Chapter 3, subject 4
QMP Reference Standard and Compliance Guidelines
Section 6

6. Verification and Maintenance of the QMP Plan

Reference Standard Requirements:

6.1 Processors are required to perform the following verification activities to ensure that their QMP Plan is functioning correctly.

6.1.1 Before implementation the processor is required to validate the critical limits of CCPs.

6.1.2 Before implementation the processor is required to review the QMP Plan to ensure that all of the necessary controls are in place and that it meets the requirements of the Reference Standard.

6.1.3 Once the QMP Plan is implemented the processor is required to perform routine verification of the HACCP Plan to ensure it is functioning effectively.

6.1.4 Once the QMP Plan is implemented the processor is required to verify or validate any changes to the QMP Plan or to critical limits that may occur in the ongoing development of the QMP Plan.

6.1.5 Once the QMP Plan is implemented the processor is required to review the QMP Plan at least once per year.

6.1.6 To ensure that the QMP Plan is accurately documented, processors are required to maintain a list of amendments of any changes to their QMP Plan.

Intent:

The QMP Plan is a dynamic document and verification is a systematic and comprehensive approach to ensure continuous maintenance and improvement to the QMP Plan in order to confirm that the QMP meets the needs of the fish processor in producing a safe, wholesome, fairly traded product.

Compliance Guidelines:

There are five main activities that a processor is required to perform to verify the QMP Plan.

Before implementation of the QMP Plan, the processor is required to:

1. Validate the critical limits for all identified Critical Control Points. The processor must obtain supportive evidence or documentation to confirm that the parameters of the critical limit for each CCP are sufficient to prevent, eliminate or reduce to an acceptable level, food safety hazards in the final product. There are two components to this supportive evidence or documentation:

• sound and reliable scientific evidence, standards from an accepted authority, advice from an accepted authority, or a regulatory standard to demonstrate that the process, if operated within the established critical limits, will result in a safe product, and
• sufficient technical data, gathered through testing and measurement of the process in a processing establishment, to demonstrate that the process can operate within the chosen critical limits.

2. Review the QMP Plan to ensure that it complies with the requirements of the Reference Standard. This includes:

• reviewing the Prerequisite and RAP Plans to confirm that all the necessary controls and documentation are in place. This includes the strategy for monitoring, the taking of records when required, and the implementation of appropriate corrective actions, as outlined in the QMP Plan; and
• reviewing the HACCP Plan to confirm that all the necessary controls and documentation are in place. This includes the strategy for monitoring and recording at CCP, the implementation of appropriate corrective actions, and the verification of the HACCP Plan to ensure the system is working effectively.

Once the QMP Plan is implemented, the processor is required to:

3. Perform routine verification procedures to confirm that the HACCP system is working effectively (HACCP principle 6). For CCP verification, the processor must complete independent tests, measurements, sampling, review of monitoring procedures and records etc., as necessary and at an appropriate frequency, to verify that the control measures implemented at each CCP are effective and being implemented as described in the plan.

4. Re-validate QMP controls or CCP critical limits as changes are made to raw materials, products, processes, equipment, or in response to adverse review findings, recurring deviations, new information on hazards or control measures, on-line observations, and/or new distribution or consumer handling practices where potential hazards may be encountered.

5. Review the QMP Plan, at least once per year, including:

• verifying the HACCP Plan, to confirm that it is complete, accurately reflects current products and processes (product descriptions, process flow, and establishment layout), has effective controls over the significant hazards, and the monitoring of the critical limits is at a frequency sufficient to ensure that products remain in compliance. This verification should include, as appropriate, product sampling and testing, a review of process deviations, corrective actions, audit findings, and consumer complaints. The HACCP Plan is also verified following a system failure or, when there is a significant change in the product or process.
• conducting a review of the QMP Plan, including Prerequisite and RAP Plans, to confirm that these programs are complete and functioning effectively. Verification activities for the Establishment Environment Program can use a combination of visual observation, record review, surface swabs or other methods of microbiological analysis of surfaces such as contact plates, or ATP (adenosine triphosphate) bioluminescence. Mock recall exercises are effective verification of the traceability system. Verification of the RAP Programs can include product and incoming material testing and label inspection at atypical inspection points or using more stringent sampling regimes.

This review would confirm that all corrective actions, problems and consumer complaints have been evaluated to ensure the results were effective and that all amendments and other required written changes have been made to the QMP Plan.

The processor should consider the yearly operating schedule in order to best schedule the annual review of the QMP Plan. Some verification activities require the establishment to be in typical production mode in order to assess (for example, swab samples for microbiological analysis), whereas some verification activities, such as equipment calibrations may better be scheduled during shutdown periods. All elements of the QMP Plan should be reviewed in the course of each year, however, each element need not be reviewed simultaneously. The QMP Plan should describe the schedule and method by which each element will be reviewed.

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