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.
| 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:
- If COA values exceed critical limit → REJECT the entire lot at supplier's cost
- If COA values exceed target but are below critical limit → Place on HOLD; request re-test from accredited lab
- If re-test passes → Release with documentation
- If re-test fails → Reject lot; document in Supplier Non-Conformance Report
- 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:
- Temperature drop below 85°C detected:
- Immediate: Stop product feed; increase steam pressure; check steam trap function
- If restored within 2 minutes: Divert product from temp-drop period to re-blanching
- If > 2 minutes: Divert to hold tank; record as non-conforming material
- Non-conforming product:
- Evaluate core temperature of potatoes in hold tank
- If core > 65°C for ≥ 2 min → Product may be re-blanched and released
- If core < 65°C for duration → Product rejected for human consumption (redirect to animal feed or disposal)
- Root cause investigation: Steam supply pressure, boiler function, heat exchanger fouling
- 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:
- Temperature drops below 160°C:
- If ≤ 1 min: Adjust burner output; wait for recovery; any product in fryer during drop period placed on hold
- If > 1 min or recovery not achieved within 2 min: Stop product feed; engage backup heating element
- Hold product evaluation:
- Measure core temperature of held product
- If core temperature > 72°C for ≥ 15 seconds → Product acceptable (pathogen kill achieved)
- If core temperature < 72°C → Product rejected for human consumption
- Root cause: Gas pressure, burner nozzle maintenance, oil level, heat exchanger fouling
- 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)
| 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:
- Failed test (detector fails to reject test sphere):
- Stop production line immediately
- Isolate all product produced since last successful test
- Re-inspect isolated product through a functioning metal detector
- Recalibrate and verify with test spheres; if pass → resume production
- If cannot recalibrate → Switch to standby detector; repair faulty unit
- Rejected product from air-blast:
- Weekly collection and forensic examination of reject bin
- Record type of metal found, size, source (if identifiable)
- Trend analysis to identify repeat contamination sources
- 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:
- Cold storage temperature deviation:
-
−18°C but ≤ −15°C for < 2 hours → Alert; investigate root cause (door open, defrost cycle, HVAC failure)
-
−18°C for > 2 hours OR any excursion above −15°C → Isolate affected product; mark as HOLD
- Product evaluation: Check core temperature of representative samples; measure quality parameters
- If core temp never exceeded −12°C → Product may be released with risk assessment
- If core temp exceeded −12°C → Reject (texture degradation, microbial growth risk)
- Transport temperature deviation:
- Logger indicates excursion above −15°C → Flag shipment for evaluation at destination
- Customer or Dinweys QC evaluates upon arrival
- Financial responsibility determined by excursion source (pre-loading vs. en route)
- 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:
- Ejection efficiency below 99.5%:
- Stop product feed; run test samples with known defects
- Verify camera focus, lighting intensity, air pressure (min 6 bar)
- Clean camera lenses; check compressed air line filters
- Re-run test; if efficiency restored → resume production
- If not restored → Switch to backup sorter; call OEM support
- Manual re-inspection of product produced during any sorter malfunction
- 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 |
| 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
- Pre-qualification questionnaire — Food safety capability, certifications, production capacity, food defense
- Document review — Certificates, COAs, product specifications
- Initial audit — On-site (Tier 1 & 2) or desk audit (Tier 3 & 4)
- Sample testing — Three consecutive lots tested to specification
- Trial approval — If samples pass, one production trial lot
- 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
- 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)
| 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%" |
- 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:
- Incoming raw materials received on shared delivery vehicles: COA for each lot confirms no allergen contamination
- Test runs with alternative coatings (e.g., wheat flour coating for customer trials):
- Dedicated equipment or full line deep clean after trial
- ATP swab (threshold < 50 RLU) + ELISA swab for specific allergen (e.g., gluten < 5 ppm)
- Visual inspection of all surfaces
- 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
- Detection: Quality issue identified via COA, customer complaint, regulatory notification, or routine testing
- Assessment: Food Safety Team evaluates risk level within 2 hours
- Form initial recall team: QA Manager (lead), Production Manager, Logistics Manager, Sales Manager
- Containment:
- Immediate quarantine of suspect finished product lot(s) in cold storage (designated "HOLD" area, padlocked or keycard-restricted)
- Check WIP (work-in-process) — if product from same raw material batch still in line or in storage, quarantine that too
- Notification (within timeframes above):
- Internal: General Manager + all department heads
- External: Customer(s) — provide lot code, quantity, nature of issue, proposed disposition
- Regulatory: Local Market Supervision Bureau (China); destination market authority if export
- Certification body: CB (certification body) notified within 72 hours if recall affects certified products
- Recovery:
- Coordinate return of affected product (Dinweys logistics or customer arrangement)
- Quarantine returned product at Dinweys cold storage
- Disposition options: rework (if applicable), redirect to animal feed, incineration, landfill with supervision
- Root cause investigation: CAPA with 5-Why or Fishbone analysis; completed within 30 days
- Preventive action: Systemic changes implemented; effectiveness verified
- Mock recall: Conducted annually — results presented at management review
| 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 |
← Back to Quality Control