potential treatment programmes must be documented.

15.5 Suppliers should ensure that a proactive, preventative approach is adopted to pest control. This should be demonstrated by the presence of clear, signed off proactive advice in the pest control file e.g. relating to pest proofing, and an apparent ownership of the pest control management for the site.

15.6 Staff must be trained to report pest related issues.

15.7 Audits for signs of pest activity (especially rodents, birds and insects) must be undertaken on a regular and frequent basis.

15.8 All pest control audits and treatments must be recorded in a logbook or pest control file. This should contain full details of all findings, chemicals used and the pest controller’s recommendations.

15.9 If a pest control contractor is used, they should be registered with a recognised pest control body or other nationally recognised organisation).

15.10 The pest control contractor or company making pesticide applications should hold up-to-date public liability insurance. A current certificate of insurance should be held.

15.11 The person responsible for pest control and the application of any pesticides should be suitably qualified with appropriate training certificates.

15.12 The premises must be adequately proofed against the potential ingress of pests.

15.13 The practice of preventative treatments using insecticides should be discouraged and be continuously reduced – unless risk assessment determines otherwise. The reduction of preventative treatments should be undertaken in conjunction with an increased depth / frequency of inspection and cleaning.

15.14 Where there is no risk of explosion, production and storage areas should be fitted with suitably located electrical flying insect control devices fitted with catch-trays. Electric fly killers (EFKs) should not be located above or near to exposed product areas. Sticky-type flying insect monitors may be used in small areas where there is open food product. These should be switched on at all times. There should be a programme for the annual replacement of EFK tubes (which must be sheathed), which should be recorded. EFK catches should be regularly monitored, results recorded and actioned as necessary.



15.15 Where appropriate, pheromone moth traps and/or crawling insect monitors should be provided in storage and production areas. Crawling insect monitors may also be appropriate in ancillary areas e.g. locker/changing rooms/canteens/toilets. Monitors and traps should be regularly monitored, results recorded and actioned as necessary.

15.16 All factory areas including canteens/mess rooms should be baited against rodents. Non-toxic monitor points should be located within production areas, although toxic baits are permitted if considered necessary. These should be tamper-evident and secured to the wall or floor to avoid relocation during cleaning.

15.17 Loose grain baits must not be used, coloured toxic wax blocks only should be used in exceptional circumstances within buildings, and then in a controlled manner to prevent potential foreign body contamination. Rodenticidal dust must only be used where it will not present a possible contamination issue. Baits/dust must be strictly controlled with the areas of use recorded and clearly labelled. Wax block bait and rodenticidal dust must not be used inside plant.

15.18 Live traps or glue boards intended to catch mammals must be checked daily.

15.19 Loss of toxic baits must be formally investigated.

15.20 All areas of the site should be kept free from debris, defunct equipment and rubbish, which may attract pests, or provide harbourage. Refuse skips should be kept covered.

15.21 External building and site perimeters should be baited with rodent bait stations. These should be sturdy, tamper-proof and secured in place. Toxic bait may be used.

16 Ethical Trading and Environmental Policy

16.1 The supplier should hold formal ethical trading and environmental policies and have systems in place to monitor and support compliance with the policies.

16.2 Ethical Procurement:

16.2.1 Procurement should be based on Ethical Trading Initiatives (ETI) and International Labour Organisations (ILO) convention recommendations.

16.2.2 This Code of Practice requires compliance with the ABF Code of Conduct.

16.2.3 As a minimum, the Supplier’s ethical policies must include:-

• An ethical management protocol for the supply base,

• A formally documented Corporate and Social Responsibility Policy,

• A supplier ethical risk assessment matrix,

• Access to a supplier’s ethical data.

16.2.4 Suppliers should seek to develop relationships with their supply chain consistent with the ABF Code of Conduct. Where suppliers show shortcomings in any of these areas, customers should strive to encourage a programme of improvement leading to compliance.

16.3 Protocols for the evacuation of buildings in the event of damage regardless of cause, fire, explosion or unauthorised gas/chemical release must be documented and in compliance with internationally recognised good practice (typically less than 4 minutes). Evacuation drills must be at least annual, or where seasonal activity is common, seasonal, and



formally recorded. These protocols may be challenged by the requirement of a demonstration.

16.4 Locked, blocked or inadequate means of escape or evidence of staff locked in are not acceptable.

16.5 Environmental Policy:

16.5.1 The following aspects will be included in the assessment of the supplier’s environmental policy:

• There should be a company environment representative.

• The supplier should be aware of and able to demonstrate compliance with all current legislation that may affect their activities.

• The supplier should have conducted an environmental review and considered all aspects of their products and services.

• The supplier’s environmental policy shall be supported by annually reported KPI’s.

• ABF Companies supplied must be made aware of any enforcement/ improvement or prohibition notices served on the site within the last 3 years.

16.5.2 Suppliers stating participation in a Sustainability Management programmes must be able to demonstrate membership of the relevant scheme and compliance with their core values.

17 Minimum Security Standards

17.1 As a minimum requirement, it is expected that sites will comply with current applicable National legislation. In addition the following provisions should apply:

• A nominated manager should be responsible for site security. • Site perimeters should be protected to deter unauthorised access. • Authorised access points should be monitored and a record maintained of all

persons and vehicles entering and leaving a site. • All staff, contractors, and visitors should be readily identifiable by their dress, name-

badge, or pass. • The identity of prospective employees should be verified and references obtained

before employment commences. • Plans to address Incident/Crisis Management and Business Continuity should be

reviewed and tested annually. Key staff should be briefed and trained in their responsibilities under the plans.

17.2 Where threat/risk levels are increased additional provisions will be necessary and may

include guarding, Closed Circuit Television (CCTV), security lighting and other additional protection measures.



17.3 The responsibility for achieving compliance with these requirements should be devolved to the chief executive or managing director with advice and assistance from relevant Security advisers.



ABF Supplier Code of Conduct: The core principles by which Associated British Foods (ABF) operates are:

• responsible stewardship of our environment

• being responsible for our people;

• being a responsible neighbour; and

• responsible for promoting good health. As an international business with suppliers and representatives the world over, we accept that we have a duty to trade responsibly.

We therefore want to ensure that those people with whom we deal and in particular our suppliers and our representatives live up to our values and standards and share that responsibility.

Accordingly, suppliers and representatives should comply with and seek to develop relationships with their own supply chains consistent with the principles set out below and should be compliant with all local laws and the following principles as a minimum.

Employment is freely chosen

There is no forced, bonded or involuntary prison labour. Workers are not required to lodge ‘deposits’ or their identity papers with their employer and are free to leave their employer after reasonable notice.

Freedom of association and the right to collective bargaining are respected

Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively. The employer adopts an open attitude towards the activities of trade unions and their organisational activities. Workers, representatives are not discriminated against and have access to carry out their representative functions in the workplace.

Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.

Working conditions are safe and hygienic

A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

Workers shall receive regular and recorded health and safety training and such training shall be repeated for new or reassigned workers.

Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided. Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.

The company observing the code shall assign responsibility for health and safety to a senior management representative. Child labour shall not be used Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child. There shall be no further recruitment of child labour.

Children and young persons under 18 shall not be employed at night or in hazardous conditions.



Policies and procedures shall conform to the provisions of the relevant International Labour Organization (ILO) standards.

A child is defined as any person less than 15 years of age, unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age would apply. If, however, local minimum age law is set at 14 years of age in accordance with developing country exceptions under ILO Convention 138, the lower age will apply.

A young person or young worker is defined as any worker over the age of a child as defined above and under the age of 18.

Land Acquisition

We adhere to the principle of free, prior and informed consent of all communities when acquiring land. The rights of communities and traditional peoples to maintain access to land and natural resources will be recognised and respected.

Living wages are paid

Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income.

All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.

Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

Working hours are not excessive

Working hours comply with national laws and benchmark industry standards, whichever affords greater protection.

In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off for every seven-day period on average. Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate.

No discrimination is practised

There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

Regular employment is provided

To every extent possible work performed must be on the basis of a recognised employment relationship established through national law and practice.

Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, subcontracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment. No harsh or inhumane treatment is allowed Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

Confidentiality

The confidentiality of information exchanged in the course of business must be respected and never be used for illegal purposes or for individual gain. False information must not be given in the course of commercial negotiations.

No bribery or corruption will be tolerated



The offering, paying, soliciting or accepting of bribes or kickbacks, including facilitation payments, is strictly prohibited.

A bribe may involve giving or offering any form of gift, consideration, reward or advantage to someone in business or government in order to obtain or retain a commercial advantage or to induce or reward the recipient for acting improperly or where it would be improper for the recipient to accept the benefit. Bribery can also take place where the offer or giving of a bribe is made by or through a third party, e.g. an agent, representative or intermediary.

Some examples of bribes are as follows. This is not an exhaustive list:

• lavish gifts, meals, entertainment or travel expenses, particularly where they are disproportionate, frequent or provided in the context of ongoing business negotiations;

• the uncompensated use of company services, facilities or property;

• cash payments;

• loans, loan guarantees or other credit;

• the provision of a benefit, such as an educational scholarship or healthcare, to a member of the family of a potential customer, public or government official;

• providing a subcontract to a person connected to someone involved in awarding the main contract; and

• engaging a local company owned by a member of the family of a potential customer, public or government official.

Facilitation payments are small payments or fees requested by government officials to speed up or facilitate the performance of routine government action (such as the provision of a visa or customs clearance). Such payments are strictly prohibited.

Suppliers, representatives and their employees must comply with all applicable anti-bribery and corruption laws. If no such anti-bribery or corruption laws apply or are of a lesser standard to that prescribed in the UK Bribery Act 2010, suppliers, representatives and their employees must adhere to the UK Bribery Act 2010.

Suppliers and representatives shall have in place anti-corruption and bribery procedures designed to prevent employees or persons associated with its business from committing offences of bribery or corruption. Suppliers and representatives will properly implement these procedures into their business and review them regularly to ensure that they are operating effectively. Environmental management We support and encourage operating practices, farming practices and agricultural production systems that are sustainable. The supplier and representatives will continually strive towards improving efficiency and sustainability of their operations which will include water conservation programmes.

The following aspects of environmental management will be included in the supplier assessment:

• there should be a company environment representative;

• the company should be aware of and able to demonstrate compliance with all current legislation that may affect its activities;

• the company should conduct an environmental review and consider all aspects of its products and services; and

• any enforcement, improvement or prohibition notices served on the site within the last three years. Quality

Any goods supplied shall be without fault and of the best available design, quality, material and workmanship, be fit for any purpose held out by the supplier and representatives or made known to the supplier and representatives or for which they are commonly used and shall conform in all respects with any order and specification and/or patterns or samples supplied or advised by the supplier and representatives.



Any services supplied shall be provided by appropriately qualified and trained personnel, with due care and diligence, to such high standard of quality as is reasonable for us to expect in all circumstances and shall conform in all respects with any order.

Audit and termination of agreements

ABF reserves the rights to verify the supplier’s and representative’s compliance with the Code.

Where supplier and representative reviews or audits demonstrate shortcomings in any of these areas, the supplier and representative should strive to implement a time-bound programme of improvement (remediation) leading to conformance.

In the event that we become aware of any actions or conditions not in compliance with the Code, we reserve the right to request corrective actions. ABF reserves the right to terminate an agreement with any supplier and representatives that does not comply with the Code.



Appendix 1 - References

Legislation – others may apply

Summary of Key UK & EU Food Safety Legislation

• Food Safety Legislation • Biocidal Products:

• EU Regulation 528/2012 concerning the making available and use of biocidal products

Food Safety and Hygiene (England) Regulations 2013 (SI No 2996)

• Commission Regulation (RC) No 852/2004 on the hygiene of foodstuffs Implemented by SI 2996/2013 above

• Commission Regulation (EC) No 2073/2005 on Microbiological Criteria for Foodstuffs Implemented by SI 2996/2013 above and amended by Commission Regulation (EC) No. 1441/2007 below

• Corrigendum (10.10.2006) to Commission Regulation (EC) No 2073/2005 on Microbiological Criteria for Foodstuffs

• Corrigendum (14.10.2006) to Commission Regulation (EC) No 2073/2005 on Microbiological Criteria for Foodstuffs

• Commission Regulation (EC) No. 1441/2007 (5.12.2007) amending Regulation (EC) No. 2073/2005 on microbiological criteria for foodstuffs

• Commission Regulation (EU) No 365/2010 (28.04.2010) amending Regulation (EC) No 2073/2005 on microbiological criteria for foodstuffs as regards Enterobacteriaceae in pasteurised milk and other pasteurised liquid dairy products and Listeria monocytogenes in food grade salt

• Commission Regulation (EC) No 2073/2005 on Microbiological Criteria for Foodstuffs Consolidated Version - Implemented by SI 14/2006 above

Food Safety Act 1990 (Chapter 16) • Food Safety Act 1990 (Amendment) Regulations 2004 (SI No 2990)

Food Safety (Enforcement Authority) England and Wales Order 1990 (SI No 2462)

Food Safety (Sampling and Qualifications) (England) Regulations 2013 (SI No 264)

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:167:0001:0123:EN:PDF


http://www.legislation.gov.uk/uksi/2013/2996/contents/made


http://europa.eu.int/eur-lex/lex/LexUriServ/site/en/oj/2005/l_338/l_33820051222en00010026.pdf

http://europa.eu.int/eur-lex/lex/LexUriServ/site/en/oj/2005/l_338/l_33820051222en00010026.pdf

http://eur-lex.europa.eu/LexUriServ/site/en/oj/2006/l_278/l_27820061010en00320032.pdf










http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2005R2073:20100519:EN:PDF

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2005R2073:20100519:EN:PDF

http://www.legislation.hmso.gov.uk/acts/acts1990/Ukpga_19900016_en_1.htm

http://www.legislation.hmso.gov.uk/si/si2004/20042990.htm

http://www.legislation.hmso.gov.uk/si/si1990/Uksi_19902462_en_1.htm

http://www.legislation.gov.uk/uksi/2013/264/pdfs/uksi_20130264_en.pdf



Appendix 1 – References (cont)

Food Safety Legislation

General Food Regulations 2004 (SI No 3279) Implement EC 178/2002 below Regulation (EC) No 178/2002 laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety

Commission Implementing Regulation (EU) No 931/2011 on the traceability requirements set by Regulation (EC) No 178/2002 for food of animal origin

General Product Safety Regulations 2005 (SI No 1803)

Microbiological Criteria for Foodstuffs – see Commission Regulation (EC) 2073/2005 above Official Controls (Animals, Feed and Food) (England) Regulations 2006 (SI No 3472)

Official Feed and Food Controls (England) Regulations 2009 (SI No 3255) Products of Animal Origin (Third Country Imports) (England) Regulations 2006 (SI No 2841) Products of Animal Origin (Third Country Imports) (England) (Amendment) Regulations 2007

(SI No 1605)

Products of Animal Origin (Third Country Imports) (England) (Amendment) Regulations 2008 (SI No 3230)

Products of Animal Origin (Third Country Imports) (England) (Amendment) Regulations 2009 (SI No. 875)

Products of Animal Origin (Third Country Imports) (England) (Amendment) Regulations 2010 (SI No 1758)

REACH Enforcement Regulations 2008 (SI No 2852) Implement EC 1907/2006 below Regulation (EC) No. 1907/2006 of the European Parliament and of the Council concerning the

Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)

Water Supply Regulations 2010 (SI No 991) (amend SI No 3184 below) Water Supply (Water Quality) Regulations 2000 (SI No 3184) (English Regulation)

• Water Supply (Water Quality) (Amendment) Regulations 2001 (SI No 2885)

• Water Act 2003 (Consequential and Supplementary Provisions) Regulations 2005 (SI No 2035)

Water Supply (Water Quality) Regulations 2000 (Amendment) Regulations 2007 (SI No 2734)







http://www.opsi.gov.uk/si/si2005/20051803.htm


http://www.opsi.gov.uk/si/si2009/pdf/uksi_20093255_en.pdf



http://www.legislation.gov.uk/uksi/2007/1605/made/data.pdf



















Appendix 1 – References (cont) Packaging Legislation

Food Packaging Legislation Materials and Articles in Contact with Food (England) Regulations 2012 (SI No 2619) Implement s

• Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food and repealing Directives 80/590/EEC and 89/109/EEC

• Commission Regulation (EC) No 2023/2006 on good manufacturing practice for materials and articles intended to come into contact with food

• Commission Regulation (EC) No 450/2009 on active and intelligent materials and articles intended to come into contact with food

• EU Regulation 10/2011 on plastic materials and articles intended to come into contact with food

• EU Regulation 1282/2011 amending and correcting EU Regulation 10/2011 on plastic materials and articles intended to come into contact with food

• EU Regulation 1183/2012 amending and correcting EU Regulation 10/2011 on plastic materials and articles intended to come into contact with food

• Corrigendum to EU Regulation 1183/2012 amending and correcting EU Regulation 10/2011 on plastic materials and articles intended to come into contact with food

Packaging (Essential Requirements) Regulations 2003 (SI No 1941)

• Packaging (Essential Requirements) (Amendment) Regulations 2004 (SI No 1188)




Plant Health (England) Order 2005 (SI No 2530) Implement Directive 2000/29/EC below – requires various imported plant products, such as wooden pallets, to be free from harmful organisms

• Council Directive 2000/29/EC on protective measures against the introduction into the Community of organisms harmful to plants or plant products and against their spread within the Community









http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:328:0022:0029:En:PDF

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:328:0022:0029:En:PDF















Food Packaging Legislation Timber and Timber Products (Placing on the Market) Regulations 2013 (SI No 233) Enforce:

• EU Regulation 995/2010 laying down the obligations of operators who place timber and timber products on the market

• EU Regulation 607/2012 on the detailed rules concerning the due diligence system and the frequency and nature of the checks on monitoring organisations as provided for in EU Regulation 995/2010 laying down the obligations of operators who place timber and timber products on the market

The above legislation contains the requirement that ‘Packaging compliance documents’ are supplied (this applies to all parties in the supply chain excluding the ultimate consumer)










Appendix 1 – References (cont)

• UK Retailer Standards

• Tesco – Food Manufacturing Standards v6; Metal Detection & Allergen Control

• J Sainsbury – Consolidated Standards

• M&S – Consolidated Standards

• Waitrose

• HACCP

• WHO Codex Alimentarius – Food Hygiene Basic Texts –2009

• CCFRA – Guidelines for the Establishment of Hazard Analysis Critical Control Points Technical Guide 42 – 2009

• CCFRA – Guideline72 TACCP – Threat Assessment and Critical Control Point

• Quality Management Systems

• Global Food Safety Initiative/BRC Global Standards (Food, Storage & Distribution and Packaging)/FSSC 22000.

• BS EN ISO 9001: 2008, 22000:2005 – Quality Management systems.

• IFST – Food and Drink, Good Manufacturing Practice: A Guide to its Responsible Management.

• Campden Guides - Design & Construction

• BS EN ISO 19011:2002 – Guidelines for Quality and/or Environmental Management Systems Auditing

• Ethical Trading Initiatives (ETI) and International Labour Organisations (ILO)

• Microbiology Micro-Facts, Issue 5 2003 – Leatherhead Food International

• Allergens

• Campden Guide 59 – Validation of Cleaning to remove food allergens

• Campden Guide 71 – Food allergens; practical risk analysis, testing and action levels

• FSA Guidance on Allergen Management and Consumer Information http://multimedia.food.gov.uk/multimedia/pdfs/

• Misc.

• Chilled Foods Ass. - Best Practice Guidelines for the production of Chilled Food.

• CEPI Industry Guidelines for the Compliance of Paper & Board Materials and Articles for Food Contact.

• Empac Guide to Good Manufacturing and Hygiene Practices for Metal Packaging in Contact with Food.

• AIB International Consolidated Standards – Prerequisite and Food Safety Standards & Food Contact Packaging Facilities.

http://www.fao.org/docrep/012/a1552e/a1552e00.htm



Appendix 2 - Allergens

Allergens

Current known major allergens as detailed in the Regulation (EU) No 1169/2011 on the provision of food information to consumers

ANNEX II SUBSTANCES OR PRODUCTS CAUSING ALLERGIES OR INTOLERANCES

1. Cereals containing gluten, namely: wheat, rye, barley, oats, spelt, kamut or their hybridised

strains, and products thereof, except:

(a) wheat based glucose syrups including dextrose(1);

(b) wheat based maltodextrins (1); (c) glucose syrups based on barley; (d) cereals used for making alcoholic distillates including ethyl alcohol of agricultural origin;

2. Crustaceans and products thereof; 3. Eggs and products thereof; 4. Fish and products thereof, except:

(a) fish gelatine used as carrier for vitamin or carotenoid preparations; (b) fish gelatine or Isinglass used as fining agent in beer and wine;

5. Peanuts and products thereof; 6. Soybeans and products thereof,

except:

(a) fully refined soybean oil and fat (1); (b) natural mixed tocopherols (E306), natural D-alpha tocopherol, natural D-alpha tocopherol acetate, and natural

D-alpha tocopherol succinate from soybean sources; (c) vegetable oils derived phytosterols and phytosterol esters from soybean sources; (d) plant stanol ester produced from vegetable oil sterols from soybean sources;

7. Milk and products thereof (including lactose), except: (a) whey used for making alcoholic distillates including ethyl alcohol of agricultural origin; (b) lactitol;

8. Nuts, namely: almonds (Amygdalus communis L.), hazelnuts (Corylus avellana), walnuts (Juglans regia), cashews (Anacardium occidentale), pecan nuts (Carya illinoinensis (Wangenh.) K. Koch), Brazil nuts (Bertholletia excelsa), pistachio nuts (Pistacia vera), macadamia or Queensland nuts (Macadamia ternifolia), and products thereof, except for nuts used for making alcoholic distillates including ethyl alcohol of agricultural origin;

9. Celery and products thereof; 10. Mustard and products thereof; 11. Sesame seeds and products thereof; 12. Sulphur dioxide and sulphites at concentrations of more than 10 mg/kg or 10 mg/litre in terms of the total

SO2 which are to be calculated for products as proposed ready for consumption or as reconstituted according to the instructions of the manufacturers;

13. Lupin and products thereof; 14. Molluscs and products thereof.





Appendix 3

Known Maize and Soya Ingredients and Derivatives

Maize

Ascorbates Ascorbic acid Aspartame Caramel Citrates Citric acid Corn Fibre Corn Gluten Corm Grits Corn Syrup Dextrin Dextrose Ethanol Fructose

Glucono delta lactone Glucose syrup Glycerine Hemicellulose High fructose corn syrup Isoglucose Lactic acid Maize flour Maize Meal Maize starch – regular and waxy Malt vinegar Maltodextrin

Masa flour Polenta Polydextrose Polyols Sodium ascorbates Sorbates Sorbitol Sugar syrup Sweetcorn Xanthan gum

Soya

Miso Soy extracts Soy sauce Soya concentrates Soya beans Soya fibre Soya flour Soya isolates Soya Lecithin Soya oil

Soya protein Tempeh Tofu TVP (textured vegetable protein) HVP (Hydrogenated vegetable protein)



Appendix 4 - Packaging

Summary of Key QA checks for Rigid Packaging Glass Metal Cans • Post annealing glass fault inspection • Migration specifics e.g. litho links, Bisphenol A.

• Stress check using polarized light. • Side seam welds.

• Critical default action log. • Seam checks for base on 3 piece cans.

• End of line “Packed Ware Audit”. • Compound fill level in can ends.

• Pre-start up checks at hot end. • Compound temperature stability (max Temp).

• Swab routine. • Plate steel supplier assurance - lacquer application.

• Mould wear (for mould number impression). • 2 piece can lacquer application checks.

• Glass density records.

• On jar traceability e.g. UV Coding.

Plastic Bottles and Containers Metal Caps and foils

• BPA – Hard Plastics. • Lug formation.

• Date coding and traceability marking. • Critical dimensions.

• Barrier integrity. • Compound fill level and coating integrity.

• Dimensional stability. • Irradiation.

• Migration specifics e.g. ESBO, phthalates, BADGE, Inks.



Dear Supplier,

If required to do so by an ABF division, please confirm receipt and acceptance of the terms detailed in

this Code of Practice for Suppliers of Food Products, Ingredients, Drink and Packaging and the

Code of Conduct of Associated British Foods plc by completing the acknowledgement and

acceptance slip below and returning it the requestor.

On behalf of the company named below, I confirm the company’s receipt, review and agreement to

comply with the requirements of this Code of Practice for Suppliers of Food Products, Ingredients, Drink and Packaging and the Code of Conduct of Associated British Foods plc., and that under

no circumstances will products or production facilities be changed in a way that will affect the quality,

integrity or safety of the products supplied to UK based Associated British Foods Divisions, without

prior approval.

Signature: __________________________________

Name: __________________________________

Company name __________________________________

Position: __________________________________

Date: __________________________________

Documents

CODE OF PRACTICE FOR CONDUCTING QUALITY...Associated British Foods CODE OF PRACTICE FOR SUPPLIERS OF FOOD PRODUCTS, INGREDIENTS, DRINK, AND PACKAGING Incorporating the Code of Conduct