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Zardasht Company Ltd.

Contracting and General Trading


WWW.ZARDASHT GROUP.COM

HACCP program

Document Control

Document title: ZARDASHT COMPANY PROFILE


Effective date: 25 Nov 2017 Policy number : ZC-PRO-0020

Last revision Date:July2020 Revision Number :3

Prepared by

Name: Sana I. Yousif Title: QHSE Manager Signature:

Approved by

Name: Idrees Y. Khorsheed Title: General manager Signature:

Next revision Date: July 2020

Iraq - Erbil - Ainkawa - Gazna Road - Gazna Base / Mob. 0750 445 0263 / Mob.
0750 449 6629
Email: idres_yousif@hotmail.com / idrees@zardasht-group.com
PURPOSE / SCOPE
Zardasht company Ltd, is committed to assisting our customers to provide safe food and
animal feed products for the nation and some parts of the world.
The purpose of this program is to ensure that all Zardasht company Ltd, staff are aware of the
steps necessary to ensure the safety of human food and animal feed products we may come in
contact with or processes we work around.
It is our responsibility when we work for our food processing customers, to take any steps
needed to ensure that the products we are around are 100% safe for consumption.
We will use each applicable customer’s Standard Operating Procedures (SOPs) to ensure the
safety and regulatory compliance of manufactured products is followed.
These rules have been created to prevent the contamination of food products by any unknown
material(s) whether it is a tool, part, chemical, bacteria, or particulate (such as wood, glass, or
metal). Food Safety is “everyone’s” responsibility.

 Case Study: A single tool is left in a small 130-gallon tank. If it is not


retrieved in time, it contaminates 9,000 gallons of product. This product is sent
out in multiple tankers/trucks to many different locations to be processed into
human food. Then, that food is distributed all over the country for consumers.
One truck load of Citric Acid could contaminate almost 54 million cans of
soda pop. Ultimately, a product that we contaminate could potentially affect
millions of people. What started as a small retrieval is now a global recall.
YOU CAN make a difference!

All contractors must take Food Safety seriously. Remember, if we contaminate the product
with anything from tools, dirt, grease, ear plugs, pencil/pens, washers, etc., you and your
families are only a few hours away from being the consumer that might purchase a
contaminated product!

DEFINITIONS

FINISHED PRODUCT AREA


Any area in the plant that produces a product that will be sent to a customer.

LOAD OUT AREA


Any area where product is loaded into truck or rail cars.

GOOD MANUFACTURING PRACTICES (GMPS)


as defined by the Food and Drug Administration in 21 CFR part 110 are the minimum
sanitary and processing requirements for food companies. GMPs are fairly broad and general

Iraq - Erbil - Ainkawa - Gazna Road - Gazna Base / Mob. 0750 445 0263 - 0750 449 6629 - 0750426 9666
Email: idres_yousif@hotmail.com / / idrees@zardasht-group.com
and can be used to help guide the development of Standard Operating Procedures (SOPs)
which are very specific.

FOODBORNE DISEASES
are the illnesses contracted from eating contaminated food or beverages? Illnesses include
foodborne intoxications and infections, which are often incorrectly referred to as food
poisoning. There are more than 250 different foodborne diseases. They are caused by viruses,
bacteria, parasites, toxins, metals, and prions.

FOODBORNE ILLNESS
Symptoms of foodborne illness range from mild gastroenteritis to life-threatening neurologic,
hepatic, and renal syndromes. Botulism, Brucellosis, Campylobacter enteritis, Escherichia
coli, Hepatitis A, Listeriosis, Salmonellosis, Shigellosis, Toxoplasmosis, Viral gastroenteritis,
Taeniasis and Trichinosisare examples of foodborne diseases. The quality of food, and
controls used to prevent foodborne diseases, are primarily regulated by the US Food and
Drug Administration (FDA), the Centers for Disease Control and Prevention (CDC), and
local public health authorities. These diseases may be occupationally related if they affect the
food processors (e.g., poultry processing workers), food preparers and servers (e.g., cooks,
waiters), or workers who are provided food at the worksite.

ALLERGENS
Allergenic food products are available in vending machines in break rooms and shall remain
in designated areas. Do not take these products into processing areas. These foods can only
be consumed and stored in approved areas. Do NOT ignore these rules. They are designed to
prevent someone from having a serious allergic reaction or death. The FDA Big 8 list of
allergens in the US are products containing:
Milk
Eggs
Fish
Shellfish
Tree Nuts
Peanuts
Wheat and
Soy
In our day-to-day life we may not think of these foods as deadly. However, to many people
these substances are a serious health hazard and can be fatal. Typical symptoms to allergic
food reactions are; Gastrointestinal, Systemic, Cutaneous and Respiratory. Life-threatening
reactions can occur such as Anaphylactic Shock which can cause shock, shortness of breath,
unconsciousness and death can occur within 15 – 30 minutes of exposure.

Iraq - Erbil - Ainkawa - Gazna Road - Gazna Base / Mob. 0750 445 0263 - 0750 449 6629 - 0750426 9666
Email: idres_yousif@hotmail.com / / idrees@zardasht-group.com
GOOD MANUFACTURING PRACTICES (GMP)
is a regulation for food or pharmaceutical facilities to produce high quality products for
human and animal consumption. GMP includes the following practices; Batch Records,
Personal Hygiene, Pest Control, Plant Sanitation, Maintenance, Purchasing of Materials,
Metal Detection, Product Retrieval, Water, Rework, Transportation and Product Labeling. It
is extremely important to follow all customer, state and federal regulations to reduce food
contamination.
A STANDARD OPERATING PROCEDURE (SOP)
is a set of step-by-step instructions compiled by an organization to help workers carry out
complex routine operations. SOPs aim to achieve efficiency, quality output and uniformity of
performance, while reducing miscommunication and failure to comply with industry
regulations.

HAZARD ANALYSIS CRITICAL CONTROL POINTS (HACCP)


is a preventative system of food control where quality is defined as conformance to
requirements and the standard is zero defects achieved through monitoring, verifying, and
validating that the system is working. There are three (3) main hazard types:
1. Physical Material; glass, wood, stones, metal, insects, plastic and personal effects
2. Chemical; Naturally occurring poisonous or toxic chemicals
3. Biological; bacterial, viral, and parasitic

CRITICAL CONTROL POINTS (CCPS)


is defined as any point in the chain of food production from raw materials to finished product
where the loss of control could result in an unacceptable food safety risk. These are specific
points, procedures, or steps in food manufacturing at which control can be exercised to
reduce, eliminate, or prevent the possibility of a food safety hazard.

EMPLOYEE RESPONSIBILITIES
GENERAL GUIDELINES
 Loss of any item (pens, glasses, earplugs, tools, parts, etc.) while working on
equipment, around open tanks or pipes, or around raw materials must be reported
immediately to your foreman or control room. Don’t
wait!
 Protect against wood chips/shavings, glass, brittle plastic, and ceramic contamination.
No glass bottles are allowed in the plant on site. Any instances of broken glass, brittle
plastic, or ceramic must be reported to a supervisor immediately.
 Assure the area is clean prior to cutting into the system and after you have completed
your work. Only approved cleaning compounds may be used.
 Do not carry any unnecessary materials into a work zone. The less you have to lose,
the better.
 Keep all doors and plant entry points closed at all times when not in use. Do not prop
doors open. Use installed Knappco doors, if available, to route cords, leads, and
hoses.

Iraq - Erbil - Ainkawa - Gazna Road - Gazna Base / Mob. 0750 445 0263 - 0750 449 6629 - 0750426 9666
Email: idres_yousif@hotmail.com / / idrees@zardasht-group.com
 Work areas must be kept clean and orderly. Trash includes welding rods,
nuts/bolts/washers, wire strippings, wire tie ends, wire nuts, and stake on connectors,
as well as any paper or material left after the job is completed. Trash cans must be
labeled and must have lids. They should be emptied often.
 Assure that trash and materials are cleaned up and the area is inspected and clean
prior to leaving the job. Report to your supervisor when the work is expected to be
complete so that it can be inspected in a timely manner.
 Do not use food grade hoses for non-food grade use, for example sump pumps.
 Ensure food grade hoses that will be used for food grade use are properly sanitized.
 Food sampling equipment and thermometers must be cleaned and sanitized before
each use and safely labeled that will not put product at risk.

PERSONAL HYGIENE
 Practice good personal hygiene. Keep yourself clean. All personal hygiene standards
apply to all contractors, visitors, maintenance, management, supervisory, and
laboratory personnel when present in production areas.
 No employee, when having diarrhea, vomiting, fever, sore throat with fever, open or
visibly infected skin sores, bleeding, discharges, jaundice, Hepatitis A or any
infectious communicable disease shall be permitted to work in any product process
building, for either food or feed products.
 All cuts, abrasions, and sores shall be covered at all times with clean band-aids that
are food grade metaldetectable. These metal detectable wound coverings are typically
blue.
 Clothing should be in good repair and should not have buttons. Clothing must be
reasonably clean at all times. Employees should change clothing if they become
unreasonably dirty. If you are dirty, get a pair of Tyvek suits to cover your work
clothes or have a spare change of clothes at work.
 Carrying of any items such as pens, pencils, notepads, etc., in pockets above the waist
is prohibited. No bib overalls are allowed at some locations.
 Hands must be thoroughly washed with antibacterial soap and water or sanitized with
an alcohol-based hand sanitizer after every visit to the lavatory and before and after
eating and drinking. Hand washing reminder signs will be posted in all lavatories and
break rooms where eating and drinking is allowed.
 Fingernails should be kept clean and neatly trimmed. No fake fingernails or nail
polish is allowed unless covered by gloves.
 Jewelry; piercings, necklaces, ring, earrings, ear gauges, watches, or cosmetic items
will NOT be worn in finished product areas. Wedding rings or other rings are not
allowed unless hands are covered by a glove or tape - band-aids are not sufficient
coverage.
 NO tobacco products (including chew) or spitting is allowed ANY WHERE on site.
 Take break only in designated break areas.
 Food, food allergen products, drinks, chewing gum, candy, toothpicks, or
medications are NOT allowed in production areas.
 Drinking water is allowed in some customers locations to prevent dehydration. Water
must be in clear, closed, labeled bottles or containers. Coffee, tea, Gatorade or energy
drinks must be consumed at break locations and are not allowed in production areas.
 Check your boots, they can carry dirt and other contaminates everywhere. A good
example is to look under most stairways that have grating steps and see just how
much trash and dirt there is that has fallen off shoes and personnel.

Iraq - Erbil - Ainkawa - Gazna Road - Gazna Base / Mob. 0750 445 0263 - 0750 449 6629 - 0750426 9666
Email: idres_yousif@hotmail.com / / idrees@zardasht-group.com
 Any person who has come into contact with water or mud that has been contaminated
or possibly contaminated with flood or sewer water must not enter any of the
production facilities until proper cleaning and sanitation of clothes, PPE, and the
person has taken place. Cleaning and sanitation stations are located at designated
areas on site and must be used prior to entering facility. Directions for cleaning and
sanitation are posted at the stations.

PPE
 Clothing and PPE must be maintained in good, sanitary condition along with a high
degree of personal cleanliness and personal hygiene to prevent potential
contamination.
 Hair nets and beard nets must be worn in all load-out, packaging areas, production
and all other sensitive areas of the facility. Watch for signs and obey their
instructions.
 Ear plugs must have the string attached and secured to your hardhat or shirt. DO
NOT take the strings off of your earplugs!
 Safety glasses must be secured or worn with chums.
 Any time gloves touch a non-food grade surface that may become contaminated,
need to be replaced with clean gloves.
 Touching of product that is not removed from the production stream, with bare hands
is prohibited. Product that is not removed from the process stream may be touched
with impervious gloves that have been washed according to the hand washing
standard. Any product samples removed from the process area for inspection or
analysis must be discarded and not returned to the process.

PAPERWORK/PERMITS
 Data entered only by the person who performed the work / inspection.
 All entries must be dated and signed/initialed by the person making the entry.
 All data must be written in black or blue non-erasable ink (NO GEL PENS).
Erroneous entries must be cancelled with a single line through the item and initialed –
no scribbling, no “white-out”, or erasing.
 Do not leave documents lying around.
 Do not give copies of completed documents to anyone outside the company.
 Falsification of documents is unacceptable.
 Return permits to the customer when work is completed or at the end of the day.

PRODUCT LINES
 Follow all customer SOPs for the process system you are working on.
 Always follow lockout/tagout, permit and safety procedures before starting any kind
of work.
 Prior to start of work, identify and account for any tools used in the procedures. Tools
should be free of dust, dirt, oil, grease and other types of foreign material before
starting work on equipment.
 Some equipment or tools may need additional cleaning with high pressure washer to
remove any metal or dirt hanging on the sides of the equipment. Some tools may need
to be sanitized with an approved sanitizing solution. Discuss with your site contact
before starting work.

Iraq - Erbil - Ainkawa - Gazna Road - Gazna Base / Mob. 0750 445 0263 - 0750 449 6629 - 0750426 9666
Email: idres_yousif@hotmail.com / / idrees@zardasht-group.com
 Inspect and clean all replacement parts or equipment. New parts/equipment need to be
free of dust residues, insects, or other foreign material. These may be washed with
Potable Water to clean.
 Efforts shall be made to cover cleaned equipment with plastic, if reassemble is
conducted over several days or an extended period of time.
 Look on the levels below your work area where work is to be performed to make sure
you are not contaminating areas beneath. Use barricades and/or protective covers or
cloths if necessary.
 Purge pipes for welds. Purge welds must be smooth and sanitary. Clean all welded
joints and connections inside and out. Deburr all cuts and examine these to assure
they are smooth and even. Cover all fabbed pipe ends to keep out contaminates.
 Metal shavings and welding slag must be removed. Extra care is needed when a
plasma or a mig welder is used. Slag from both, are extra hard to clean up. Equipment
such as pumps, tanks, or piping that has been welded should be flushed to remove
slags before putting back in service.
 Keep scrap welding rods and trash picked up in properly labeled bucket.
 Make sure there is a flange connection close enough to all welded joints so the inside
can be cleaned. Make sure all bolted flanges are cleaned and examined thoroughly.
 Valves in food grade lines have to be lined or approved for use for food grade.
 Make sure there are no dead ends that could hold product that could become stagnate
and contaminate the system.
 Once all foreign material is removed, the equipment that comes in contact with human
food grade materials shall be washed or flushed with 180°F potable water and then
inspected for foreign material and chemical residues.
 Animal feed grade surfaces may be washed with potable water if appropriate for
equipment and product. Conveyor lids shall be inspected with lids open for foreign
material. Animal feed equipment shall be inspected for foreign material and chemical
residues before reinstating or putting back in use.
 After work is done, the equipment must be inspected and cleaned.

LIGHTING
 Use approved lighting sources to inspect interior equipment surfaces for any metal
fragments, shavings, and welding slag embedded onto the surfaces of the equipment.
Remove any foreign material and tools.
 Lighting must have break resistant lenses or shatterproof shields. It should also be
moisture resistant and cleanable. Report any broken bulbs or glass to your foreman
immediately.
 Assure that all covers remain in place over light fixtures. Lights need to be shielded to
prevent product exposure to glass. Sleeves can be used over fluorescent lighting and
protected or shielded glass needs to be used in all food applications.

CHEMICALS
 No chemicals, gasket materials, lubes, sealants, or adhesives can be used unless it
has been approved. To determine if something is approved on site, ask your
customer representative if they are accepted.
 Approval must be obtained for all new or expanded use, or change of any
manufactures, of any product before it can be taken into a customer location.

Iraq - Erbil - Ainkawa - Gazna Road - Gazna Base / Mob. 0750 445 0263 - 0750 449 6629 - 0750426 9666
Email: idres_yousif@hotmail.com / / idrees@zardasht-group.com
 All material exposed to the product has to be food grade. Food grade lubrication
shall be stored separately from nonfood grade products.
 Apply only enough food grade lubricant to do the job. Do NOT over apply.
However, if over lubrication occurs, there should be a plan in place to remove the
excess lubricant before putting the equipment back in service such as, all
oil/grease residues must be wiped off surfaces with a clean disposable towel.
 Any chemical that is defined as hazardous by OSHA 29 CFR 1910.1200 must
have a Safety Data Sheet available for review.
 All chemicals used for cleaning and disinfection in the plant must be appropriately
labeled and shall be stored in a locked closet or restricted area if the closet or area
opens into a processing area. Chemicals must be used in a manner consistent with
the manufacturer’s label.
 All chemicals stored in secondary containers must be labeled appropriately. All
maintenance related chemicals including WE-40, anti-seize, coolants, etc., must
be removed from the area when the job is complete.

CONFINED SPACES
 Discuss vessel entry requirements during the PJHA and Confined Space
Permit process.
 A customer representative must be contacted after human food grade storage
vessels have been cleaned and sanitized for final approval.
 Cover any manways into tanks prior to doing the work, if possible.
 Excess materials such as welding rods, nuts, and bolts, should be collected and
removed from the area, making sure that none are inadvertently left inside the
equipment.

MATERIAL STORAGE, TRASH & PEST HARBORAGE


 Assure proper storage of all materials and fabricated parts (cover the ends).
Store inside when possible. If parts are stored outdoors, a cleaning SOP should
be competed and inspection should verify that the part is clean.
 Motors, pumps, and other equipment need to be covered with plastic or tarps
until ready for installation. Don’t remove from shipping crate unless
necessary.
 Even if stored inside – clean before installing. Have it sandblasted, caustic
cleaned, or rinse with water, whatever it takes to clean it. If sandblasting or
cleaning with chemicals, assure a total rinsing to remove the material used for
cleaning. Assure that the equipment is dry prior to installation.
 Pipe storage - tape off and cover all fabricated fittings and pipes to keep out
contaminates.
 Close lids on all labeled trash receptacles and keep doors closed to prevent
pests from entering the building. Dispose of trash items such as general trash,
wood, or scrap metal in designated dumpsters. Do NOT overfill them beyond
the dumpster edges. Be proactive and contact your customer representative to
get them emptied when necessary.
 When working on piping, conduit, or steel that is going through buildings and
siding, make sure the areas around the penetrations are sealed.
 Remove scaffolding, welding blankets and other materials, that are potential
harborage areas from the work site when the job is complete.

Iraq - Erbil - Ainkawa - Gazna Road - Gazna Base / Mob. 0750 445 0263 - 0750 449 6629 - 0750426 9666
Email: idres_yousif@hotmail.com / / idrees@zardasht-group.com
 Report chronic pest activity to your plant contact. Be as specific as possible.
What, when and where are key to eliminating pest problems.
 Outside of buildings must be kept clear of contaminants, trash, garbage,
broken pallets, chunks of cribbing, etc.
 Use dunnage or cribbing to keep everything up off the ground and out of the
mud or rock to prevent contamination and pest harborage and infestation.
 Lockers should contain clothing, PPE, personal items only and kept in orderly
manner. Overnight storage of opened food or perishable items is prohibited.

TOOL IN – TOOLS OUT


 Remember the rule—” tools in, tools out”. Ensure all parts, tools and materials
are picked up and accounted for before returning systems back to service.
 If you go into a job with 10 tools, be sure you leave with 10 tools.
 Tools need to be cleaned before and after the job where product contact is
possible.
 Tie off your tool if there is a chance of dropping it. Tie a lanyard to the tool
and to your wrist or a stationary object.
 If you do lose a tool or part, let someone know immediately! Remember, we
are just a matter of hours from the process ingredients to becoming a product
on the shelf for a consumer.

WHAT ARE SOME FOOD SAFETY TRIGGERS THAT SHOULD


REQUIRE YOU TO STOP WORK?
 If it affects your safety or food safety STOP and reevaluate the job.
 Lost tool, dropped personal item (cell phone, pen, contact lens/glasses,
etc.)
 Changing weather conditions (rain, wind, etc.)
 Presence of birds/pests around open product
 Scope change of work, cutting a line that was not planned
 Need to bring in a new chemical to complete the job
 Moving tools from allergen-controlled area
 When in doubt ASK

OTHER OSHA STANDARDS PERTAINING TO FOOD:


CONSUMPTION OF FOOD AND BEVERAGES ON THE PREMISES
This paragraph shall apply only where employees are permitted to consume food or
beverages, or both, on the premises. [1910.141(g)]
 Eating and drinking areas. No employee shall be allowed to consume food or
beverages in a toilet room nor in any area exposed to a toxic material.
 Waste disposal containers. Receptacles constructed of smooth, corrosion resistant,
easily cleanable, or disposable materials, shall be provided and used for the disposal
of waste food. The number, size, and location of such receptacles shall encourage
their use and not result in overfilling. They shall be emptied not less frequently than
once each working day, unless unused, and shall be maintained in a clean and sanitary
condition. Receptacles shall be provided with a solid tight-fitting cover unless sanitary
conditions can be maintained without use of a cover.

Iraq - Erbil - Ainkawa - Gazna Road - Gazna Base / Mob. 0750 445 0263 - 0750 449 6629 - 0750426 9666
Email: idres_yousif@hotmail.com / / idrees@zardasht-group.com
 Sanitary storage. No food or beverages shall be stored in toilet rooms or in an area
exposed to a toxic material.
 Food handling. All employee food service facilities and operations shall be carried out
in accordance with sound hygienic principles. In all places of employment where all
or part of the food service is provided, the food dispensed shall be wholesome, free
from spoilage, and shall be processed, prepared, handled, and stored in such a manner
as to be protected against contamination.

APPENDIX A TO §1910.272 GRAIN HANDLING FACILITIES


The use of edible oil sprayed on or into a moving stream of grain is another method
which has been used to control dust emissions. Tests performed using this method have
shown that the oil treatment can reduce dust emissions. Repeated handling of the grain
may necessitate additional oil treatment to prevent liberation of dust. However, before
using this method, operators of grain handling facilities should be aware that the Food
and Drug Administration must approve the specific oil treatment used on products for
food or feed.

BLOODBORNE PATHOGENS Food and drink shall not be kept in refrigerators,


freezers, shelves, cabinets or on countertops or benchtops where blood or other
potentially infectious materials are present. [1910.1030(d)(2)(x)]

HEXAVALENT CHROMIUM Whenever the employer allows employees to consume


food or beverages at a worksite where chromium (VI) is present, the employer shall
ensure that eating and drinking areas and surfaces are maintained as free as practicable of
chromium (VI). [1910.1026(i)(4)(i)

TRAINING
 All Zardasht Company Ltd, employees must go through food safety training as
part of their orientation at various customer locations.
 Employees must demonstrate knowledge of food safety by passing an annual
customer orientation and food safety review.
 Food safety training will include Good Manufacturing Practices and customer
requirements.
DOCUMENT CONTROL:
Initial Program November 25, 2017

Iraq - Erbil - Ainkawa - Gazna Road - Gazna Base / Mob. 0750 445 0263 - 0750 449 6629 - 0750426 9666
Email: idres_yousif@hotmail.com / / idrees@zardasht-group.com

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