haccp manual 03

7/30/2019 Haccp Manual 03

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T3A INDUSTRIAL

HACCP MANAUAL Issue number: 03 Page 1 of 21

TABLE OF CONTENT

1. Definitions .... 2

2. Prerequisite programs ....... 4

3. Purpose ..... 5

4. Scope . 6

5. Issuing and updates .. 7

6. T3A HACCP certificate according to ISO 22000:2005 .. 8

7. T3A HACCP Policy . 9

8. HACCP Control ... 10

9. HACCP objectives and Targets 16

10. HACCP Management Programs .. 16

11. Organizational structure and responsibility . 16

12. Training, Awareness and competence . 17

13. Communication & Consultation ... 17

14. HACCP Management system documentation . 17

15. Document Control 18

16. Operational control .. 18

17. Recall procedures 19

18. Monitoring and measurements 19

19. Corrective actions ... 20

20. Records and record managements .. 2021. HACCP System Verification .. 21

Prepared by: HACCP rep. Reviewed by: QA manager Approved by: Plant manager

Mohamed Elassady Ahmed Salah Sumit Kumar Shrivastava

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1. Definitions:

1.1. Certification:Action by a third party demonstrating that adequate confidence is provided that a duly

identified product, process or service is in conformity with a specific standard or other

nonnative document. (ISO/JEC Guide 2)

1.2. Control Measure:

Any action and activity that can be used to prevent or eliminate a food or drug safety hazard or

reduce it to an acceptable level.

1.3. Corrective Action:

Any action to be taken when the results of monitoring at the CCP indicate a loss of control.

1.4. Critical Control Point (CCP):

A step at which control can be applied and is essential to prevent or eliminate a food safety

hazard or reduce it to an acceptable level.

1.5. Critical Limit:

A criterion, which specifies the acceptability and unacceptability.

1.6. Decision Tree:

A systematic sequence of questions to be asked to determine where the CCPs are.

1.7. Organization:

Organizations concerned with the food or drug chain from primary production, processing,

packaging, storage and distribution until the point of consumption.

1.8. Deviation:

Violation of critical limits.

1.9. Manufacturing Flow Diagram (MFD):

A systematic representation of the sequence of steps or operations used in the production or

manufacture of a particular food or drug item.



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1.10. GMP:

Good manufacturing practices, which are the roles and principles to ensure the product quality

and it is fit for its intended use. Including materials, machines, facilities, personnel and all

other factors.

1.11. Significant Hazard:

Any biological, chemical, or physical property that may cause a food or drug to be unsafe for

human consumption.

1.12. HACCP:

A system that identifies, evaluates, and controls hazards which are significant for food or drug

safety.

1.13. Hazard Analysis:

The process of collecting and evaluating information on hazards and conditions leading to their

presence to decide which are significant for food or drug safety and therefore should be

addressed in the HACCP plan.

1.14. Monitoring:

To conduct a planned sequence of observations or measurements of control parameters to

assess whether the CCPs are controlled or not.

1.15. SOP:

Standard Operation Procedures.

1.16. Validation:

Obtaining evidence that the elements of the HACCP plan are effective.

1.17. Verification:

The application of methods, procedures, tests and other evaluations, in addition to monitoring

to determine compliance with the HACCP plan.

1.18. MS:

Management system



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2. Prerequisite programs:

The T3A management is committed to safety management system through safety policy andawareness for implementation of an effective HACCP system. T3A cover all requirements of

medicinal manufacturing site and inspected periodically by Egyptian Ministry of Health to

ensure complying with all prerequisite requirements.

Sanitation control

T3A is complying with the general hygiene requirements of pharmaceutical products, relative

codes and regulations. Sanitation control procedures include but not limited to the following:

Safety of water.

Conditions and cleanliness of product contact surfaces.

Prevention of cross contamination.

Maintenance of hand washing and toilet facilities.

Product protection, packaging material and product contact surfaces from adulteration.

Proper labeling, storage and use of toxic compounds.

Control of employees health conditions

Exclusion of pests

Construction and lay-out

Waste control

The sanitation control records are documented and maintained. The sanitation monitoring records

are evaluated, and corrective measures are taken in timely manner if they are out of control.



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3. Purpose:

This manual defines the scope of the T3A Company, HACCP management System and provides alinkage of system documents to the various elements traditionally been accomplished through the

application Good Laboratory Practice (GLP), GMP and other guidelines, which are considered to be

essential to the development and implementation of effective HACCP plans. HACCP plans are

focused on hazards, the overall objective being to ensure that pharmaceuticals are safe for use. The

existence and effectiveness of GLP and GMP should be assessed when drawing up HACCP plans.

The T3A Company objective is a common management system framework that connects our

business planning, implementation, measurement and performance improvement, in the T3A

HACCP System, so as to systematically HACCP risks, opportunities and impacts.

This common management system follows the Plan-Do-Check-Act-Model, (PDCAM) which allowed

T3A to upgrade the existing management activities of the common HACCP programs.

The principal elements of the system described in this manual are:

HACCP T3A Policy.

HACCP Control.

HACCP objectives and Targets.

HACCP Management Programs.

Organizational structure and responsibility.

Training, Awareness and competence.

Communication.

HACCP Management system documentation.

Document Control.

Operational control.

Recall procedures.

Monitoring and measurements.

Nonconformance, corrective and preventive actions.

Records and record management.

Verifications.



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4. Scope

The T3A Company HACCP MS provides a mechanism for HACCP management throughout

all areas and organization departments. The HACCP management system is designed to cover

all hazards and risks which the company can control and directly manage, and those it does not

control or directly manage but can be expected to have an influence.



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5. Issuing and updates

* The Control of this manual is in accordance with T3A company document control procedure.



.. .....

Issue number Effective

date Description of changes Pages changedPerformed by

From To

01 02 01/12/2006

Change in format ,

Addition of ISO

22000:2005 certificate,

remove item 21

All pages , Page

8 , Page 22

Islam Omar HACCP

Management

representative

02 03

Change of assignee

Persons.

re-evaluation time

All pages

Mohamed El Assady

HACCP Management

representative


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6. T3A HACCP certificate according to ISO 22000:2005



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7. T3A HACCP Policy



.. .....

Product safety comes first through hazard prevention, commitment to meet or

exceed relevant HACCP principals, legislations, regulations, and other

requirements.

Strict implementation of the prerequisite program for all the company

premises and personnel.

Continual improvement of HACCP system, and enhance the competence of

all T3A members towards product safety.

Approval

Plant Manager

Name:......

Sign.:...

Date:


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8. HACCP Control

The T3A HACCP Team identified the control points and critical control points hazards, which

the facility controls and over which it may be expected to have an influence, and determinedwhich of those points are considered critical. Discussions regarding significance are recorded in

HACCP meeting minutes. These aspects are to be reviewed at least annually by the HACCP

team or when there is a new or changed process or activity at the facility. The HACCP

Management representative maintains meeting minutes and other records. A list of all aspects

and risks and hazards by area and department is maintained.

8.1. Assemble a HACCP team

The pharmaceutical manufacturer should assure that product-specific knowledge and expertise

are available for the development of an effective HACCP plan. This may be best accomplished

by assembling a multidisciplinary team. Team members should therefore represent all the

relevant disciplines, such as research and development, production, quality control, quality

assurance, microbiology, engineering and distribution or others as applicable. Team members

should have specific knowledge and expertise regarding the product and process. Where such

expertise is not available on site, expert advice should be obtained from other sources .

Team members should be able to:

(a) Conduct a hazard analysis;

(b) Identify potential hazards;

(c) Identify hazards which should be controlled;

(d) Recommend controls and critical limits;

(e) Devise procedures for monitoring and verification;

(f) Recommend appropriate corrective action where deviations occur;

(g) Verify the HACCP plan.

The scope of the HACCP plan should be defined. The scope should describe the segment of the

process involved and the classes of hazards to be addressed should be identified.

8.2. Describe the product and process

A full description of the product and the process should be drawn up, including relevant

quality information such as the composition, physical/chemical properties, structure, pH,

temperatures, method of cleaning, bactericidal / bacteriostatic treatments (e.g. heat-

treatment), drying, screening, mixing, blending, packaging, and the storage conditions. The

method of distribution and transport should also be described, especially where products are

thermolabile.



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8.3. Identify the intended use

The intended use should be based on the expected uses of the product by the end user or

consumer. In specific cases, vulnerable population groups, e.g. geriatric patients, infants andimmunocompromised patients, may have to be considered.

8.4. Construct a flow diagram

The flow diagram should be constructed by the HACCP team, and should cover all operations

and decisions in a process. When applying HACCP to a given operation, the steps preceding and

following that operation should also be considered. A block-type diagram may be sufficiently

descriptive.

8.5. On-site confirmation of flow diagram

The HACCP team should confirm the processing operation against the flow diagram during all

stages and hours of operation. Amendments to the flow diagram may be made where

appropriate, and should be documented.

8.6. List all potential hazards associated with each step, conduct a hazard analysis, and

consider any measures to control identified hazards:

When hazard analysis is conducted, safety concerns must be distinguished from quality

concerns.

The HACCP team should list all the hazards that may be reasonably expected to occur at each

step from production, testing and distribution up to the point of use. It should then conduct a

hazard analysis to identify for the HACCP plan which hazards are of such a nature that their

elimination or reduction to acceptable levels is essential.

A thorough hazard analysis is required to ensure an effective control point. A two-stage hazard

analysis is recommended. During the first stage, the team should review the materials, activities,

equipment, storage, distribution and intended use of the product. A list of the potential hazards

(biological, chemical and physical) which may be introduced, increased or controlled in each

step should be drawn up.

In the hazard analysis, the following should be included wherever possible:

The probable occurrence of hazards and the severity of their adverse health effects.

The qualitative and/or quantitative evaluation of the presence of hazards.



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The survival or multiplication of microorganisms of concern.

The production or persistence in drugs of toxins, chemicals or physical agents.

The conditions leading to the above.

During the second stage, a hazard evaluation should be conducted, i.e. the severity of the

potential hazards and the probability of their occurrence should be estimated.

The team should then decide which potential hazards should be addressed in the HACCP

plan, and what control measures, if any, exist that can be applied for each hazard. More than

one control measure may be required to control a specific hazard(s) and more than one

hazard may be controlled by a specified control measure.

Potential hazards in relation to at least the following should be considered:

Materials and ingredients.

Physical characteristics and composition of the product.

Processing procedures.

Microbial limits, where applicable.

Premises.

Equipment.

Packaging.

Sanitation and hygiene.

Personnel.

Risk of explosions.

Mix-ups.

8.7. Determine critical control points:

A CCP in the HACCP system can be more easily determined by the use of a decision-tree,

which facilitates a logical approach. The way that a decision-tree is used will depend on the

operation concerned, e.g. production, packing, reprocessing, storage, distribution. Training in

the use of decision-trees should be given.

If a hazard has been identified at a step where control is necessary for safety, and no control

measure exists at that step, or any other, the product or process should be modified at that

step, or at an earlier or later stage, to include such a control measure.



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8.8. Establish critical limits for each CCP

Critical limits must be specified and verified, if possible, for each critical control point. More

than one critical limit may sometimes be elaborated at a particular step. The criteria used ofteninclude measurements of temperature, time, moisture level, pH, and sensory parameters, such as

visual appearance and texture. Critical limits should be scientifically based.

8.9. Establish a monitoring system for each CCP

Monitoring is the scheduled measurement or observation of a CCP relative to its critical limits.

Monitoring should be recorded. The monitoring procedures used must be able to detect loss of

control at the CCP, and this information should ideally be available in time to make adjustments

to ensure control of the process and prevent violations of the critical limits. Where possible,

process adjustments should be made when the monitoring results indicate a trend towards loss of

control at a CCP. These adjustments should be made before a deviation occurs. Data derived

from monitoring must be evaluated by a designated person with the knowledge and authority to

carry out corrective actions when indicated. If monitoring is not continuous, the amount or

frequency of monitoring must be sufficient to guarantee that the CCP is under control. Most

monitoring procedures for CCPs will need to be done rapidly because they relate to on-line

processes and there will not be time for lengthy analytical testing. For this reason, physical and

chemical measurements are often preferred to microbiological tests because they can be done

rapidly and can often indicate the microbiological control of the product. The personnel

conducting the monitoring of CCPs and control measures should be engaged in production (e.g.

line supervisors, maintenance staff) and, where appropriate, staff from quality control. They

should be trained in monitoring procedures. Where continuous monitoring is possible, a reliable

monitoring procedure and frequency should be identified. Statistically designed data collection

or sampling systems should then be used. All records and documents associated with monitoring

CCPs must be signed and dated by the person(s) carrying out the monitoring and by a

responsible reviewing official(s) of the company.

8.10. Establish corrective actions

Specific corrective actions should be developed for each CCP in the HACCP system in order

to deal with deviations when they occur. These actions should ensure that the CCP is brought

under control. Corrective actions should include at least the following:

(a) Determination and correction of the cause of non-compliance.

(b) Determination of the disposition of the non-compliant product.



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(c) Recording of the corrective actions that have been taken.

Specific corrective actions should be developed in advance for each CCP and included in the

HACCP plan. As a minimum, this plan should specify what is to be done when a deviation occurs,

who is responsible for implementing the corrective actions, and that a record will be kept and

maintained of the actions taken. Individuals who have a thorough understanding of the process,

product and HACCP plan should be assigned the responsibility for the oversight of corrective

actions.

As appropriate, experts may be consulted to review the information available and to assist in

determining the disposition of non-compliant product. Actions taken must also include the proper

disposition of the affected product. Deviation and product disposition procedures must be

documented in the HACCP records.

8.11. Establish verification procedures

Procedures should be established for verification. Verification and auditing methods, procedures

and tests, including random sampling and analysis, can be used to determine whether the HACCP

system is working correctly. The frequency of verification should be sufficient to confirm the

proper functioning of the HACCP system. Examples of verification activities include:

Review of the HACCP system and its records.

Review of deviations and product dispositions.

Confirmation that CCPs are kept under control.

Initial verification of the HACCP plan is necessary to determine whether it is scientifically and

technically sound, that all hazards have been identified, and that, if the HACCP plan is properly

implemented, these hazards will be effectively controlled.

Information reviewed to verify the HACCP plan should include:

(a) Expert advice and scientific studies;

(b) in-plant observations, measurements and evaluations. For example, verification of the moist

heat sterilization process for sterile injectables should include the scientific justification of the

heating times, pressure and temperatures needed to obtain an appropriate destruction of

pathogenic microorganisms (i.e. enteric pathogens) and studies to confirm that the

sterilization conditions ensure that the whole load is kept at the required temperature for the

time required.

Subsequent verifications should be performed and documented by a HACCP team or an

independent expert, as needed. For example, verifications may be conducted when there is

an unexplained system failure, a significant change in product, process or packaging occurs,

or new hazards are recognized.



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In addition, a periodic comprehensive evaluation of the HACCP system by an unbiased,

independent third party is useful. This should include a technical evaluation of the hazard

analysis and each element of the HACCP plan as well as an on-site review of all flow diagrams

and appropriate records of the operation of the plan. Such a comprehensive verification is

independent of other verification procedures and must be performed in order to ensure that the

HACCP plan is

Resulting in the control of the hazards. If the results of the comprehensive verification identify

deficiencies, the HACCP team should modify the HACCP plan as necessary.

Individuals doing verification should have appropriate technical expertise to perform this

function.

Where possible, verification should include actions to confirm the efficacy of all elements of

the HACCP plan.

8.12. Establish documentation and record keeping

Efficient and accurate documentation and record keeping are essential to the application of a

HACCP system and should be appropriate to the nature and size of the operation.

Examples of activities for which documentation is required include:

Hazard analysis.

CCP determination.

HACCP plan.

Critical limit determination.

Examples of activities for which records are required include:

CCP monitoring activities.

Process steps.

Associated hazards.

Critical limits.

Verification procedures and schedule.

Deviations.

Associated corrective actions.

Modifications to the HACCP system.



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9. HACCP Objectives and Targets

The HACCP Team has developed objectives and targets for each significant type of product orrisk or hazard. These objectives and targets define:

Produce a hazard free product.

Produce a HACCP system that can specify that CPs and CCPs identify each type of

hazard and initiate corrective and preventive actions.

Taking risks into minimal.

The performance objectives (Identify/Investigate/Study, Control/Maintain, or Improve) for

each type of product aspect.

1. The specific, quantified targets which define those performance objectives.

2. The planned deadlines for the achievement of those targets.

Objectives and targets are developed considering significant according to hazards type and risk

control, technological options, financial, operational and business plans, and the views of

interested parties.

10. HACCP Management Programs

The HACCP team establishes HACCP management programs as a means for achieving

objectives and targets. These programs define the principal actions to be taken, those

responsible for undertaking those actions and the scheduled times for their implementation.

The (programs), are developed by the HACCP team and approved by the Plant Management

Team (refer to Section 5.0 HACCP Control).

11. Organizational Structure and Responsibility

HACCP management system roles, responsibilities and authorities are defined at relevant

functions and levels within the organization. The Plant Management Team jointly provides the

resources essential to the implementation and control of the HACCP management system,

including: training, human resources, specialty services, financial resources, technical and

informational services. The HACCP Management representative has primary responsibility for

establishing, operating and maintaining the HACCP MS.



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12. Training, Awareness and Competence

The success of a HACCP system depends on educating and training management andemployees in the importance of their role in producing safe pharmaceuticals. Information

should also be provided on the control of hazards at all stages of production and supply.

The Company identifies, plans, monitors and records training needs for personnel whose work

may create a significant impact upon the hazard analysis and critical control points. The

Company has an integrated documentation procedure to train employees at each relevant

function and level so they are aware of the HACCP policy, their roles and responsibilities in

achieving conformance with the policy and procedures, and with the requirements of the

HACCP management system. The training officer is responsible for maintaining employee

training.

The training program shall address the following:

Identification of training needs

All members of the HACCP team and all employees related to the CCPs well trained in

HACCP principles, sanitation controls and applications, sanitation controls and

applications.

At least two persons are trained in HACCP principles, the relevant legislation and

regulations and internal audit programme.

The evaluation of training effectiveness.

13. Communication

The T3A Company has established and will maintain a procedure for internal and external

communications regarding hazards aspects, the HACCP MS and Hazards Risks and Legal.

14. HACCP Management System Documentation

This Manual identifies all documents relevant to the HACCP MS. A copy of HACCP MS

documents, visual aids and records, can be obtained from the HACCP management

Representative or designee.



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15. Document Control

The T3A Company has established integrated procedures to control all the managementdocuments (quality, environmental, OHSAS and HACCP). These procedures describe where

documents can be located and how and when they are reviewed. The procedure ensures that

current versions are available and that obsolete documents are promptly removed from use or

are suitably identified. Controlled documents are obtainable from the HACCP Representative

or designee.

16. Operational Control

The HACCP team is responsible for identifying CPs & CCPs and activities associated with

significant HACCP aspects, risks & hazards that require operational controls in procedures,

work practices or HACCP management programs.

These documents define the mechanisms for the establishment, implementation and

maintenance of the HACCP MS and ensure that the system is maintained in accordance with

the HACCP policy and objectives and targets and is communicated to suppliers (as

appropriate).

System Procedures: cover the management and control of both the HACCP MS and the

principal hazard risk aspects, which the system manages. These procedures are plant wide in

their application.

Work Practices: cover the hazard control of specific operational activities and are usually

activities specific in their application.



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17. Recall procedures

The T3A Company has a recall procedure to manage and respond to accidents and emergencysituations, and for preventing hazards that may be associated with them. Emergency methods

are reviewed by the HACCP Team on an annual basis and after the occurrence of accidents or

emergency situations.

The recall procedure shall include:

Product nomenclature.

Batch Identification.

Reason of recall.

Disposal of recalled product.

Participant parties to be notified.

Consideration of improving the existing HACCP system.

Any other requirements of regulation (if applicable).

A moke recall is preformed once a year as a minimum to verify the effectiveness of the

procedure.

18. Monitoring and Measurement

The T3A Company has established procedures to monitor and measure the key characteristics of

its operations and activities that can have a significant impact on the product safety. The

procedure includes in process control system and environmental monitoring and ensures that

records will be retained.

The T3A Company has established a hazard regulatory Compliance Program. And periodically

review regulatory compliance and report results to management on a yearly basis.

The monitoring procedures shall ensure that the critical limits of each CCP are consistently met,

and shall include the sequence of measurements demonstrating that the critical control points are

under control.

The monitoring procedures shall define the following points:

What to be monitored.

Monitoring method.

Monitoring frequency.



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Personnel responsible.

Calibration of monitoring equipment.

Identification and traceability of product.

Corrective action, if deviation occurs

Monitoring personnel training

The monitoring results are recorded on day to day basis and signed by the personnel

responsible for monitoring and reviewing respectively.

19. Corrective Actions

For each critical control point (CCP), a documented corrective action procedure is established

and implemented to deal with the deviations when they possibly occur.

The corrective action shall include:

Designated personnel who have the responsibilities and authority to handle the

corrective action.

Identification of the non conforming products.

Determining the disposition of non conforming product.

Correcting the cause of non compliance to prevent a recurrence.

Verifying/ evaluation the effectiveness of corrective action taken.

Consideration of modifying process or HACCP plan, if the CCP is violated constantly.

20. Records and Records Management

The T3A Company has integrated management procedures for the identification, maintenanceand disposal of all management records (quality, environment, safety and HACCP). These

records include training records and the results of audits and reviews. They are readily

retrievable and protected against damage, deterioration and loss. The Areas and Departments

maintain their own HACCP records. Record and document retention is also specified in the

procedure.



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21. HACCP System Verification

T3A has established and maintain procedures to specify, plan and conduct all activities thatverify the adequacy and effectiveness of HACCP plan and requirements of codes, legislation

and regulation for the purpose of product safety.

The responsibilities, authorities, methods, frequency for internal and external audits are clearly

defined in the integrated audit procedures for all the management system activities (Quality,

environment, OHSAS and HACCP).

The personnel performing verification are trained or qualified to HACCP principles and

system audit techniques.

The verification includes:

a) Initial validation of elements of the HACCP plans such as process flow diagram,

hazard analysis, determination of CCPs, critical limits, monitoring procedures,

corrective actions, documents, record keeping system .. Etc.

b) On going HACCP system assessment

Review of records.

Review of deviations

Confirmation the CCPs are under control

Calibration of monitoring equipments.

Sampling and testing.

Evaluation of customer complaints.

c) Verification of the overall HACCP system

Internal audit which shall be performed at least twice a year

Feedback system of audit data for improvement of HACCP system.

External audit.

Any changes made that may effect the HACCP system

The plant manager reviews all elements of the HACCP MS annually to ensure its continuing

suitability, adequacy and effectiveness. Meeting minutes record these reviews and are kept by

the HACCP Management representative or designee.


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