Food Safety Manual
Food Safety Manual
P h y s i c al A d d re s s : S hi ma n zi A r e a , M w a t a t e S t r e e t M o mb a s a
Bahari (T) Company Ltd Food Safety Manual V 7 Page 1 of 52
Approval Page:
________________________ ________________________
Amended & Reviewed by Approved For Implementation by:
FSTL M. D.
INTRODUCTION
The Food safety manual of Bahari (T) company sets out the principals of operation,
control and code of practice which is provided as a practical interpretation and a guide to
good product handling, storage practices and procedures to be followed throughout the
product chain. This manual forms the referral point for all the procedures which are
aimed at giving product safety, legality, regulatory and quality requirements. Bahari’s
integrated food safety system borrows its foundation from ISO 22000, HACCP standards
and procedures, which gives us the confidence of conformance to international food
safety standards.
In implementing food safety systems, Bahari hopes to improve its profile and credibility,
win customer confidence and have a competitive advantage in the market. Our aim is to
achieve satisfactory and consistent safe products of the right quality which is compatible
with the customer needs and market expectations.
ITEM PAGE
1 Food safety policy 5
2 FSMS requirements - General 6
3 Context of the organization 9
4 Management responsibility 11
5 FSMS Planning (Risks & FSMS Objectives) 13
6 Support (Resources, Awareness, Communication, doc info) 16
7 Planning & realization of safe products 17
8 Preliminary steps to hazard analysis 21
9 Hazard analysis 24
10 Flow diagram 29
11 Hazard identification table 30
12 Hazard assessment & control measures 31
13 Decision Tree 35
14 Hazard control plan 36
15 Performance evaluation 39
16 Improvement 41
17 Warehouse procedures 42
18 Training 50
Bahari (T) Company Ltd is committed to supplying high quality tea products
which are safe and meet the most stringent of our customer specifications.
The company is committed to the adherence of the food safety requirements
underpinned by ISO 22000:2018, compliance with local food related legislations
as well as food safety requirements of destination as advised by our customers.
Operational risks are identified and controlled.
Our operations personnel effectively manage communication throughout the food
chain to ensure the availability of necessary information that demonstrates
compliance of our operations to the food safety norms in general and specific
industry practices as necessary.
To ensure continual improvement the company has provided the necessary
resources and ensured personnel remain competent to manage food safety
through continuous training programs. Specific objectives and targets have been
established to enhance performance.
All Bahari (T) Company employees have a responsibility to uphold best practices
in warehousing and handling of tea in order to guarantee the achievement of our
objectives, targets and policy commitment to the benefit of all industry
stakeholders.
Date: ……………………………….
2. Out-sourced Services
Bahari (T) Company Ltd does outsourcing of the external services from credible
suppliers who conform to the company requirements as pertaining to food safety
management.
The following is a selection of companies supplying various services to Bahari (T)
Company ltd:
1. Vectorcorn - pest management
2. Avery Scales - Scales calibration and maintenance
3. Fumigation of pallets - Merchant Inspection Services
4. SGS Kenya Limited - third party audits
If they must enter the warehouse, they have to comply with the warehouse code of
practice. The company exercises control over their processes to ensure compliance.
3. Definitions
1. Acceptable level - level of a food safety hazard not to be exceeded in the end
product provided by the organization.
2. Action criterion - measurable or observable specification for the monitoring of
an OPRP
3. Audit - systematic, independent and documented process for obtaining audit
evidence and evaluating it objectively to determine the extent to which the audit
criteria are fulfilled
i Timely payments
Suppliers of services i Business continuity
ii Meeting of contractual
8 & non raw material
agreements ii Positive feedback
item on their services
iii Good working relationship
4 X 4 MATRIX
4
3
Likelihood
2
1
1 2 3 4
Consequences
Likelihood
1 – Very low chances of occurring, may not have been reported in the company.
2 – Low chances of happening, may have happened before, infrequent
3 – Has high chances of happening
4 – Will definitely happen
Consequences
1 – Has no impact on company image, financial loss or product safety.
2 – Has low impact to the business, other interested party financial loss or
product safety.
3 – Has significant impact to the business or its interested parties
4 – Has severe impact to the business or its interested parties
# Risk Root Causes Probabilit Severity Risk level Current controls Proposed
y additional
controls &
Opportunities
- Plan for anticipated
high season To be
- High season - Notify other reviewed in
- Slow warehouses to collect December
dispatch/shi their teas timely 2019
pments - Arrange teas well to
Shortage of - deficient free up space.
1 warehousing storage 3 3 9 - Check possibility for
space practices strategic space
Opportunity
- lack of outsourcing in high
Increase
adequate season
handling
coffee - stop dealing with
capacity
pallets customers who misuse
the warehouse
Have a
- Daily planning of contingency
- Poor
financial needs by kit / float for
planning
11am emergency
from
Cash-flow - Planned cash
3 operations 3 3 9
constraints expenditure, eg Opportunity
- unplanned
purchase of Improved
cash
packaging materials cash flow,
expenditure
to be done early avoidance
of bouncing
cheques
Monitor
landlords
reaction and
change
- Notify landlord
strategy
before rainy season to
when
Warehouse Uncooperati inspect and repair,
4 2 3 6 necessary
leakages ve landlord - carry out repair works
Opportunity
and invoice landlord
Avoid
- Put a new roof
product loss,
prevent
customer
complaints
Machine - Safety - Conduct tool box
5 breakdown or noncomplian 2 3 6 talks and include None
injury to ce safety awareness
7.2 Competence
Only competent workers with experience in tea handling and other support functions in
the tea export business are hired at Bahari. Personnel job descriptions are documented
under the “Company organogram and personnel duties” manual. The food safety team
leader has ultimate responsibility for planning of food safety refresher training.
7.3 Awareness
All employees are made aware of important food safety aspects through training,
posters, notice boards and meetings. All personnel working for or on behalf of the
company have to be aware of basic food safety requirements needed to demonstrate
conformity and safety of products.
7.4 Communication
On external communication with suppliers, customers, the public and relevant
government agencies the company has relies on management and HOD to manage
such communication relevant to their areas of operation. Input from such communication
and relevant outputs are reviewed at the management review meetings.
While implementing the prerequisite programs, the organization has identified statutory
and regulatory requirements as follows:
the Kenya Standard for Black Tea
EATTA rules
ISO TS 22002-1:2009
The organization has considered the following while establishing the prerequisite
programs:
Construction and lay-out of buildings and associated utilities
Lay-out of premises, including workspace and employee facilities
Verification of prerequisite programs has been planned and the same have been
modified as necessary. Records of verifications and modifications are maintained
Specific procedures related to PRPs are covered under the PRP manual.
Equipment
The Food Safety Team Leader is responsible of ensuring that all new equipment
conforms to the companies Food Safety Policy
Transport
Tea is delivered to the warehouses in closed containers loaded on trucks. Transportation
is on ambient temperatures.
Hygienic conditions are preserved during transport and mingling with other products is
prevented.
Storage
Tea packages are arranged on wooden pallets and stored in the warehouses at ambient
temperatures. The packages are arranged on wooden pallets during offloading for
convenience of storage, movement by the forklift and to prevent direct contact with the
ground.
Storage periods are determined by many factors, such as how soon the product is sold
and when the buyer comes for collection.
There is no defined time a package can be stored at the warehouse, but the quality of
the products is maintained as long as it is maintained in the warehouse.
A cleaning program is maintained in the company that ensures that walls, roofs and
other places where dust collects are thoroughly cleaned, and that the floors, doorways
and entrances are maintained clean always to avoid contamination of the products.
Product Supply
The product stored at Bahari (T) Company is sourced from producers who are members
of East African Tea Trade Association, an organization that governs tea trade in Africa.
The factories have also implemented quality and food safety management systems, so
as to ensure the safety and quality of the product at factory level.
The main suppliers factories of the tea stored at Bahari are:
2 Munobwa Marvera
3 Mabale Dindira
4 Mpanga Chivanjee
NOTE:
Flow Diagram
Objective
The objective is to guarantee food safety by implementing a quality system, which
covers the complete product chain from the farm, processing, dispatch up to the client.
This means that Bahari (T) Company is not only responsible to the Good Warehousing
Practices within the warehouses but also reckons with possible hazards, which can
occur before and after the warehouse.
Biological Hazards
Biological hazards are living organisms that make food unsafe for consumption. They
may be bacterial, parasitical or viral. They maybe introduced by people handling food,
environment, packing material, e.t.c.
Microbiological safety hazards cause most of the food borne illnesses.
Tea can be affected by microbiological pathogens at any point of our procedures.
Whether the contamination by microorganisms will be hazardous will depend on the
following factors:
Hygiene practices in the system
Presence of controlling and preventing pathogens propagation within the chain
Conditions of the product regarding possible microbiological growth
Chemical Hazards
A chemical hazard maybe the result of something naturally occurring in food or added
during processing. Harmful chemicals have been associated with acute cases of food
borne illnesses or chronic illnesses.
Naturally occurring chemical hazards are those that are natural constituents of foods and
not the result of environmental, industrial or other contamination and include aflatoxins
and mycotoxins.
Added chemical hazards are those intentionally or sometimes unintentionally added to
food such as pesticides, ingredients, cleaners or paints.
Major chemical contaminants include:
Contamination of product with pesticides
Indiscriminate spraying of facilities against pests
Accidental spillage of pesticides
Contamination of product with an allergen
Mycotoxin emanating from molds in tea
Contamination of product with cleaning agents
Many of the chemical food safety problems are addressed by observing good
warehousing practices such as pest control, effective cleaning program and proper
storage practices.
Physical Hazards
A physical hazard is a physical component in food that is unexpected and may cause
illness or injury to the person consuming the product e.g. glass, metal and plastic.
Monitoring Systems
This is a series of observations or measurements put in place to ensure that the
preventive measures are implemented correctly and that they do not deviate beyond the
set targets.
Review
Bahari uses the review plan to determine whether the plan is still appropriate and is
taken as an additional step to the verification procedure. Our in-house review is done by
the Food Safety Team and the entire management team.
OFFLOADING
WEIGHING
VIBRATION
REPAIR OF TORN
PACKAGES
PACKAGING STAKING
MATERIALS RECEIPT
AND INSPECTION
STORAGE
PACKAGING
MATERIALS STORE
BLENDING
SAMPLING
PACKAGING
SPILLAGES WEIGHING
(WASTE) SPILLAGES
(WASTE) & TORN
PAPER SACKS
PROCESS ACCEPTABLE
HAZARD ORIGIN OF HAZARD
STEP LEVELS
Offloading
Other foreign matter
Environment Not possible to fix
(non-vegetative)
The establishment of the acceptable levels of the hazards has been based on customer
requirements, statutory and regulatory requirements and the intended use of the
product.
As a help in classifying the severity of health effects and the probability of occurrence,
the Table below has be used. Significant hazards that have to be controlled are in red.
Hazards that are not considered significant (in green) are managed by PRPs or may not
need to be controlled.
2
1
1 2 3 4 5
Likelihood of Occurrence
KEY
Severity of health effect
1: Almost no inconvenience
2: Can cause inconvenience
3: Can cause illness
4: Can lead to serious illness
5: Can cause fatality
Likelihood of occurrence
1: Unlikely (once in two years)
2: Rare (once a year)
3: Could occur (once in six months)
4: Likely (once a month)
5: Frequent (once a week)
Risk Analysis
SEVERITY
PROCESS LIKELIHOOD OF SIGNIFICANC CONTROL
HAZARD OF RISK CONTROL MEASURE
STEP OCCURRENCE E OF HAZARD TYPE
IMPACT
Not Offloading
Dust 2 2 4 PRP
significant procedure
OFFLOADING OF TEA
Pieces of wood
Not Ensure pallets are
and other 1 1 1 PRP
significant well repaired
foreign matter
Use tamper
Not
Baits 1 3 3 resistant bait PRP
Significant
boxes
Installation of
Not shatter proof
STORAGE Glass 1 2 2 PRP
Significant covers on light
tubes
Not
Detergents 2 2 4 Cleaning program PRP
Significant
Sampling
Not procedure,
SAMPLING Coliforms 2 3 6 PRP
Significant
Code of practice
Decision
BLENDING Iron filings 4 3 12 Significant Use of magnets
Tree
Physical foreign
Hygiene / personal
matter (hair, Not
PACKAGING 2 2 4 behavior policy PRP
dust, wood significant
implementation
chippings etc)
Many of the microbiological food safety problems can potentially are addressed by good
warehousing practices such as proper employee hygiene, adequate training, and
effective cleaning and sanitizing of the manufacturing equipment and environment.
Many chemical food safety problems are also addressed by following good warehousing
practices, such as pest control and proper storage.
Physical hazards are addressed by proper supervision of the processes and maintaining
personal and environmental hygiene standards and training of employees.
The hazard assessment has been conducted based on past experience, customer
requirements and regulatory and statutory requirements.
After conducting hazard analysis, it has been found out that control measures for
managing most of the hazards in Bahari (T) Company would be managed through
effective implementation of the prerequisite programmes. For risk level above 8, this is
yes
yes
Q3 : Is frequent monitoring
needed ?
no Operational PRPs
PROCESS
HAZARD CONTROL MEASURE Q1 Q2 Q3 Q4 CONTROL TYPE
STEP
BLENDING Iron filings Use of magnets YES NO N/A N/A Operational PRP
Action criterion Max 50ppm – Kenya Standard Specification for Black Tea revision 2013
Corrective action Testing of magnets to ensure they remain strong, replacement of weak magnets
Action Criterion Any sick worker or non-compliant worker noted in process areas to be evacuated
Control measures Hygiene procedures (Medicals for workers, proper hand washing, exemption to work)
Warehouse / Blending supervisors to ensuring only health workers are allowed to handle
Monitoring procedure tea. They should have valid medical certificates and should not be sick on during
material day.
Correction measures Prevent sick workers from tea handling operations, Isolate sick workers,
Ensure workers are sensitized on key hygiene procedures and always do implement
Corrective action
hygiene requirements during blending.
Responsible person Warehouse supervisors and blending supervisor
Verification Medical records to be in place, microbial swabs at least once per year
CONCLUSION
Check test report
CONCLUSION
Implementation of good hygienic practices and personnel behavior policy are adequate
measures for the prevention of any product contamination. Ensuring that the tea remains
within required moisture content is also important. Supervisors to ensure personnel who
are sick are not allocated any packaging work.
Internal Audits
Shall be planned and conducted according to the internal audit procedure at least once
per year.
Management review
The management of Bahari (T) Company is committed to maintaining all the Food safety
management systems necessary for food safety and quality of the end- products
Therefore in this respect the senior management will be meeting once per year to review
the following.
Input
a) Follow up actions from previous management reviews
b) Analyzing the results of verification activities
c) Changing the circumstances that can affect food safety
d) Emergency situations, accidents and withdrawals
e) Reviewing results of system updating activities
f) Review of communication activities, including customer feed-backs
g) External audits or inspections
h) Risks and opportunities
The management reviews the input and output process analyzing current activities that
may require change and consider opportunities for improvement, including Food Safety
policy and Food Safety objectives
The members present shall be the management and the supervisory team having
responsibility for the Food Safety management system
04 - Actual Offloading
i. Offload the packages one by one and check that they are in good condition, with
no tears, water stains or other non-conformities.
ii. Offload only in dry conditions or under a shed to prevent potential wetting of tea
packages
iii. For minor tears on the paper sacks, they will be gum-taped. This will only apply if
the product has not been tampered with.
iv. Packaging material liner shall be put in place to prevent direct contact of tape
with tea
05 - Palletizing
i. Identify each package by its garden, grade and invoice number. Packages of
similar details are arranged together on the same pallet. Pallet arrangement
should be as follows:
A. For paper sacks, pallet arrangement should not exceed 20 packages
B. For poly bags, they should not exceed 20 packages on both big pallets (coffee
pallets) and on small (ordinary) pallets.
ii. If the number of packages on an invoice is not in the multiples of 20, the excess
packages are placed on pallets of their own. Packages of different invoices
should not be placed on the same pallet.
iii. For good balancing on the pallets, the packages are arranged in a criss-crossing
pattern
iv. The clerk in charge of offloading should ensure that all the packages on a pallet
are of the same Garden, package type, Invoice number and grade
08 - Reporting
i. The report of each consignment is then sent to the stock clerks who send the
information to both the producers and the brokers
ii. If the details of the consignment do not correspond with the details given in the
packing list, the information is communicated to by the stock clerks to the parties
concerned, verifying the correct details of the packages that have been received
in the warehouse.
iii. The offloading exercise will involve the following:
Warehouse supervisor (to oversee)
Clerk in charge
Fork lift driver
Security Guards
Casual workers, assigned as per number of packages in a truck
Stock clerks
iv. The following records shall be maintained:
Inward Tally form
Garden Stock books
Truck Inspection Form
09 - Vibrating
i. Identify all the packages to be vibrated and place them near the vibrating
machine.
ii. Put the packages on the vibrating machine one by one.
iii. After they are vibrated, the packages are then arranged on pallets once more, as
per the invoice numbers.
iv. When arranging pallets on the pallets, layer pads are placed between the pallets
and the bags (bottom capping).
11 - Sampling
This procedure shall apply to gardens for which samples are not sent from the factory,
for reprints or on special request from customers.
i. Sampling is to be done as per the sampling instructions received from the
brokers or on request from customers.
ii. Label all the sampling bags to indicate:
Garden
Grade
Invoice number
12 - Releasing Procedure
i. When a buyer buys tea and the sale confirmation is sent to the respective parties
including the warehouse, the stock clerks invoice the buyers so they can make
the payments.
ii. Once payment has been done, the buyer sends a copy of the Delivery Order
(non-negotiable copy) to the warehouse.
iii. The Delivery Order must be endorsed (by the buyer), stamped by the buyer or
his agent and signed by the broker’s authorized personnel. The delivery order
contains the details of the tea that has been bought:
Lot number
Invoice number
Garden
Records:
Release Orders
Delivery orders
Records:
Local delivery note
Loading instructions
Garden Stock books
Container inspection form (for shipments)
Daily Stocks
i. The daily stock report shall be compiled by the warehouse clerks for every day
reflecting:
The day’s opening stock
Receipts of the day
Deliveries of the day
The days closing stock
ii. The delivery notes will then be handed to the warehouse supervisor for
counterchecking. He will also confirm the teas that have been received as
indicated in the inward tally.
iii. All the inward tallies and delivery notes shall be delivered to the stock clerks on a
daily basis for updating the system stocks.
iv. The daily stock report given by the warehouse clerks and the stock clerks should
tally on a daily basis
Weekly Stocks
i. The warehouse clerks on a weekly basis shall prepare the stocks indicating the
teas they have received and delivered within the week.
ii. They shall also carry out physical stock checks to ensure the figures in record
rhyme with the book records
Monthly Stocks
i. Physical stocks shall be carried out on a monthly basis, invoice by invoice, by the
warehouse clerks.
ii. The figures given shall be matched by the figures recorded in the daily stock
books and the system stock, and reconciliation done.
iii. The warehouse supervisor shall be responsible of the reconciliation exercise
Records
Daily Stock movement records
Physical stock records
System stock records
Reconciliation report
15 – Training Procedure
i. Training will be organized at three different levels:
Management level
Clerks
Casual workers
ii. All directly employed staff at supervision level and above will be expected to
have necessary professional qualifications relevant to the job they do.
iii. On being engaged to work, they will undergo a three months training on job
induction to learn about the processes and systems used in the warehouses,
standard procedures and operations as set before assuming full responsibilities
of their duties.
iv. Thereafter, training needs will be evaluated annually and appropriate training
organized.
v. All regular clerks will be trained in all areas relevant to their work through short
training sessions. Such areas of training will include personal hygiene, food
RECORDS
Training program
Training records
Records for evaluation of training
16 – Management of Change
Bahari T Company Ltd operates a Food safety management system that is coordinated
by the food safety team and team leader. The food safety team has the primary
responsibility to introduce changes to the system through their periodic reviews, food
safety team meetings and through the management reviews. Changes that do not affect
food safety may not necessarily be controlled by the food safety team but by heads of
respective departments. It is incumbent upon the food safety team and respective HODs
to ensure that changes are adequately reviewed to prevent undesirable outcomes.
Changes may also be discussed and endorsed/approved during management reviews.
All changes critical to food safety must be endorsed by the FSTL and shall be minuted in
the food safety team meetings. Minutes shall be kept by the food safety team leader and