Welcome to
this page. I hope, as always, that the information presented
here is of interest to you.
Despite the
great diffusion that has been made worldwide of management system based on standards, it is common for people involved with this type
of system, such as those responsible
for part of the organizations, members of top management, as well as internal
auditors, and for other organizations, as external
auditors and evaluators of certification or accreditation
bodies, even though they have participated in training
programs, do not know nor comprehend all requirements of these standards. That is why we have given ourselves the task of individually
identifying each of the requirements that derive from the different clauses, sub-clauses and sections of these standards.
In the
previous entries we dealt with requirements corresponding to Section
5.2.1-Establishing the food safety policy, and we did it in two parts, due to the importance and complexity of the requirements derived from said section. In this entry, as Part 3 of Sub-clause 5.2 –
Policy, we will deal with requirements
that derive from Section
5.2.2 – Communicating of the food safety policy.
As I have
explained to you in a previous entry, the food safety policy is the most important element of a food safety
management system (FSMS), because all
the processes and activities carried
out by the organization within that FSMS will be to meet the aforementioned food safety
policy. That is why in this group of requirements derived from Section
5.2.2 of the standard, all of them refer to this food safety
policy, specifying how, and to whom, this element of the food safety
management system should be communicated.
In this Section 5.2.2, the ISO 22000:2018 standard establishes the following requirements, and I present them to you with the corresponding
progressive numbering, as I have been presenting, individually, all requirements of this standard that have been analyzed:
If we consider this list, our next requirement to analyze is the following:
Requirement No. 80: The food safety
policy shall be available as documented information.
What this requirement indicates is that when top management establishes the food safety policy, it should do so as documented
information, that is, in addition to containing all the elements required
by Section 5.2.1 - Establishing the food safety policy, it should have all the identification elements
that the organization itself has established in accordance with Subclause 7.5 Documented information, mainly with Section
7.5.2 - Creation and updating, such as
those related to identification and description, format and support medium, as
well as the review and approval with respect to suitability and adequacy, as
well as, as it is a controlled document, it must comply with the provisions of Section 7.5.3 – Control of documented information.
Requirement No. 81: The food safety policy shall be maintained as documented information.
In accordance
with this requirement, top management should ensure that when it takes all the actions
necessary to maintain the food safety policy and determines that it continues to be appropriate for the purpose and context of the organization, it complies with all the required elements, regardless of adjustments or
modifications that may have suffered, this maintained food safety policy should also be
maintained as documented
information, also complying with sections
7.5.2 and 7.5.3.
Interestingly,
the Technical Specification TS 9002:2016 - Quality
management systems — Guidelines for the application of ISO 9001:2015, in relation to this Section
5.2.2 Communicating the food safety policy, mentions that in order to
maintain the food safety policy, the organization should review it periodically to determine if it
is still appropriate to the purpose of the organization. This recommendation is misplaced, since if you
remember, in the first paragraph of Section 5.2.1 –
Establishing the food safety policy, there is a requirement for top management shall maintain the food safety policy.
As I have
previously mentioned, we should be very careful when reading and analyzing
these requirements to avoid confusion, mistakes or misinterpretation,
which will inevitably lead us to non-compliance with the standard. What this particular requirement refers to is not that the food safety policy is maintained, which was already established in the requirement mentioned previously, but that when the organization maintain such food safety policy, it should also maintain it as documented
information.
Requirement No. 82: The food safety
policy shall be
communicated at all levels within the organization.
The intent of
this requirement, according to TS 9002:2016, with its corresponding adjustment to ISO 22000, is to ensure that the food safety policy is communicated
to all persons in the organization, at all levels, so they are able to contribute to
the effectiveness of the food safety
management system. This food safety policy can be communicated by different methods such as
via noticeboards, screensavers, the organization's website, or during routine meetings. Sufficient
evidence should be generated so that the
organization is able to demonstrate that the food safety policy has been communicated throughout the organization.
It is
important that for communication of
the food safety policy, what the organization has established in accordance with Sub-clause 7.4 - Communication of the ISO 22000:2018 Standard is complied with.
Requirement No. 83: The food safety policy shall be understood at all levels within the organization.
The intention
of this requirement is to ensure
that all people in the organization understand the food safety policy, so that they are able to contribute to the effectiveness of the FSMS.
The organization needs to ensure that the food safety policy is clearly understood throughout the organization. This can be achieved by taking into account the requirements of Sub-clauses 7.3 -
Awareness and 7.4 - Communication
of ISO 22000:2018, of all people of all different levels of the organization.
The organization can use different mechanisms to achieve the understanding of the food safety policy by people, such as informative meetings, workshops,
seminars, evaluations, among others, generating sufficient evidence that this policy has been understood by all organization staff.
Requirement No. 84: The food safety policy shall be applied at all levels within the organization.
Top management should ensure that all elements of the food safety policy, both the intentions and direction, are being
applied regularly by the entire organization.
It is
important to remember that in order to fulfill the purpose of the organization, all
processes and activities that are carried out in the operation of the food safety
management system should be oriented to comply with the food safety policy, to achieve the food safety objectives.
For this, top
management should ensure
that the specified activities and controls are carried out and that the
appropriate follow-up is given to all processes,
to generate sufficient evidence that the food safety policy is being applied.
Requirement No. 85: The food safety policy shall be available to relevant interested parties, as appropriate.
The intent of
this
requirement is for the organization to ensure that the food safety policy is available to relevant interested parties.
The organization should make the food safety policy, as appropriate, available to relevant interested parties, such as external providers, partners,
customers, and regulatory agencies.
This can be
done on demand, or by publishing the food safety policy on a web page.
In the next entry we will
continue with the analysis of requirements derived from Section 5.3 – Organization
roles, responsibilities and authorities, of this ISO 22000:2018 Standard.
I will be
grateful to the readers who upload their doubts or comments on this analysis in
this blog.
Author:
Ernesto Palomares Hilton
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