Information Sheet 64: how do you keep your monitoring plan up to date?

What does the NVWA write about this in Information Sheet 64? 

“The NVWA expects you to have continuous visibility of risks and to be able to demonstrate that you're taking the right measures,” says Hans van der Moolen, manager of the Expertise Center at Eurofins Food Safety Solutions. This includes: 

• At least once a year, an update of your hazard and risk assessment (GIRA). 
• With every relevant change, you must reassess the hazards and risks. Think of the following situations: 
  1. You choose new suppliers, new raw materials, or introduce new products into your range. 
  2. You adjust an existing product in composition or packaging. 
  3. Changes in legislation. 
  4. New insights into the likelihood and severity of risks (for example via RASFF notifications, scientific studies, or your own analyses). 

“If you only do an update annually, you're taking a risk” 

“I regularly speak to retailers, importers or buyers who think that updating their monitoring plan annually is sufficient. After all, GFSI, BRC or IFS guidelines also state that you must update ‘at least annually’. But if you only update it annually, you're taking a risk. To illustrate: legislation around contaminants sometimes changes several times a year. In that case, you may miss a new risk for months – a risk for which you are still responsible if you cannot demonstrate that you have addressed it,” says Van der Moolen. 

What makes keeping a monitoring plan up to date so complex? 

“Keeping a monitoring plan up to date means you have to be continuously alert to various factors,” continues Max van Leeuwen, director of Eurofins Food Safety Solutions. “With that information, you have to assess the hazards and risks for your product and understand what it means for your monitoring plan. That requires quite a bit of work and insight.” These are the different factors: 

“Every new supplier calls for a reassessment of the GIRA and possibly extra checks.” 

New suppliers, new raw materials, or introducing new products into your range
an Leeuwen: “Every new supplier calls for a reassessment of the GIRA and possibly extra checks. The fewer products a supplier delivers, the more you relatively need to sample. Because that means you're working with many suppliers. You're required to maintain the √n sampling frequency per product group per supplier. So it can be smart to choose fewer suppliers and take more raw materials or products from reliable suppliers. And if you choose new raw materials or buy different products, you also need to look at the risks associated with those raw materials or products.” 

Changing legislation
Van der Moolen: “Contaminant legislation in particular changes regularly, even several times a year. Think of stricter standards for heavy metals, mycotoxins or residues. You naturally want to factor that into your risk assessment and monitoring plan.” 

Changing risk assessment
“Recent RASFF notifications or your own analyses may show that a risk is increasing or decreasing. Those trends need to be translated into your monitoring plan,” says Van der Moolen. 

Coordination between purchasing and QA 
Purchasing decisions have a direct impact on your monitoring plan. Max van Leeuwen: “We often see that the purchasing department doesn't consider the extra checks that a new supplier or raw material/product requires. Involve each other in good time, otherwise you make choices that aren't smart from a QA perspective.” 

Tips & tricks for an up-to-date monitoring plan 

So what can you do to keep your monitoring plan up to date? Here are the best tips from Van Leeuwen and Van der Moolen:

• Check more often than annually whether your monitoring plan needs an update: update it with every relevant change, not only during the annual audit round. 
• Carry out a thorough supplier assessment for new suppliers. 
• Be smart in your choice of suppliers: the fewer suppliers, the clearer and more efficient your monitoring plan. 
• We see more deviations in raw materials/products from outside the EU than from within the EU. That makes sense, since suppliers from outside the EU don't always intend to bring their products to the EU market. Different rules simply apply outside the EU. Tip: factor this risk into your assessment. 
• Use data from comparable products where possible, but stay alert: a new supplier requires more substantiation than an existing one. 
• Keep track of changes in laws, regulations and guidelines, and incorporate them into your monitoring plan. 
• Keep track of RASFF notifications, your own analysis results, scientific studies and market developments, and factor these trends into your GIRA. For example, Gemzu recently developed the SAR methodology, with which you can safeguard the risk of listeria in soft cheeses. 
• Coordinate regularly with buyers and make sure they know what costs are involved in risk safeguarding. Structurally link purchasing and QA, to prevent decisions in one department leading to unexpected costs or risks in the other. 
• Realise that certification alone is not sufficient; you must be able to demonstrate that all relevant risks have been taken into account. 
• If existing products change in composition or packaging, carry out a risk analysis or validation to continue safeguarding the related risks properly. 

Support: fully unburdened 

Still finding it a challenge to keep your monitoring plan up to date despite our tips? We completely understand — many companies struggle with this. Keeping your monitoring plan up to date is labour-intensive and requires specialist knowledge. Did you know that the specialists at Eurofins Food Safety Solutions can take this work off your hands completely, giving you one less thing to worry about?

We then take care of: 

• Tracking legislation and RASFF notifications 
• Updating your GIRA and monitoring plan 
• Monitoring product risks 
• Selecting the right analyses via our Eurofins laboratories and correctly interpreting the results 

This way, you can be sure that your monitoring plan is always up to date, without having to keep on top of it yourself. One point of contact, fully unburdened.