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PAS 220:2008 GAP Assessment Audit Report

Name of the Organization, Location

ORGANIZATION DETAILS
Operation Name

Address

Mr.
Designation:
Contact Person
Tel: Fax:
E-mail Id:
Manufacture and distribution of carbonated sweetened, unsweetened
Operation Type: Beverages, fountain syrup preparation, thermally processed beverages
and packaged drinking water
Division Name: India

AUDIT DETAILS
Audit Dates:
Audit Type: Gap Assessment Audit

Audit Criteria: PAS 220:2008


Lead Auditor –
Audit Team
Auditor -

 Coca Cola Division


Report
 Plant Location
Distribution
 DNV office
GAP Assessment Audit Report on PAS 220:2008
1.0 DEFINITIONS
1.1 MAJOR : Essential to meet the standard requirement, requires immediate attention.
1.2 MINOR : Essential to meet the process requirement, justification for priotization can be given.
1.3 Not Applicable : Requirements that are not applicable

2.0 AUDIT EXECUTION


2.1 AUDIT PLANNING : The Audit was planned with the Auditee Company with pre decided dates.
2.2 OPENING MEETING : Prior to commencement of the audit an Opening Meeting was held between the
Auditee and Audit Team. The purpose and terms of the Audit were defined
and arrangements for the Audit were reviewed and agreed.
2.3 EVALUATION : Activities and documentation were examined and evaluated according to the Audit
Programme and prepared Check-Lists. All relevant Observations were recorded and
discussed and agreed with the Auditee personnel.
2.4 CLOSING MEETING : At the completion of the Audit a Closing Meeting was held between the Auditee and
the Audit Team to reiterate the basis of the Audit, present the Audit Team findings,
summarise the result.

3.0 SUMMERY OF AUDIT FINDINGS


Major Findings XX
Minor Findings YY
Not Applicable ZZ

4.0 ACKNOWLEDGEMENTS AND CONFIDENTIALITY


The DNV Team acknowledge the assistance and co-operation provided by the Auditee's management and staff,
and are grateful for the provision of other facilities which affected the conduct of the audit. Due to the nature of
the work undertaken by DNV, confidential information concerning the clients business may often be examined.
No such information is disclosed to a third party except when the client has given his written consent.

5.0 KEY PERSONNELS PRESENT DURING THE AUDIT

Name Job Title Present at Audit (a


a)

Opening Facility Procedure Closing


Meeting Inspection Review Meeting

Report No: Page 2 of 25


GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
4 Construction and Layout of Buildings
General Buildings shall be designed, constructed and
Requirement maintained in a manner appropriate to the
nature of processing operations to be carried
out, the food safety hazards associated with
those operations and potential sources of
contamination from the plant environment.
Buildings shall be of durable construction
which presents no hazards to the products.
4.2 Environment
4.2.1 Consideration shall be given to local activities and the
site environment, which may have an adverse impact
on finished product integrity, and measures shall be
taken to prevent contamination. Where measures have
been put into place to protect the site from any
potential contaminants, they shall be regularly reviewed
to ensure they continue to be effective, e.g. dust or
odour control.
4.3 Location of establishment
4.3.1 Site boundaries shall be clearly defined. The external
areas shall be maintained in good order. Where
buildings are surrounded by grassed or planted areas,
they shall be regularly tended and well maintained. The
condition of the site shall be included within the internal
audit process.
4.3.2 External traffic routes, under site control, shall be
suitably surfaced and maintained in good repair to
avoid contamination of the product.
5 Layout of Premises and Workspace
General Internal layouts shall be designed, constructed
Requirement and maintained to facilitate good hygiene and
manufacturing practices. The movement

Report No: Page 3 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
patterns of materials, products and people and
the layout of equipment, shall be designed to
protect against potential contamination source.
5.2 Internal design, layout and traffic pattern
5.2.1 The process flow from intake to dispatch shall be
arranged to minimise the risk of product contamination.
5.2.2 Physical barriers or demonstrably effective procedures
shall be in place to minimise the risk of the
contamination of raw materials, intermediate/semi-
processed products, packaging and finished products.
5.2.3 Segregation shall take into account the flow of product,
nature of materials, equipment, personnel, waste,
airflow, air quality and utilities provision.
5.3 Internal structures and fittings
5.3.1 Walls
Walls shall be designed, constructed, finished and
maintained to prevent the accumulation of dirt,
minimise condensation and mould growth, and facilitate
cleaning.
5.3.2 Floors
Floors shall be designed to meet the demands of the
process, and withstand cleaning materials and
methods. They shall be impervious and maintained in
good repair with adequate slope. Drainage, including
drains from laboratories where provided, shall be sited,
designed and maintained to minimise risk of product
contamination. Machinery and piping shall be arranged
so that, wherever feasible, process waste water goes
directly to drain
5.3.3 Ceilings
Ceilings and overheads shall be designed, constructed,
finished and maintained to prevent the accumulation of
dirt, minimise condensation and mould growth, and
facilitate cleaning. If false ceiling is provided, it shall be
maintained in a good condition.

Report No: Page 4 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
5.3.4 Windows
Where there is a risk to product, windows and roof
glazing which are designed to be opened for ventilation
purposes shall be adequately screened to prevent the
ingress of pests. Where applicable, glass windows
shall be protected against breakages.
5.3.5 Doors
Where external doors to raw material handling,
processing, packing and storage areas are opened,
suitable precautions shall be taken to prevent pest
ingress. Doors and dock levellers in these areas shall
be close fitting or adequately proofed.
5.4 Location of equipment
5.4.1 All equipment shall be properly specified before
purchase, constructed of appropriate materials, be of a
suitable design to ensure it can be effectively cleaned,
and shall be tested and commissioned prior to use
5.4.2 Equipment shall be positioned to give access under,
inside and around it for ease of cleaning, inspection
and servicing, or where permanently sited shall be
properly secured and sealed to the floor.
5.4.3 Certificates of conformity or other evidence shall be
available for equipment in direct contact with food to
confirm its suitability for use, e.g. conveyor belts.
5.5 Laboratory facilities
5.5.1 Where routine testing laboratories are present on a
manufacturing site, they shall be located, designed and
operated to eliminate potential risks to product safety.
Controls shall be documented, implemented and shall
include consideration of the following:
• design and operation of drainage and ventilation
systems
• access and security of the facility
• movement of laboratory personnel
• protective clothing arrangements

Report No: Page 5 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
• processes for obtaining product samples
• disposal of laboratory waste.
5.5.2 Pathogen testing shall be subcontracted to an external
laboratory or, where conducted internally, the
laboratory facility shall be remote from the
manufacturing site.
5.6 Temporary mobile premises / vending machines
5.6.1 Temporary structures constructed during building work
or refurbishment, etc., shall be designed and located to
avoid pest harbourage and potential contamination of
products.
5.7 Storage of food, packahing material,
ingredients and non food chemicals
5.7.1 The storage area shall be dry and well ventilated. It
shall identify the raw material, work –in progress and
finished goods.
5.7.2 Monitoring devices for temperature and relative
humidity as applicable shall be installed.
5.7.3 Food storage facilities are designed and constructed to:
 permit adequate maintenance and cleaning ;
 avoid pest access and harbourage;
 enable food to be effectively protected from
contamination;
 provide the necessary environment to prevent
spoilage.
5.7.4 If externally stored, appropriate protection shall be
provided to prevent from any contamination.
6 Utilities – Air, Water, Energy
General The provision and distribution of routes for
Requirement utilities to and around processing and storage
area shall be designed to minimize the risk of
product contamination. Utilities quantity shall
be monitored to minimized the product
contamination risk.

Report No: Page 6 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
6.2 Water Supply
6.2.1 Only potable water shall be used in food handling and
processing, with the following exceptions:
 for steam production, fire control and similar
purposes not connected with food
 In certain processes (e.g. chilling) and in food
handling areas provided it does not constitute a
hazard to the safety of food (e.g. use of clean sea-
water)
6.2.2 Ice shall be made from water complying with
standardards. The ice and the steam shall be
produced, handled and stored to protect them from
contamination.
6.2.3 Water quality shall be monitored for the specifications
at periodic intervals.
6.3 Boiler Chemicals
6.3.1 Boiler chemicals if used, shall comply to relevant
national specifications.
6.3.2 Storage of boiler chemicals shall be done in protected
condition.
6.4 Air quantity and Ventilation
6.4.1 Adequate ventilation and extraction shall be provided in
product storage and processing environments to
prevent condensation or excessive dust.
6.4.2 Where the process requires screened or filtered air, the
equipment used for this purpose shall be easily
accessible and adequately maintained.
6.4.3 The air quality of such process shall be monitored for
air borne microbiological contamination.
6.5 Compressed air and other gases
6.5.1 Gases shall be non-toxic and not pose a
threat to the safety and suitability of food under the
specified conditions, storage and use.
6.5.2 Oil or other lubricants that may come in contact with

Report No: Page 7 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
the food shall be of “food grade” nature.
6.6 Lighting
6.6.1 The intensity for light shall be defined for the work
space especially for the inspection areas.
6.6.2 Where they constitute a risk to product, bulbs and strip
lights, including those on electric fly-killer devices, shall
be adequately protected. Where full protection cannot
be provided, alternative management such as wire
mesh screens or monitoring procedures shall be in
place.
7 Waste Disposal
General Systems shall be in place to ensure that waste
Requirement materials are identified, collected, removed and
disposed off in a manner which prevents
contamination of products or production areas.
7.2 Containers for waste and inedible or hazardous
substances
7.2.1 Systems shall be in place to avoid the accumulation of
waste in production areas, and shall prevent the use of
unfit materials.
7.2.2 External waste collection containers and rooms
housing waste facilities shall be managed to minimise
risk. These shall be:
• clearly identified
• designed for ease of use and effective cleaning
• well maintained to allow cleaning and where
required, disinfection
• emptied at appropriate frequencies
covered or doors kept closed as appropriate.
7.3 Waste Management and Removal
7.3.1 Where appropriate, waste shall be categorised
according to legislative requirements based on the
intended means of disposal, segregated and collected

Report No: Page 8 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
in appropriate designated waste containers.
7.3.2 Waste disposal shall meet legislative requirements.
Where licensing is in operation for disposal of
categorised waste, it shall be removed by licensed
contractors and records of disposal shall be maintained
and available for audit.
7.3.3 If substandard trademarked materials are transferred to
a third party for destruction or disposal, that third party
shall be a specialist in secure product or waste
disposal and shall provide records of material
destruction or disposal.
7.4 Drainage and Drains
7.4.1 The drains shall be in covered condition with sufficient
capacity to remove expected flow loads.
7.4.2 Where significant amounts of water are used, or direct
piping to drain is not feasible, floors shall have
adequate falls to cope with the flow of any water or
effluent towards suitable drainage.
8 Equipment Suitability, Cleaning and
Maintenance
General Food contact equipment shall be designed and
Requirement constructed to facilitate cleaning, disinfection
and maintenance. Contact surface shall not
affect or be affected by the intended product or
the cleaning system.
Food contact materials shall be constructed of
durable materials able to resist the repeated
cleaning.
8.2 Hygienic design
8.2.1 Equipment and re-usable containers coming into
contact with food shall be designed and constructed to
ensure that, where necessary,
they can be adequately cleaned, disinfected and
maintained to avoid the contamination of food.

Report No: Page 9 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
8.2.2 Where necessary, equipment is durable and movable
or capable of being disassembled to allow for
maintenance, cleaning, disinfection, monitoring and, for
example, to facilitate inspection for pests.
8.2.3 The piping and duct work shall be cleanable,
draininable with no dead ends.
8.3 Product contact surfaces
8.3.1 Equipment, Containers and other product contact
surfaces shall be clearly identified and shall be made
of materials with no toxic effect in intended use.
8.4 Temperature control and monitoring equipment
8.4.1 Equipment used to cook, heat treat, cool, store or
freeze food shall be designed to achieve the required
food temperatures as rapidly as
necessary in the interests of food safety and suitability,
and to be effectively maintained
8.4.2 Such equipment shall also be designed to allow
temperatures to be monitored and controlled. Where
necessary, such equipment shall have effective means
of controlling and monitoring humidity, air-flow and any
other condition likely to have a detrimental effect on the
safety or suitability of food.
8.5 Cleaning Plant, Utensils and equipment
8.5.1 Documented cleaning procedures shall be in place and
maintained for the building, utilities, plant and all
equipment. Cleaning procedures shall include the
following information as a minimum:
• responsibility for cleaning
• item/area to be cleaned
• frequency of cleaning
• method of cleaning
• cleaning materials to be used
cleaning records and responsibility for verification.
8.5.2 Cleaning-in-place (CIP) facilities shall be monitored

Report No: Page 10 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
and maintained to ensure effective operation.
Consideration shall be given to frequency, cycle time,
temperature, chemical concentration and spray ball
location and coverage. CIP shall have adequate
separation from active product lines.
8.5.3 The effectiveness of the cleaning and disinfection
procedures shall be verified and recorded. Corrective
actions shall be documented.
8.6 Preventive and Corrective Maintenance
8.6.1 Equipment, including fixtures and fittings, shall be
maintained in such condition as to minimise the risk of
product contamination.
8.6.2 When commissioning new equipment and plant, a
maintenance programme shall be established and put
into place based on risk assessment.
8.6.3 The company shall ensure that the safety or legality of
product is not jeopardised during maintenance and
cleaning operations.
8.6.4 In addition to any planned maintenance programme, if
there is a risk of product contamination arising from
equipment failure, the equipment shall be inspected at
predetermined intervals, inspection results documented
and appropriate action taken.
8.6.5 Where temporary repairs are made, these shall be
controlled to ensure the safety or legality of product is
not jeopardised and permantly repaired.
8.6.6 Contractors involved in maintenance or repair activities
shall be under the supervision of a nominated person.
9 Management of Purchase Material
General Purchasing of material which impacts food
Requirement safety shall be controlled to ensure that the
suppliers used have capability to meet specified
requirements. The conformance of incoming
material to specified requirements shall be met.

Report No: Page 11 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
9.2 Selection and Management of Suppliers
9.2 The company shall have a documented supplier
approval procedure and continual assessment
programme in place, based on risk assessment.
9.2 These procedures shall include clear criteria for
ongoing assessment and standards of performance
required. Ongoing assessment may take the form of
monitoring performance through the following, although
this is not an exhaustive list:
• in-house checks
• certificates of analysis
• supplier audit as appropriate.
Records of this monitoring shall be retained.
9.2 The procedures shall define how exceptions are
handled, e.g. the use of products or services where
audit or monitoring has not been undertaken.
9.2 The company shall review the performance of new
suppliers against defined criteria within a specified
‘trial’ period and thereafter at a specified frequency to
decide the level of ongoing supplier performance
monitoring.
9.3 Incoming material requirements (Raw,
Ingredients /Packaging)
9.3.1 Specifications shall be adequate and accurate and
shall ensure compliance with relevant safety and
legislative requirements.
9.3.2 Raw materials or ingredients shall, where appropriate,
be inspected and sorted before processing. Where
necessary, laboratory tests shall be carried out to
establish fitness for use. Only sound, suitable raw
materials or ingredients shall be used.
9.3.3 Stocks of raw materials and ingredients shall be
subject to effective stock rotation.
9.3.4 The company shall seek formal agreement of
specifications with relevant parties. Where

Report No: Page 12 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
specifications are not formally agreed then the
company shall be able to demonstrate that they have
taken steps to ensure formal agreement is in place.
9.3.5 There shall be a documented procedure for the
amendment and approval of specifications for all parts
of the process including regular reviews to ensure
adequacy and status.
10 Measures for Prevention of Cross
Contamination
General Programs shall be in place to prevent, control
Requirement and detect contamination. Measures to prevent
physical, allergen and microbiological
contamination shall be included.
10.2 Microbiological cross contamination
10.2.1 Areas from where the threat to microbiological
contamination exists shall be identified. Based on
hazard assessment, the source shall be controlled.
10.2.2 The control measures shall be clearly defined,
documented and monitored. The records of monitoring
shall be available.
10.3 Allergen Management
10.3.1 The company shall carry out hazard assessment of raw
materials to establish the presence and likelihood of
contamination by allergens. This shall include approval
of raw material specifications. The company shall
implement systems to specify the integrity of the raw
material and compliance with specification throughout
the purchasing and supply chain.
10.3.2 Hazard assessment shall be carried out to identify
routes of contamination and establish documented
policies and procedures for handling raw materials,
intermediate and finished products to ensure cross
contamination is avoided. This shall include as
appropriate:

Report No: Page 13 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
• physical or time segregation while allergen
containing materials are being stored, processed or
packed
• use of identified, dedicated equipment for
processing or cleaning
• all food brought onto site including that by staff.
10.3.3 Where rework is used, or reworking operations carried
out, procedures shall be implemented to minimise
cross contamination from allergen-containing materials
and ensure the safety, legality and quality of the
finished product.
10.3.4 Consumer information shall be presented for allergen
contamination.
10.3.5 Validated equipment or area cleaning procedures shall
be documented and undertaken to remove or reduce to
acceptable levels any potential cross contamination in
compliance with finished product specifications.
10.4 Physical Contamination
10.4.1 Metal
There shall be a documented policy for the control of
the use of sharp metal implements including knives,
cutting blades on equipment, needles and wires. This
shall include suitable controls both into and out of the
factory, and safe disposal.
10.4.2 Glass and Brittle Material
Documented procedures for handling glass, brittle or
hard plastic, ceramic or other similar materials shall be
in place and implemented to ensure that necessary
precautions are taken. Procedures shall include as a
minimum:
• list of items detailing location, number, type and
condition
• recorded checks of condition of items carried out at
a specified frequency based on risk assessment
• details on cleaning or replacing items to minimise
potential for product contamination.

Report No: Page 14 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
10.4.3 Documented procedures detailing the action to be
taken in case of breakage of glass, brittle or hard
plastic and similar material, shall be implemented and
include the following:
• quarantining the products and production area that
were potentially affected
• cleaning the production area
• inspecting the production area and authorising to
continue production
• changing of workwear and inspection of footwear
• specifying those staff authorised to carry out the
above points
• recording the breakage incident.
10.4.5 Wood
In areas where a hazard assessment has identified the
potential for product contamination from wood, the use
of wood shall be excluded. Where the use of wood
cannot be avoided, and the risk is managed, the
condition of wood shall be regularly checked to ensure
it is in good condition and clean.
11 Cleaning and Sanitizing
General Cleaning and sanitizing programmes shall be
Requirement established to ensure that food processing
euipments and environment are maintained in a
hygienic condition. Programmes shall be
monitored for continuing suitability and
effectiveness.
11.2 Cleaning and Sanitizing agents and tools
11.2.1 Cleaning chemicals and equipment shall be:
• fit for purpose
• suitably identified for intended use, e.g. colour
coded or labelled
• stored in a hygienic manner to prevent
contamination.

Report No: Page 15 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
11.3 Cleaning and Sanitizing programs
11.3.1 The cleaning and disinfecting method(s) shall be
specified and documented. The water used will comply
with regulatory requirements. Contamination of food
with cleaning chemicals shall be prevented.
11.3.2 Cleaning and disinfection programmes shall ensure
that all parts of the establishment are appropriately
clean, and shall include cleaning of equipment. The
documented cleaning programmes shall specify:
 areas, items of equipment and utensils to be
cleaned;
 responsibility for particular tasks;
 method and frequency of cleaning;
 monitoring arrangements.
Where appropriate, programmes shall be drawn up in
consultation with relevant expert advisors.
11.4 Cleaning In Place (CIP) system
11.4.1 The methodology of CIP system shall be clearly
defined including concentration, time, type of chemical
used etc.
11.5 Monitoring and sanitation effectiveness
11.5.1 Cleaning and disinfection programmes shall be
continually and effectively monitored for their suitability
and effectiveness and documented.
11.5.2 Cleaning and disinfection procedures shall be
revalidated following building or maintenance work,
new product introduction or changes to equipment.
12 Pest Control
General Hygiene, Cleaning, Incoming material insoection
Requirement and monitoring procedures shall be
implemented to avoid creating an environment
conductive to pest activity.
12.2 Pest Control Programs

Report No: Page 16 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
12.2.1 A preventive pest control programme shall be
maintained covering all areas of the site to minimise
pest infestation. This shall include as a minimum:

 an up-to-date, signed and authorised site plan


identifying numbered pest control device locations
 identification of the baits and/or monitoring devices
on site
 clearly defined responsibilities for site management
and the contractor
 details of pest control products used and instructions
for their effective use.
12.2.2 The company shall either contract the services of a
competent pest control organisation, or shall have
appropriately trained staff, for the regular inspection
and treatment of the site to deter and eradicate
infestation. The frequency shall be documented. The
service contract shall be clearly defined and reflect the
activities of the site.
12.3 Preventing Access
12.3.1 Holes, drains and other places where pests are likely to
gain access shall be kept sealed. Where sealing is not
possible (e.g. open
windows, doors and ventilators) measures like wire
mesh screens shall be in place to reduce the problem
of pest entry.
12.3.2 Fly-killing devices and/or pheromone traps shall be
correctly sited and operational.
12.3.3 Bait stations shall be robust, of tamper resistant
construction, secured in place and appropriately
located to prevent contamination risk to product.
12.4 Harborage and Infection
12.4.1 Areas both inside and outside food premises shall be
kept clean. Where appropriate, refuse shall be stored
in covered, pest-proof
containers

Report No: Page 17 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
12.5 Monitoring and Detection
12.5.1 Detailed records of pest control inspections,
recommendations and actions taken shall be
maintained. It shall be the responsibility of the company
to ensure all of the relevant recommendations made by
their contractor or in-house expert are carried out and
monitored. The completion of corrective action shall be
demonstrated by documented evidence.
12.5.2 Results of pest control inspections shall be assessed
and analysed for trends regularly, but as a minimum:
• in the event of an infestation
• annually.
This shall include a catch analysis from trapping
devices to identify problem areas. Any such problems
shall be suitably rectified.
12.6 Eradiation
12.6.1 In the event of infestation, immediate action shall be
taken to eliminate the hazard. Action shall be taken to
identify, evaluate and authorise the release of any
product potentially affected.
13 Personal Hygiene and Employee Facilities
General Requirements for personal hygiene and
Requirement behaviours proportional to the hazard posed to
the process area or product shall be established
and documented. All personnel, visitors,
contractors shall be required to comply with the
documented requirements.
13. 2 Personal Hygiene Facilities and Toilets
13.2.1 Designated changing facilities shall be provided for all
personnel, whether staff, visitor or contractor. These
shall be sited to allow direct access to the production,
packing or storage areas without recourse to any
external area.

Report No: Page 18 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
13.2.2 Outdoor clothing and other personal items shall be
stored separately from workwear within the changing
facilities.
13.2.3 Suitable and sufficient hand-washing facilities shall be
provided at access to, and at other appropriate points
within, production areas. Such hand-wash facilities
shall provide as a minimum:
• sufficient quantity of water at an appropriate
temperature
• liquid soap
• single use towels or suitably designed and located
air driers
13.2.4 Toilets shall be sufficient in number and shall not open
directly into storage, processing or production areas
with minumum requirements as
 basins with soap and water at a suitable temperature
• adequate hand-drying facilities
• advisory signs to prompt hand washing
13.3 Staff canteens and designated eating areas
13.3.1 Where catering facilities are provided, they shall be
suitably controlled to prevent contamination of product.
13.3.2 Where eating of food is allowed outside during breaks,
this shall be in suitable designated areas with
appropriate control of waste.
13.3.3 All food brought into manufacturing premises by staff
shall be appropriately stored in a clean and hygienic
state. No food shall be taken into storage, processing
or production areas. Facilities for visitors and
contractors shall be such as to enable compliance with
the company’s hygiene policy.
13.4 Work wear and protective clothing
13.4.1 The company shall document and communicate to all
employees, contractors or visitors the rules regarding
the wearing and changing of protective clothing in
specified work areas, e.g. high-risk and low-risk areas.

Report No: Page 19 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
13.4.2 Protective clothing shall be available that is:
• provided in sufficient numbers for each employee
• of suitable design to prevent contamination of the
product (as a minimum contain no external pockets
or sewn on buttons).
13.4.3 There shall be no risk from the protective clothing for
any contamination including physical e.g. buttons etc.
13.5 Health status
13.5.1 There shall be written and communicated procedures
for employees, including temporary employees,
contractors and visitors, on action to be taken in the
case of infectious disease from which they may be
suffering or have been in contact. Particular
consideration should be given where product safety
may be compromised. Expert medical advice shall be
sought where required.
13.5.2 The employee health check will be done as per the
legal requirement of the country.
13.6 Illness and Injuries
13.6.1 Conditions which shall be reported to the management
in order to assess the need for medical examination
and/or possible exclusion
from food handling, include:
 jaundice
 diarrhoea
 vomiting
 fever
 sore throat with fever
 visibly infected skin lesions (boils, cuts, etc.)
 discharges from the ear, eye or nose
13.7 Personal cleanliness
13.7.1 Food handlers shall maintain a high degree of personal
cleanliness and, where appropriate, wear suitable
protective clothing, head covering and footwear.
13.7.2 When personnel with a minor injury are permitted to

Report No: Page 20 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
continue working, cuts and wounds shall be covered by
suitable waterproof dressings
13.7.3 Personnel shall always wash their hands when
personal cleanliness may affect food safety, for
example:
 at the start of food handling activities;
 immediately after using the toilet
 after handling raw food or any contaminated material
which could result in contamination of other food
items; they shall avoid handling ready-to-eat food,
where appropriate.
13.8 Personal Behaviour
13.8.1 People engaged in food handling activities shall refrain
from behaviour which could result in contamination of
food, for example:
 smoking
 spitting / chewing or eating;
 sneezing or coughing over unprotected food.
13.8.2 Personal effects such as jewellery, watches, pins or
other items shall not be worn or brought into food
handling areas if they pose a threat to the safety and
suitability of food.
14 Rework
General Rework shall be stored, handled and used in
Requirement such a way that product safety, quality,
traceability and regulatory compliance are
maintained.
14.2 Storage, Identification and Traceability
14.2.1 The rework material shall be kept in protected condition
to prevent from any contamination.
14.2.2 Allergen material seggregation protocol must be
followed.
14.2.3 Full traceability of reowork material including shift
details, batch details, product name etc shall be

Report No: Page 21 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
maintained.
14.3 Rework Usage
14.3.1 There shall be clear specification for the quantity of
rework / reuse material including the step in which it
gets added.
14.3.2 Where rework involve removing a product from the
filled / wrapped packets, the controls shall be in place
for segreggation of packing material and prevent cross
contamination to the product.
15 Product Recall Procedures
General Systems shall be in place to ensure that
Requirement products failing to meet required food safety
standards, can be identified , located and
removed from all points of supply chain.
15.2 Product Recall Requirements
15.2.1 The company shall have procedures designed to
manage effectively incidents and potential emergency
situations that impact food safety, legality or quality and
have effective product withdrawal and product recall
procedures in place including conditions under which it
may take place.
15.2.2 An incident management procedure shall be
documented, implemented and maintained. This shall
include as a minimum:
• identification of key personnel constituting the
incident management team with clearly identified
responsibilities
• an up-to-date list of key contacts, e.g. incident
management team, emergency services, suppliers,
customers, certification body, regulatory authority
• a communication plan including the provision of
information to customers, consumers and regulatory
authorities in a timely manner
• details of external agencies providing advice and

Report No: Page 22 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
support as necessary, e.g. expert laboratories,
regulatory authority and legal expertise
• product withdrawal and/or recall procedures
• corrective action and business recovery.
16 Warehousing
General Materials and Products shall be stored in clean,
Requirement dry, well ventilated spaces protected from dust,
condensation, fumes, odours and other sources
of contamination
16.2 Warehousing requirements
16.2.1 Procedures to maintain product safety and quality
during storage shall be developed. These may include
as appropriate the following, although this is not an
exhaustive list:
• controlling temperature
• cleaning storage areas including removal of waste
• segregating to avoid cross contamination or taint
uptake
• storing materials off the floor and away from walls as
appropriate
• Follow FIFO / FEFO system
16.2.2 Where temperature control is required, the storage
area or transport facility shall be capable of maintaining
product temperature within specification, under
minimum and maximum load and under worst case
ambient temperature. Storage areas shall be dry and
well ventilated with continuous temperature monitoring
devices.
16.3 Vehicles, Conveyances and Containers
16.3.1 Where the company employs third-party contractors, all
the requirements specified in this section shall be
clearly defined in the contract.
16.3.2 There shall be a clear record of dispatch and receipt of
goods and materials demonstrating that sufficient

Report No: Page 23 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
checks have been completed during the transfer of
goods.
16.3.3 Documented maintenance and hygiene procedures
shall be maintained for all vehicles and equipment used
for loading/unloading (e.g. hoses of silo installations)
inluding vehicle pre-loading and unloading inspection
records.
16.3.4 Procedures shall, where appropriate, be in place in the
case of vehicle or refrigeration equipment breakdown.
All incidents of vehicle or refrigeration equipment
breakdown shall be recorded and corrective action
documented.
17 Product Information and Consumer
Awareness
General Informattion shall be presented to consumers in
Requirement such a way as to enable them to understand its
importance and make informed choices.
17.2 Labelling of pre-packed foods
17.2.1 Each container of food shall meet national or
international labelling legislations.
17.2.2 Where the quantity of the product is not governed by
legislative requirements (e.g. bulk quantity), the product
must conform to customer requirements.
17.2.3 All food products shall be accompanied by or bear
adequate information to enable the next person in the
food chain to handle, display, store, prepare and use
the product safely and correctly. This also includes
information on advertisement, web etc.
18 Food Defence, Biovigilance and
Bioterrorism
General Establishment shall assess the hazards to the
Requirement products posed by potential acts of sabotage,
vendalism or terrorism and shall put in place

Report No: Page 24 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas
GAP Assessment Audit Report on PAS 220:2008
Name of the organization, Location

PAS 220:2008 Requirement Conform If No, Details along with evidences Proposed Corrective Action
Requirement (Yes / No / Not Major / with responsibility &
No. Applicable) Minor deadline
propotional protective measures.
18.1 Site Security
18.1.1 Staff shall be trained in site security procedures and
encouraged to challenge unidentified or unknown
visitors.
18.1.2 Based on risk assessment, procedures shall be in
place to ensure the secure storage of all materials
including ingredients, packaging, chemicals and
equipment and finished proudct.
18.1.3 Where required by legislation, the site shall be
registered with, or approved by, the appropriate
authority.
18.2 Access Control
18.2.1 Access to the site by employees, contractors and
visitors shall be controlled and a visitor reporting
system shall be in place. Only authorized personnels
shall be allowed to enter in the processing faciltiy
18.2.2 There shall be a plan of the site which defines access
points for personnel, travel routes and staff facilities
with the logical routing.
18.2.3 Contractors and visitors, including drivers, shall be
made aware of all procedures for access to premises
and the requirements of the areas they are visiting, with
special reference to hazards and potential product
contamination.

Report No: Page 25 of 25


This report shall not be reproduced in part without the permission of Det Norske Veritas

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