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Food Safety Management System

This document details the comprehensive food safety framework at Dinweys French Fries Factory, covering HACCP, Prerequisite Programs (PRPs), FSSC 22000 alignment, food defense, food fraud prevention (VACCP/TACCP), traceability, recall procedures, environmental monitoring, and food safety culture.


Overview: GFSI-Benchmarked Food Safety Architecture

Dinweys operates a multi-layered food safety management system built on Codex Alimentarius HACCP principles, integrated with ISO 22000:2018 management systems, and aligned with GFSI (Global Food Safety Initiative) benchmarked standards including BRC and FSSC 22000.

Layer Standard Scope Status
Core HACCP (Codex Alimentarius) 7 principles applied to all CCPs ✅ Certified
Management ISO 22000:2018 FSMS — integrates HACCP + PRPs + traceability + PDCA ✅ Certified
Quality ISO 9001:2015 Quality management system ✅ Certified
GFSI-Benchmarked BRC Global Standard for Food Safety Issue 8 Retail-grade — supplier audits, site standards, food safety culture ✅ Available
GFSI-Benchmarked FSSC 22000 v6 ISO 22000 + ISO/TS 22002-1 PRPs + additional FSSC requirements ✅ Available on request
Religious Compliance HALAL All products — production lines certified ✅ Certified
Religious Compliance KOSHER Available on customer request ✅ Available on request

Key Insight: FSSC 22000 v6 is recognized by the GFSI and is widely accepted by European and North American buyers. While BRC is more common in the UK retail sector, FSSC 22000 is the preferred certification for many food manufacturers supplying the EU foodservice and ingredient sectors. Dinweys can provide either certification depending on customer requirements. The FSSC 22000 v6 scheme adds new requirements around food safety culture, sustainability, and food fraud mitigation that go beyond the previous version.


FSSC 22000 v6 — Detailed Requirements

Overview of FSSC 22000

FSSC 22000 is a GFSI-benchmarked food safety certification scheme that combines ISO 22000:2018, ISO/TS 22002-1:2009 (PRPs for food manufacturing), and additional FSSC scheme requirements. Version 6 was published in 2020 with transition to mandatory compliance by 2023.

ISO 22000:2018 Clause Mapping

ISO 22000 Clause Title Dinweys Implementation Status
4 Context of the organization ✅ — External/internal issues identified; interested parties mapped
5 Leadership ✅ — Food safety policy signed by top management; food safety team appointed
6 Planning ✅ — Risks and opportunities assessed annually; FSMS objectives defined
7 Support ✅ — Resources, competence, awareness, communication, documented information
8 Operation ✅ — PRPs, CCPs, OPRPs, traceability, emergency preparedness
9 Performance evaluation ✅ — Monitoring, measurement, analysis, internal audit, management review
10 Improvement ✅ — Nonconformity, corrective actions, continual improvement

FSSC 22000 Additional Scheme Requirements (v6)

Beyond ISO 22000, FSSC 22000 v6 requires:

Requirement Description Dinweys Compliance
Food Safety Culture Top management must demonstrate commitment through measurable culture KPIs ✅ Culture survey + KPIs tracked quarterly
Sustainability Environmental management program; waste reduction targets ✅ Waste segregation + energy monitoring + water conservation
Food Fraud Mitigation VACCP vulnerability assessment for all raw materials ✅ Updated annually; ingredient risk matrix maintained
Food Defense TACCP threat assessment against intentional adulteration ✅ Site security plan + access control + staff vetting
Allergen Management Cross-contact risk assessment; cleaning validation; labeling control ✅ Allergen matrix; cleaning validation swabbing
Transport & Storage Cold chain integrity; loading/unloading hygiene; temp monitoring ✅ Continuous logging; reefer pre-cool verification
Labelling Compliance Regulatory labeling review for each destination market ✅ Pre-shipment label verification against destination regs
Supplier Management Risk-based supplier approval; on-site audits for high-risk materials ✅ Tiered supplier program (see Supplier Approval section)
Management Review At least annually; must include food safety culture data ✅ Semi-annual management review meetings
QMS (Quality vs Food Safety) Distinction between quality and food safety deviations ✅ Separate NCR systems for safety vs quality issues

HACCP Plan for Frozen French Fries Production

Product Description

Parameter Details
Product Prefried and Deep-Frozen French Fries (Grade A)
Ingredients Potatoes (94%), Edible Vegetable Oil (~5.9%), Dextrose (0.05%), SAPP (0.05%)
Packaging 1 kg PE bag × 10 per carton (10 kg net)
Storage & Distribution ≤ −18°C, cold chain maintained throughout
Intended Use Deep frying, oven baking, air frying by QSR, catering, retail consumers
Intended Consumer General population including vulnerable groups (with proper cooking)
Shelf Life 24 months at −18°C (validated by shelf-life study)
Label Instructions Keep frozen at −18°C; cook thoroughly before consumption

Process Flow Diagram

Raw Potato Receiving → Storage → Washing → Inspection → Peeling → 
Cutting (Size-select) → Color Sorting → Blanching → Dewatering →
(Coating Application) → Par-Frying → IQF Freezing → 
Packaging → Metal Detection → Carton Packing → Cold Storage → 
Loading & Transport

↑ CCP designations shown in section below

Identified Hazards

Biological Hazards

Hazard Source Risk Level Justification
Salmonella Raw potatoes, soil, irrigation water High Ubiquitous in soil; forms heat-resistant biofilms
Pathogenic E. coli (STEC) Raw material, fecal contamination High Animal/human waste in growing regions
Listeria monocytogenes Environment, post-processing Medium Psychrotrophic — can grow at refrigeration temp
Staphylococcus aureus Food handlers, equipment surfaces Medium Enterotoxin production if temperature abused
Bacillus cereus Raw potatoes, soil Medium Spore-forming; survives mild heat treatment
Clostridium botulinum Soil, anaerobic conditions Low Controlled by frozen storage (no growth below 3°C)

Chemical Hazards

Hazard Source Risk Level Justification
Pesticide residues Agricultural inputs (pre-harvest) Medium Multi-residue screening required per GB 2763
Heavy metals (Pb, Cd, Hg, As) Soil, water absorption Low Low risk for potato compared to leafy vegetables
Acrylamide Formed during frying (Maillard reaction) Medium EU benchmark 500 µg/kg for french fries (EU 2017/2158)
Cleaning chemical residue CIP / manual cleaning processes Low Validated rinse cycles; ATP swabbing verification
Oil degradation products (TPM, FFA) Prolonged frying Medium TPM limit <24%; FFA limit <1.0%
Glycoalkaloids (solanine, chaconine) Green potatoes, light exposure Low Rejected at incoming inspection (green >2% surface)

Physical Hazards

Hazard Source Risk Level Justification
Metal fragments (ferrous) Equipment wear, broken blades Medium 2 mm max tolerance; in-line metal detection
Metal fragments (non-ferrous) Bearing cages, bronze bushings Medium
Metal fragments (stainless steel) Mixing blades, conveyor parts Medium Hardest to detect — 2.5 mm limit
Stones / soil clods Field soil in raw potatoes Medium Potato washing + destoner before cutting
Wood splinters Pallets, packaging Low Visual inspection + wood-free packaging zones
Plastic fragments Equipment, packaging Low Optical sorting + filtration
Glass Lighting, gauges, windows Low Shatterproof glass policy; no glass in production zones

Critical Control Points (CCPs)

Dinweys operates 6 CCPs across the production process. Each CCP is validated, monitored, and documented with corrective action procedures.


CCP 1 — Raw Material Receiving (Pesticide Residues, Heavy Metals)

Element Specification
Critical Limit Supplier COA must show: pesticides ≤ GB 2763 MRL, Pb ≤ 0.1 mg/kg, Cd ≤ 0.1 mg/kg
Target Level Pesticides ≤ 50% of MRL; heavy metals ≤ 50% of limit
Monitoring Method COA verification per lot + annual third-party multi-residue testing (≥ 200 pesticides)
Monitoring Frequency Every incoming lot — 100% inspection
Responsible Incoming QC Inspector
Documentation Incoming Receiving Log, COA file, Certificate of Compliance

Calibration Requirements:

Device Frequency Standard
N/A (COA verification — no instrument)
Reference scales (if sample testing) Weekly ASTM E617 class 2 weights

Corrective Action SOP:

  1. If COA values exceed critical limit → REJECT the entire lot at supplier's cost
  2. If COA values exceed target but are below critical limit → Place on HOLD; request re-test from accredited lab
  3. If re-test passes → Release with documentation
  4. If re-test fails → Reject lot; document in Supplier Non-Conformance Report
  5. If ≥ 2 lots from same supplier rejected in 6 months → Initiate supplier audit or de-listing procedure

Validation Evidence: - Annual third-party pesticide residue testing of raw potatoes (accredited lab) - Supplier audit at least every 12 months for all approved potato suppliers - Historical data review: < 0.5% rejection rate over rolling 12 months

Verification Activities:

Frequency Activity
Daily COA documentation completeness check
Weekly Incoming inspection record review
Monthly Supplier performance scorecard update
Quarterly Trend analysis of COA parameter data
Annually Supplier audit schedule compliance review

CCP 2 — Blanching (Pathogen Reduction)

Element Specification
Critical Limit Water temperature ≥ 85°C at belt entry; product residence time ≥ 3 minutes
Target Level 88–92°C for 3.5–4.5 minutes
Monitoring Method Continuous temperature chart recorder + digital display; manual verification
Monitoring Frequency Continuous recorder logging (1 min intervals) + manual check every 30 min
Responsible Line Operator (manual); Automation System (continuous)
Documentation Blanching temperature chart; shift operator logbook

Calibration Requirements:

Device Frequency Standard
RTD temperature sensors Monthly NIST-traceable probe ±0.1°C
Chart recorder Quarterly Compare against calibrated RTD
Timer/stopwatch (residence time) Monthly NIST-traceable timer
PLC control system Annually OEM calibration service

Corrective Action SOP:

  1. Temperature drop below 85°C detected:
  2. Immediate: Stop product feed; increase steam pressure; check steam trap function
  3. If restored within 2 minutes: Divert product from temp-drop period to re-blanching
  4. If > 2 minutes: Divert to hold tank; record as non-conforming material
  5. Non-conforming product:
  6. Evaluate core temperature of potatoes in hold tank
  7. If core > 65°C for ≥ 2 min → Product may be re-blanched and released
  8. If core < 65°C for duration → Product rejected for human consumption (redirect to animal feed or disposal)
  9. Root cause investigation: Steam supply pressure, boiler function, heat exchanger fouling
  10. Documentation: Deviation Report Form FR-CCP2; corrective action within 24 hours

Validation Evidence: - Challenge study: Inoculated potato strips with Salmonella enterica (10⁷ CFU/g) and E. coli O157:H7 (10⁷ CFU/g); blanching at 88°C for 3 minutes achieved >5 log reduction (validated by [accredited lab, study ref DWF-2022-BL-001]) - Literature reference: Codex Alimentarius CAC/RCP 53-2003; 5-log reduction for vegetative pathogens achieved at 80°C for 2 min


CCP 3 — Par-Frying (Pathogen Survival)

Element Specification
Critical Limit Oil temperature at fryer entry ≥ 160°C
Target Level 160–170°C (cut-dependent); residence time 30–60 seconds
Monitoring Method Automated temperature control (±1°C) + manual verification
Monitoring Frequency Continuous (PLC-controlled) + manual check every 60 minutes
Responsible Fryer Operator (manual); Automation System (continuous)
Documentation Fryer temperature chart; operator temperature log

Calibration Requirements:

Device Frequency Standard
PT-100 temperature probes Monthly NIST-traceable, ±0.5°C
IR temperature gun (manual check) Weekly Blackbody calibration
PLC temperature module Quarterly OEM calibration

Corrective Action SOP:

  1. Temperature drops below 160°C:
  2. If ≤ 1 min: Adjust burner output; wait for recovery; any product in fryer during drop period placed on hold
  3. If > 1 min or recovery not achieved within 2 min: Stop product feed; engage backup heating element
  4. Hold product evaluation:
  5. Measure core temperature of held product
  6. If core temperature > 72°C for ≥ 15 seconds → Product acceptable (pathogen kill achieved)
  7. If core temperature < 72°C → Product rejected for human consumption
  8. Root cause: Gas pressure, burner nozzle maintenance, oil level, heat exchanger fouling
  9. Documentation: Deviation Report FR-CCP3; CAPA initiated

Validation Evidence: - Frying at 160°C for 30 seconds achieves product core temperature ≥ 72°C in 9 mm cut fries (validated by thermocouple insertion study, n=50 samples) - 72°C core temp for 15 seconds is equivalent to 6D reduction for Salmonella (FDA Food Code 2017)


CCP 4 — Metal Detection

Element Specification
Critical Limit Ferrous ≥ 1.5 mm / Non-ferrous ≥ 2.0 mm / Stainless Steel ≥ 2.5 mm
Target Level Ferrous 1.2 mm / Non-ferrous 1.8 mm / Stainless 2.2 mm (rejection at tighter tolerances)
Monitoring Method In-line metal detector with automatic air-blast rejection
Monitoring Frequency Continuous — every pack passes through detector; test using reference spheres every 60 min
Responsible Packaging Line Operator
Documentation Metal detector log (hourly test results + reject count); shift summary

Calibration Requirements:

Device Frequency Standard
Metal detector test (ferrous, non-ferrous, SS spheres) Every 60 min Certified reference spheres traceable to NIST
Metal detector sensitivity Shift start + after any false reject or failure Internal protocol
Full calibration by OEM Annually OEM service report
Reference sphere integrity Quarterly Visual inspection + measurement verification

Corrective Action SOP:

  1. Failed test (detector fails to reject test sphere):
  2. Stop production line immediately
  3. Isolate all product produced since last successful test
  4. Re-inspect isolated product through a functioning metal detector
  5. Recalibrate and verify with test spheres; if pass → resume production
  6. If cannot recalibrate → Switch to standby detector; repair faulty unit
  7. Rejected product from air-blast:
  8. Weekly collection and forensic examination of reject bin
  9. Record type of metal found, size, source (if identifiable)
  10. Trend analysis to identify repeat contamination sources
  11. Documentation: Deviation Report FR-CCP4; monthly reject trend report

Validation Evidence: - Detection sensitivity verified on-site annually by manufacturer service engineer - Product effect compensation: Detector auto-tunes to frozen product signal characteristics - Conveyor speed: 30 m/min max for specified detection limits


CCP 5 — Cold Storage & Transport (Temperature Abuse)

Element Specification
Critical Limit Product core temperature must remain ≤ −18°C at all points in the cold chain
Target Level −20°C to −25°C (cold storage); −18°C to −20°C (transport)
Monitoring Method Temperature data loggers (10-min intervals) + daily visual/manual check
Monitoring Frequency Continuous logging + manual walk-through every shift (daily for weekends)
Responsible Cold Store Supervisor + Logistics Team
Documentation Temperature logger records (downloaded monthly); daily temperature log

Calibration Requirements:

Device Frequency Standard
Cold store temperature sensors (RTD) Quarterly NIST-traceable ±0.5°C
Temperature data loggers Before each shipment Compare against calibrated reference
Handheld IR thermometer Monthly Blackbody calibration
Reefer container temperature gauges Verified at loading Against calibrated logger inserted into container

Corrective Action SOP:

  1. Cold storage temperature deviation:
  2. −18°C but ≤ −15°C for < 2 hours → Alert; investigate root cause (door open, defrost cycle, HVAC failure)

  3. −18°C for > 2 hours OR any excursion above −15°C → Isolate affected product; mark as HOLD

  4. Product evaluation: Check core temperature of representative samples; measure quality parameters
  5. If core temp never exceeded −12°C → Product may be released with risk assessment
  6. If core temp exceeded −12°C → Reject (texture degradation, microbial growth risk)
  7. Transport temperature deviation:
  8. Logger indicates excursion above −15°C → Flag shipment for evaluation at destination
  9. Customer or Dinweys QC evaluates upon arrival
  10. Financial responsibility determined by excursion source (pre-loading vs. en route)
  11. Documentation: Temperature Deviation Report FR-CCP5; root cause analysis

Validation Evidence: - Cold storage mapped annually (24-point temperature mapping for each chamber; 3D temperature distribution analysis) - Shelf-life validation study confirming 24-month stability at −18°C - Temperature abuse study: 24 hours at −10°C → measurable texture degradation (fracture force reduced by 18%)


CCP 6 — Foreign Matter Control (Optical Sorter / Color Sorter)

Element Specification
Critical Limit Ejection of stones, discolored product, foreign matter ≥ 4 mm diameter
Target Level Ejection efficiency ≥ 99.5%
Monitoring Method In-line vision system (visible + NIR cameras) with compressed air ejectors
Monitoring Frequency Continuous + calibration check at shift start + spot check every 30 min
Responsible Sorting Line Operator
Documentation Optical sorter shift log; daily performance report; reject weight recording

Calibration Requirements:

Device Frequency Standard
Camera lens cleaning Every 4 hours Visual check of image clarity
Ejector nozzle test Shift start Manual trigger + visual confirmation of air blast
Color sensitivity check Shift start Use reference color cards (acceptable/reject)
NIR sensor check Weekly Reference material test
Full preventive maintenance Monthly OEM checklist

Corrective Action SOP:

  1. Ejection efficiency below 99.5%:
  2. Stop product feed; run test samples with known defects
  3. Verify camera focus, lighting intensity, air pressure (min 6 bar)
  4. Clean camera lenses; check compressed air line filters
  5. Re-run test; if efficiency restored → resume production
  6. If not restored → Switch to backup sorter; call OEM support
  7. Manual re-inspection of product produced during any sorter malfunction
  8. Documentation: Deviation Report FR-CCP6; maintenance log

Validation Evidence: - Sorter performance validated annually by OEM service engineer - Test samples (calibrated defect colors and sizes) used daily - NIR capability enables detection of clear plastics and stones that visible camera alone would miss


Operational Prerequisite Programs (OPRPs)

OPRP Process Control Measure Critical Limit Monitoring Frequency
1 Potato washing Water pressure ≥ 3 bar + flow rate ≥ 50 L/min per nozzle Residual soil < 0.5% by weight Visual inspection of washed potatoes Every 60 min
2 Blanching time/temp 85–95°C / 3–5 min residence Min 85°C × 3 min Temperature chart review + manual log Continuous + daily review
3 Surface dewatering (post-blanch) Air knife + vibrating screen Surface moisture ≤ 70% (post-dewatering) Infrared moisture check Every 60 min
4 IQF freezing Air temp −35°C to −45°C Core temp ≤ −18°C at tunnel exit Freezer PLC parameters + spot check core temp Continuous + hourly
5 Packaging integrity Heat seal + bag integrity check Seal strength ≥ 15 N/50mm Visual check + leak test (vacuum chamber) Random sample 10 per shift
6 Color sorting Optical sorter with NIR Defect removal ≥ 99.5% Ejection test with known defects Shift start + hourly

Pre-Requisite Programs (PRPs) — Detailed Standards

Each PRP is documented in a standalone SOP with specific standards, monitoring frequencies, and personnel responsibilities.

PRP 1: Facility & Equipment Hygiene

Standard Requirement
Production area classification Clean zone (post-blanch) vs dirty zone (raw receiving). Physical separation with interlocked doors. Air pressure differential: clean zones ≥ +10 Pa
Floor & wall construction Epoxy-sealed concrete; stainless steel cladding to 2 m height; coved corners (50 mm radius)
Drainage Floor drains with P-traps; slope ≥ 2%; drain covers cleanable
Lighting ≥ 500 lux in inspection areas; shatter-proof LED tubes throughout
Cleaning frequency Dry cleaning (sweep/vacuum) hourly; wet cleaning (foam + rinse) daily; deep clean weekly
CIP schedule Blanching line: every production day; fryer oil system: every 7 days; IQF evaporator: monthly
Sanitation efficacy verification Pre-op ATP swab threshold: < 50 RLU; visual inspection approved by QC before line start

Equipment Construction Standards: - All product-contact surfaces: 304 stainless steel minimum (316 for blanching and fryer areas) - No exposed threads, wood, or absorbent materials in production area - Welds: Ground flush, ≤ 0.8 µm Ra surface finish - Conveyor belts: FDA-approved food-grade polyurethane or stainless steel modular

PRP 2: Pest Control

Element Standard
Pest Control Operator (PCO) Licensed third-party company; contract with defined KPIs
Service frequency Monthly full inspection + treatment; weekly in warm season (May–October)
Rodent bait stations Tamper-resistant; outdoor only (no indoor rodenticide in production zones). GPS-mapped. Spacing: outdoor perimeter every 15 m; critical zones every 10 m
Insect light traps (ILTs) UV-A type (320–380 nm); positioned 1.5–2.0 m height; no glue board above food contact surfaces. Monthly board replacement; count log per GB/T 31719
Pheromone traps Stored product moth traps in raw material storage; replaced every 8 weeks
Monitoring targets Rodent activity: 0 inside facility; ILT catch trend monitored — corrective action if > 3 standard deviations above baseline
Exclusions No bird netting failures; no gaps > 6 mm in building envelope
Documentation Pest activity log; corrective actions; trend analysis quarterly

Compliance Reference: AIB International Consolidated Standards for Food Processing Sections 5.0 (Pest Control) and GB/T 31719-2015 (Integrated Pest Management in Food Processing)

PRP 3: Water Quality

Parameter Standard Method Frequency
Residual chlorine (treated plant water) 0.05–0.5 mg/L DPD colorimetric test Daily
Total plate count (process water) < 100 CFU/mL GB/T 5750.12 Weekly
Coliforms (process water) Absent / 100 mL GB/T 5750.12 Weekly
Full potability analysis Meets GB 5749-2022 Third-party accredited lab Annually
Water hardness < 150 mg/L CaCO₃ EDTA titration Monthly

PRP 4: Waste Management

Waste Type Container Disposal Method Frequency
Potato peelings / silt Green bins Sold to animal feed processor (contract) Daily pickup
Defective product (organic) Red bins Compost / anaerobic digestion Daily pickup
Used cooking oil Sealed drums Sold to biodiesel processor (chain of custody) Weekly
Packaging waste (plastic) Yellow baler Recycling contractor Weekly
General waste Black bins Municipal landfill Daily
Hazardous waste (chemical containers) Sealed, labeled Licensed hazardous waste contractor Monthly

PRP 5: Staff Hygiene & Training

Element Requirement
Medical check Annual health certificate per China Food Safety Law
Personal hygiene No jewelry (including wedding bands covered with medical tape); no nail polish; no false nails; hair fully covered by bouffant + beard snood
Handwashing Every entry to production; after restroom break; after touching face; after handling raw materials. Minimum 20 seconds with antibacterial soap
Handwash stations Knee-operated or sensor-operated; at every entrance to production zones
Gowning Color-coded: White = raw zone; Blue = processed zone; Red = maintenance/visitor
Training program General food safety induction (all new hires); HACCP refresher annually; CCP-specific training for operators at each CCP; allergen awareness training annually
Training records Name, date, topic, trainer, test score (pass ≥ 80%)

PRP 6: Maintenance & Calibration

Element Requirement
Preventive maintenance schedule Monthly PM for all critical equipment (blancher, fryer, freezer, metal detector, sorter)
Lubrication Only NSF H1 food-grade lubricants in production areas
Calibration program All monitoring/measuring devices calibrated against NIST-traceable standards per defined frequency
Maintenance hygiene All maintenance activities in production zones logged; post-maintenance cleaning and pre-op inspection required
Spare parts management Critical spares (motors, belts, sensors, metal detector test spheres) stocked on-site
Work order system Digital work order for every PM and corrective maintenance action
Contractor control Contractors receive food safety briefing before entering production; supervised at all times in clean zones

PRP 7: Allergen Management

Element Detail
Allergen status Dinweys French fries — No intentionally added allergens per EU/China/FDA regulations
Risk assessment Cross-contamination risk from shared equipment: LOW (single product type — french fries only; no shared lines with allergen-containing products)
Incoming ingredient verification All raw materials receive COA confirming allergen status
Changeover procedure NOT required for standard production (single product category); required only if processing test runs with alternative coatings
Cleaning validation If alternative coating processed: visual inspection + ELISA swab testing (gluten, milk, egg) before resuming standard production
Labeling control Pre-production label verification against pack specification; labels reconciled and counted
Supplier approval Allergen management capability reviewed during supplier approval and audits

Environmental Monitoring Program (Listeria spp.)

Dinweys operates a comprehensive environmental monitoring program focused on Listeria spp. detection in the post-blanch processing environment. The program follows the principles of the International Commission on Microbiological Specifications for Foods (ICMSF) and FSMA Preventive Controls requirements.

Environmental Sampling Zones

Zone Description Examples Sampling Frequency
Zone 1 Direct food contact surfaces Freezer belts, cutting blades, fryer conveyor, packaging chutes Weekly (12 sites)
Zone 2 Non-food contact surfaces adjacent to food Equipment frames, control panels near product, drain covers in production Weekly (15 sites)
Zone 3 Floor and walls in production zones Floor drains, walls, structural supports, columns Weekly (20 sites)
Zone 4 Areas outside production (transition zones) Changing rooms, corridor floors, forklift wheels, entry mats Monthly (30 sites)

Sampling Protocol

Parameter Specification
Collection tool Sterile sponge swab (10×10 cm template for flat surfaces; defined area for irregular surfaces)
Neutralizer D/E Neutralizing Broth (lethicin, polysorbate 80, sodium thiosulfate, sodium bisulfite)
Transport Cooler with ice packs; analysis within 4 hours of collection
Method AOAC 2017.06 / VIDAS LMO2 (ELFA) or equivalent
Limit of detection Positive/negative per sample site
Confirmation Any positive — confirmed via ISO 11290-1 or FDA BAM Chapter 10

Corrective Action Protocol for Listeria spp. Positives

Zone Positive result action
Zone 1 Immediate line stop; segregate and hold product produced since last negative swab; intensified cleaning of affected surface; re-swab after cleaning (must be negative × 2 consecutive rounds); product released only after risk assessment by Food Safety Team
Zone 2 Intensified cleaning of affected surface and adjacent zone 1 surfaces; re-swab within 24 hours × 2 consecutive negatives; review cleaning procedure adequacy
Zone 3 Deep cleaning of affected area (walls + floors); review traffic patterns, drainage flow, condensate management; corrective cleaning + re-swab within 48 hours
Zone 4 Enhanced cleaning; review traffic flow; increase monitoring frequency to weekly; ensure hygiene barriers effective

Performance Targets

Metric Target
Zone 1 positive rate < 1% of samples
Zone 2 positive rate < 3% of samples
Zone 3 positive rate < 5% of samples
Time to confirm a positive ≤ 24 hours from sampling
Corrective action closure ≤ 48 hours from confirmed positive

Key Insight: Environmental monitoring data is the single best leading indicator of process hygiene. A Zone 3 positive that migrates to Zone 2 and then Zone 1 over several weeks is the classic precursor pattern to a finished product Listeria positive. Dinweys reviews zone 2 and 3 positives as seriously as zone 1 — they are the early warning system.


Food Safety Culture — Measurable Framework

Food safety culture is defined by GFSI as "shared values, beliefs, and norms that affect mindset and behavior toward food safety." Dinweys measures culture through five dimensions:

Culture Dimension Matrix

Dimension Metric Target Measurement Method Frequency
Leadership Commitment Management review meetings held 100% Calendar review Annual
Food safety budget allocation ≥ 2% of operating cost Financial review Annual
CEO/Plant Manager walk-throughs ≥ 1 per month Sign-off log Monthly
Employee Engagement Training hours per employee ≥ 12 hours/year Training records Annual
Food safety suggestion submissions ≥ 5 per 100 employees/month Suggestion system Monthly
CCP deviation reporting rate (staff-initiated) ≥ 95% Deviation log review Monthly
Communication Pre-shift briefings held 100% of production days Briefing log Daily
Food safety alerts communicated Within 24 hours Alert distribution log Per event
Performance Measurement CCP compliance rate ≥ 99.5% Monitoring data analysis Weekly
CAPA closure rate (on time) ≥ 90% CAPA tracking system Monthly
Non-conformance trend reduction Year-on-year reduction Trend analysis Quarterly
Corrective action closure rate ≥ 95% within target date CAPA database Monthly
Continuous Improvement Internal audit non-conformance trend Year-on-year reduction Audit database Semi-annual
Third-party audit score improvement Year-on-year improvement Audit reports Annual
Mock recall completion time reduction Year-on-year reduction Mock recall records Annual

Culture Survey

Annual anonymous food safety culture survey (adopted from GFSI food safety culture model):

Survey Domain Target Score Scoring
Risk awareness ≥ 4.0 / 5.0 1 = low, 5 = highest
Management commitment perception ≥ 4.0 / 5.0
Employee empowerment ≥ 3.8 / 5.0
Accountability ≥ 4.0 / 5.0
Communication openness ≥ 3.8 / 5.0

CAPA (Corrective and Preventive Action) System

CAPA Process Flow

Issue Identified
    ↓
Problem Description (what, when, where, who, extent)
    ↓
Immediate Containment (stop the bleed — isolate, segregate, rework, reject)
    ↓
Root Cause Analysis (RCA)
    ↓
Corrective Action (fix the root cause)
    ↓
Verification of Effectiveness (did it work?)
    ↓
Preventive Action (how to prevent recurrence across the system)
    ↓
Closure (documentation complete, trend added)

Root Cause Analysis Methodology

Dinweys uses three RCA tools, selected based on issue complexity:

Method Best For Example Application
5-Why Simple to moderate issues; single-failure-path "Temperature sensor failed → Why? → Not calibrated → Why? → No calibration reminder set → Why? → ..."
Fishbone (Ishikawa) Diagram Complex issues with multiple contributing factors Cross-contamination event: consider People, Equipment, Method, Material, Environment dimensions
Barrier Analysis Issues involving procedural or physical barriers Metal detector failure → analyze what barriers should have caught it (screens, magnets, visual checks)

CAPA Prioritization

Priority Definition Response Time Review Level
Critical Food safety risk; regulatory issue; serious customer complaint 24 hours Food Safety Team + Plant Manager
High Quality deviation affecting > 5% of production; repeat NCR 72 hours QA Manager + Production Manager
Medium Minor quality deviation; procedural non-conformance 7 days QA Supervisor
Low Observation; improvement suggestion 30 days Designated CAPA owner

CAPA Record Fields

Field Description
CAPA ID Auto-generated (CAPA-YYYY-XXX)
Source Audit, complaint, deviation, internal inspection, trend analysis
Problem description What, when, where, extent (quantity affected)
Immediate containment Action taken to limit damage
Root cause (5-Why / Fishbone) Narrative with methodology noted
Corrective action What was done; who; by when
Verification Evidence of effectiveness (data, follow-up audit, repeat check)
Preventive action Systemic change to prevent recurrence
Closure date Actual closure date
Trends Linked to CAPA trending database for monthly review

Supplier Approval Program

Supplier Tiering

Tier Supplier Type Approval Requirements Audit Frequency
1 Raw potato suppliers (direct farms / cooperatives) GAP certification or equivalent; signed quality agreement; initial site audit Annually
2 Key ingredient suppliers (oil, dextrose, SAPP, coating materials) ISO 22000/HACCP certification; certificate of analysis per lot; initial document review Every 2 years (on-site) or document review annually
3 Packaging suppliers (bags, cartons, pallets) Food-grade packaging certification; letter of guarantee Every 3 years (document review)
4 Service providers (pest control, lab testing, maintenance) Relevant certification; insurance; contract with defined KPIs Document review at contract signing + annual KPI review

Supplier Approval Process

  1. Pre-qualification questionnaire — Food safety capability, certifications, production capacity, food defense
  2. Document review — Certificates, COAs, product specifications
  3. Initial audit — On-site (Tier 1 & 2) or desk audit (Tier 3 & 4)
  4. Sample testing — Three consecutive lots tested to specification
  5. Trial approval — If samples pass, one production trial lot
  6. Approved Supplier List (ASL) — Formal addition to ASL with score

Supplier Scoring System

Category Weight Scoring (1–5)
Product quality (COA compliance) 30% 5 = consistently exceeds spec; 1 = frequent deviations
Food safety certification 20% 5 = GFSI cert; 3 = HACCP only; 1 = no certification
Delivery performance 15% 5 = on-time > 98%; 1 = on-time < 85%
Corrective action responsiveness 15% 5 = CA within 7 days with root cause; 1 = no response
Price competitiveness 10% 5 = market-leading; 1 = > 15% above market
Audit score 10% 5 = no major non-conformances; 1 = critical findings

Scoring bands: - A (85–100): Preferred supplier — no restrictions - B (70–84): Approved — continue with improvement plan - C (60–69): Conditional — increased monitoring; corrective action plan required - D (< 60): Not approved / de-listed

Non-Conforming Supplier Procedure

  • First non-conforming lot: Notification + request for corrective action (CAPA)
  • Second non-conforming lot (within 6 months): On-site or desk audit
  • Third non-conforming lot (within 12 months): De-listing with 30-day notice; source from alternative supplier

Internal Audit Program

Audit Schedule & Scope

Audit Type Frequency Scope Duration
Full system audit Annually All clauses of ISO 22000 + HACCP + PRPs + FSSC requirements 3–4 days
HACCP audit Semi-annually CCPs, OPRPs, monitoring records, deviation handling 1–2 days
PRP audit Quarterly All PRPs (each PRP at least once per year) 1 day per PRP area
GMP walk-through Weekly Facility condition, hygiene, pest control, personnel practices 2 hours
Preventive controls verification Monthly Process control records, calibration, environmental monitoring 1 day
Supplier audit (internal) Per supplier schedule Per tier frequency above 1–2 days (site) or 0.5 day (desk)

Audit Checklist Coverage Areas (Full System)

Area Number of Checklist Items
Management system & documentation 25
HACCP plan & CCP verification 40
PRP compliance (all 8 PRPs) 60
Environmental monitoring 15
Traceability & recall 10
Food defense & food fraud 15
Supplier management 15
Training & competence 10
Non-conformance & CAPA 15
Calibration & maintenance 10
Total 215

Auditor Qualification Requirements

Requirement Internal Auditor Lead Auditor
ISO 22000 Lead Auditor training Preferred ✅ Required
HACCP training (Codex Alimentarius) ✅ Required ✅ Required
Food industry experience ≥ 2 years ≥ 5 years
Audit observation / co-audit ≥ 2 audits as observer ≥ 4 audits as lead
Refresher training Every 3 years Every 3 years
Independence Not auditing own area Not from same department

Management Review (ISO 22000:2018 Clause 9.3)

Frequency

  • Full management review: Semi-annual (every 6 months)
  • Interim review: Quarterly (if significant issues arise or production exceeds 75% capacity)
  • Ad-hoc review: Triggered by critical incident (recall, serious food safety event, major regulatory change)

Required Inputs (per ISO 22000 clause 9.3)

Input Responsible Frequency
Status of actions from previous management reviews QA Manager Each review
Changes in external and internal issues Plant Manager Annually (or as needed)
Information on food safety performance:
— Non-conformities and corrective actions QA Manager Each review
— Customer complaints and feedback Sales / QA Each review
— Audit results (internal + third-party) QA Manager Each review
— Monitoring and measurement results (CCP, OPRP, PRP) QA Manager Each review
— Environmental monitoring results Micro Lab Each review
— Supplier performance Purchasing / QA Each review
— Food safety culture KPIs HR / QA Each review
Results of verification activities QA Manager Each review
Emergency situations and incidents (recalls, withdrawals) Plant Manager Each review
Review of resource adequacy Plant Manager Each review
Opportunities for improvement All Each review

Required Outputs

Output Description Example
Improvement opportunities Specific FSMS improvement actions "Revise PRP-2 pest control SOP to increase ILT inspection in raw storage"
Resource needs Budget, personnel, equipment "Approve budget for backup IQF compressor"
FSMS policy update needs Policy revisions required "Update food safety policy to reference FSSC v6 requirements"
Objectives update Food safety objectives for upcoming period "Reduce zone 1 environmental positives from 1.2% to < 0.8%"

Management Review Meeting Format

  • Chair: Plant Manager / General Manager
  • Attendees: QA Manager, Production Manager, Logistics Manager, Purchasing Manager, Maintenance Manager, HR Manager, Food Safety Team Leader
  • Duration: 2.5–3 hours (full review); 1 hour (interim)
  • Documentation: Agenda circulated 1 week in advance; minutes distributed within 2 weeks; action items tracked in CAPA system

Allergen Risk Assessment

Dinweys Allergen Status

Allergen (per EU Reg 1169/2011, China GB 7718, US FALCPA) Present as Ingredient Cross-Contact Risk Risk Level
Gluten / Wheat No Low (single-product facility) ✅ Low
Crustaceans No None ✅ None
Eggs No None ✅ None
Fish No None ✅ None
Peanuts No None ✅ None
Soybeans No None (soy oil is refined — exemption applies) ✅ None
Milk / Lactose No None ✅ None
Nuts No None ✅ None
Celery No None ✅ None
Mustard No None ✅ None
Sesame No Low (vehicles may carry sesame from other loads) ✅ Low
Sulphites (>10 mg/kg) No (SAPP not a sulphite) None ✅ None
Lupin No None ✅ None
Molluscs No None ✅ None

Cleaning Validation for Allergen Control

While Dinweys is a single-product facility (french fries), allergen cross-contact risk is assessed for:

  1. Incoming raw materials received on shared delivery vehicles: COA for each lot confirms no allergen contamination
  2. Test runs with alternative coatings (e.g., wheat flour coating for customer trials):
  3. Dedicated equipment or full line deep clean after trial
  4. ATP swab (threshold < 50 RLU) + ELISA swab for specific allergen (e.g., gluten < 5 ppm)
  5. Visual inspection of all surfaces
  6. First 50 kg of standard product post-trial tested for allergen residue before release

Changeover Procedure (Coated to Uncoated)

Step Action Verification
1 Stop line; clear all product from conveyors, applicator, fryer, freezer Visual inspection
2 Dry cleaning: vacuum all loose coating material Vacuum cleaner with HEPA filter
3 Wet cleaning: foam detergent + brush all coating-contact surfaces Visual + ATP swab
4 Rinse thoroughly; verify pH neutral pH test paper (6.5–7.5)
5 Pre-op inspection by QC — approve line start Signed pre-op checklist
6 First 100 kg of run = "flushing product" — segregate and evaluate Visual inspection + sorting

Traceability System

One-Step-Forward, One-Step-Backward

Dinweys maintains full traceability in accordance with ISO 22000 clause 8.3 and China Food Safety Law Article 42:

Direction Data Captured Method Time Requirement
Backward (supplier → factory) Raw material lot number, supplier name, delivery date, quantity, COA reference, storage location ERP lot tracking system (SAP Business One) < 2 hours
Forward (factory → customer) Finished product lot code, production date and time, QC release reference, customer name and shipment number, quantity ERP system + batch release record < 2 hours

Traceability Test

Parameter Specification
Frequency Semi-annual (minimum) + after any major system change
Method Select one finished product lot code — trace back to supplier raw material lots and forward to customer shipment
Target completion time 4 hours maximum (actual average: 2.1 hours)
Acceptance criteria 100% traceability — all links identified; no gaps in the chain
Corrective action if failed CAPA initiated; re-test within 2 weeks; root cause investigation

Lot Coding System

Format: YYMMDD-PRODUCT-SHIFT-LINE-BATCH

Example: 250728-SS-A-1-003

Segment Meaning Characters
250728 Production date (July 28, 2025) 6
SS Product code (SS = Shoestring, MC = Medium Cut, CC = Crinkle Cut, CF = Coated Fries, …) 2
A Shift (A = day 07:00–15:00, B = evening 15:00–23:00, C = night 23:00–07:00) 1
1 Processing line number 1
003 Sequential batch number for the day (reset daily) 3

Recall & Crisis Management Procedure

Recall Classification

Class Risk Action Timeline Example Regulatory Notification
Class I Serious health risk or death Within 24 hours — public notification + full recall Salmonella contamination, Listeria in finished product Notify local FDA (China SAMR) + destination market authority
Class II Potential health risk, not life-threatening Within 48 hours — targeted recall Excessive heavy metals, undeclared allergen, labeling error that could cause allergic reaction Notify regulatory authority
Class III Unlikely to cause adverse health effects Within 72 hours — market withdrawal Minor quality deviation, temperature abuse without safety risk, cosmetic defect Document withdrawal; no regulatory notification required in most markets

Recall Procedure — Step by Step

  1. Detection: Quality issue identified via COA, customer complaint, regulatory notification, or routine testing
  2. Assessment: Food Safety Team evaluates risk level within 2 hours
  3. Form initial recall team: QA Manager (lead), Production Manager, Logistics Manager, Sales Manager
  4. Containment:
  5. Immediate quarantine of suspect finished product lot(s) in cold storage (designated "HOLD" area, padlocked or keycard-restricted)
  6. Check WIP (work-in-process) — if product from same raw material batch still in line or in storage, quarantine that too
  7. Notification (within timeframes above):
  8. Internal: General Manager + all department heads
  9. External: Customer(s) — provide lot code, quantity, nature of issue, proposed disposition
  10. Regulatory: Local Market Supervision Bureau (China); destination market authority if export
  11. Certification body: CB (certification body) notified within 72 hours if recall affects certified products
  12. Recovery:
  13. Coordinate return of affected product (Dinweys logistics or customer arrangement)
  14. Quarantine returned product at Dinweys cold storage
  15. Disposition options: rework (if applicable), redirect to animal feed, incineration, landfill with supervision
  16. Root cause investigation: CAPA with 5-Why or Fishbone analysis; completed within 30 days
  17. Preventive action: Systemic changes implemented; effectiveness verified
  18. Mock recall: Conducted annually — results presented at management review

Mock Recall Performance Targets

KPI Target 2025 Performance
Time to assemble recall team < 1 hour 42 min average
Time to identify all affected lot codes < 2 hours 1.3 hours average
Time to contact all customers < 4 hours 3.1 hours average
Traceability completeness 100% 100%
Time to complete mock recall report < 48 hours 32 hours average

Document Hierarchy

Level 1: Food Safety Policy Manual (FSM-001)
Level 2: HACCP Plan (HACCP-001) + Operational Procedures (SOPs)
Level 3: Work Instructions (WI-XXX) + Product Specifications (SPEC-XXX)
Level 4: Records (COAs, temperature logs, training records, audit reports, E-swab results)

Document Control

Element Procedure
Document numbering TYPE-XXX (e.g., SOP-023, WI-012, FORM-045)
Review cycle Every 12 months or after significant process change
Approval QA Manager approves; Plant Manager signs off on Level 1 & 2 documents
Obsolete document handling Remove from circulation; archive with "OBSOLETE" watermark for minimum 5 years
Electronic control All documents in centralized digital repository (read-only for production floor; controlled access)
Change history Each document includes revision number, date of change, description of change, approver

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