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Published byBeverly Horton Modified over 8 years ago
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Validation and Verification Tasks March 8, 2016 Suzanne Finstad Vice President, Food Safety & Regulatory Compliance
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Verification Tasks Calibration Prior to use of the instrument (per shift) Direct Observation Monitoring Corrective Actions (per occurrence) Record Review ALL of them Prior to pre-shipment record review 2
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The Evolution of Validation In the Beginning… …There was paper. LOTS and LOTS of paper Mid to Late 2000’s Articles Statistical analysis Summaries Present Day Quality over quantity 3
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FSIS on Validation In the Beginning… …They were happy we had paper Mid to Late 2000’s They read the articles They reviewed the statistical analysis They reviewed the summaries Present Day HAV PHRE FSA 4
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Industry Put on Notice Validation Compliance Guideline Scientific support In-plant data Organized Outreach Federal Register notice Meetings Notice 78-15 Directive 5000.6 Directive 5100.1 YouTube video 5
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Where Industry Went Wrong Design Does the scientific support properly relate to the current process? Have the critical operating parameters been identified? Execution Have the critical operating parameters been included in the HACCP system? Is there documented evidence that the HACCP system has been validated under in- plant conditions? 6
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Post January 4 th … What are we doing? Is it critical? Why are we doing it? Relevant scientific support* Test and hold How do we know we’re doing it correctly? In-plant data What if we change our mind? 90-day validation 7 *Currently industry’s greatest need
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Are We There Yet? Sanitary Dress When, where, why, and how? Performance Standards Past, present, and future 8
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Where Are We Going?
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What Are We Doing? Antimicrobial applications Equipment Sprays Dips Research, research and more research Food safety Product quality 10
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Why Are We Doing It? Scientific Support Process specific? Species specific? Pathogen specific? What’s critical? In-Plant Data Does it work? How well? Relationship to the science Limitations RELEVANT peer-reviewed support 11
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How Do We Know We’re Doing it Correctly? Test the theory Do YOU have data? What kind of data? What does it tell you? Commit it to memory Keep the initial validation! Stay on top of your system.
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What If We Change Our Mind? Why Change? Document the thought process After Change… Collect some data Draw some conclusions Do it all within 90 days 13
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Bringing It All Together Standing still gets you nowhere fast!
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WE DON’T LIVE HERE!
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Committed to continuous improvement.
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