SGS SA (SGSN) Earnings Call Transcript & Summary

Hello, everybody, and welcome along to the Decoding the Changes to the FSSC Standard Webinar by SGS. In today's webinar, we're going to cover some of the key topics in the new version of the FSSC standard. During the webinar, I will cover the following topics: Firstly, a brief introduction. Then we'll look at the time line for implementation of the new version of the standard. Then we'll focus on the new additional requirements that have been included. Then we'll focus on the food safety culture aspects that need to be taken into consideration. We'll have a short conclusion, and then we'll end the session with a 15-minute question-and-answer session. In this presentation, we're going to cover the significant changes to the FSSC Version 5.1 standard. Whilst the changes are relatively small, there are some things that probably certified organizations need to take into consideration, especially as they are required to transition to Version 5.1 through the course of 2021. I'll go through each of the changes to the additional requirements and the reason why there are these changes in some detail. I'll also talk about the change to bring in an element of food safety culture and what that change is and what is required from yourselves, the certified organizations. I'll also talk about one of the changes that may mean an increase in the on-site audit duration, which potentially could have a very significant impact for small facilities. The FSSC published Version 5.1 of their standard in November 2020. In the period from the publication until the 31st of March, we are required to audit the FSSC Version 5 standard. And then from the 1st of April onwards, we're required to audit against the FSSC Version 5.1 standard. So there's a very hard transition period. So you need to start preparing yourselves to be ready for your audit in 2021 being against FSSC Version 5. Hopefully, as most of you are aware, the FSSC standard is fundamentally based on the ISO 22000 food safety standard. In order to meet the GFSI benchmarking requirements, the FSSC opted the ISO 22000, a prerequisite program which is industry dependent and so will depend on the sector of the food industry that you operate within. And on top of that, they added the additional requirements to ensure that the whole standard is in compliance with the GFSI benchmarking document. So as I mentioned, the FSSC Version 5 standard was published on the 3rd of November 2020. Implementation of the standard is immediate with the transition mandatory after the 31st of March 2021. So that fundamentally means that the first audit that you have after the 31st of March 2021 against FSSC will be performed against the Version 5.1 requirements. There were minor changes made to the standard, and we will see those shortly through the additional requirements to align it with the GFSI benchmark and also some changes made to the minimum audit duration to increase it from the current 1.5 man-days to 2 man-days. So this would impact on smaller sites that have a few employees or a low number of HACCP study. There are also 2 exemptions to this based on very small sites with fewer than 5 employees and 1 HACCP study or fewer than 20 employees and 1 HACCP study. So just to summarize the transition process. The FSSC has mandated that it is not possible to upgrade directly from Version 4.1 to Version 5.1. So this would mean that you would need to have your transition from Version 4.1 to Version 5 and then further onwards from Version 5 to Version 5.1. The only time that is possible is when the transition audit is conducted during a recertification audit, and then it is possible to transition from Version 4.1 to Version 5 as long as that recertification audit takes place after the 1st of April. Obviously, in that case, it's very likely that the reason that you haven't currently got a Version 5 certificate is because you've been affected by COVID-19. For clients that are newly considering implementation of FSSC, then it would be possible to conduct the Stage 1 audit against Version 5 and the Stage 2 audit against Version 5.1 where the date for the Stage 2 would fall after the 1st of April. On the following slide, I've included the table taken directly from the FSSC transition guidance document that clearly defines the audits that are required and what the position is with regards to the FSSC and the upgrade of your certification. On this slide, you can see the progression of audits and the options that are available to you in 2021. So you would need to determine which audits you've had in previous years or if you've missed an audit through a COVID-19 concession and what action is required from you in 2021 to either complete the missed audit from 2020 or to complete the missed audit and to have your transition upgrade audit to FSSC Version 5.1. As I mentioned, in order to comply with the GFSI benchmarking document, the FSSC have included 6 new requirements and made amendments to 2 existing additional requirements. As you can see from the list on the screen, the 2 amended requirements are management of services and the addition of purchased materials. There is an amendment made to product labeling and then 2.5.10, 2.5.11, 2.5.12, 2.5.13, 2.5.14 and 2.5.15 are all new requirements that are included in FSSC Version 5.1. As you can see from this summary slide, all of the requirements from 2.5.1 to 2.5.9 have previously been included in FSSC Version 5. The only amendments here have been made to 2.5.1 and 2.5.2. And here, we have a list of the new requirements that are included in FSSC Version 5.1. And as you can see, none of these requirements appeared in the Version 5 standard. In some cases, the additional requirements do not apply to all food chain categories. So it's important to assure that you take this into account when you consider how to implement the standard into your system. So for example, if you are a Category D producer, which is animal feed and pet food, then you -- the considerations of the additional requirements you need to implement will be slightly different to if, for example, you're in Category C, where you would need to include formulation of products as one of the additional requirements that you would have to consider. So once again, in the new additional requirements, there are some requirements that only apply to very specific sectors and other requirements that apply across the whole of the food sector. So you just need to make sure that you take this into consideration when you're designing your system or you're considering the implementation process of Version 5.1 to make sure that you're demonstrating compliance with the correct additional requirements as part of your FSSC 22000 audit. In order to give some greater understanding of the changes that have been made to the amended or new requirements, I'll go through each one in some detail. So the first thing to note is the inclusion of internal laboratories in the first part of clause 2.5.1. So not only is it a requirement that external laboratories have some kind of repeatability testing, but also the internal laboratories are also conducting some kind of repeatability testing. And remember, it's not mandatory to have certification or accreditation against ISO 17025. It's more about having the fundamental key components of the process in place to ensure that the results generated by the internal lab are repeatable and consistent. The next part is about having emergency suppliers. So in situations such as we have currently with the global pandemic where suppliers may not be able to provide you with the raw materials that you need, then you need to have some kind of process in place to identify alternative sources of raw materials and determine how those raw materials are controlled. So it may be that there is no possibility to conduct a supplier evaluation, so there might be an alternative methodology in place to approve that supplier and that raw material, for example. So continuing on with 2.5.1. So there's a specific requirement where animal products, and within that we include fish and seafood, are purchased as part of a -- as an input into your process. And this is specifically looking at things that might be present in those particular instances that may pose a risk to the finished products. So for example, pharmaceuticals, medicines, heavy metals, pesticides and so on. That would only apply in limited cases. And then the very last point is about food Category C, which is food manufacturing; D, feed; I, packaging; G, transport and storage; and K, biochemicals. There is another additional requirement about product specifications, having a very specific review process in place to ensure that the specification remains up-to-date and is still in compliance with any relevant regulatory or legal aspects and also that it still continues to meet the customers' expectations. Another existing additional requirement that's been slightly amended is 2.5.2. The additions here, you can see in the red text on the screen, are fundamentally what really has changed here is this idea that actually some products, and in particular bulk raw materials, may not be individually labeled. And therefore, the information specific to the product might be available in alternative ways, perhaps through the provision of a data sheet or maybe it's done electronically and the information is held online. It's really about recognizing the fact that even if a product is unlabeled, there is still a need to ensure that the customer or consumer is provided with the correct information related to that product. The additional requirements that haven't changed, as you can see, 2.5.3, 2.5.4, 2.5.5, 2.5.6, 2.5.7, 2.5.8 and 2.5.9, there's been no amendments made to these additional requirements as none was felt to be necessary. Now we'll move on to look at the new additional requirements, and the first of those is 2.5.10, storage and warehousing. As the name suggests, this is a requirement specifically related to the storage activities that are undertaken, both of raw materials and finished product and, in particular, is looking at how stock rotation is managed, so what systems are in place to manage the rotation of raw materials and finished products. There's a second component to this that is, in particular, looking at where slaughtering and post-slaughtering activities are taking place where carcasses, for example, are being chilled or frozen as part of that process. So that would only apply in those cases where there is actually some kind of post-slaughter activity. And so moving on to 2.5.11. So this clause is specifically looking at -- an addition to category -- for Category I to the ISO 22000 clause, and this really is looking at where there is functional packaging being used. So this is packaging that would have some impact on the packaged product. So it could be, for example, a MAP packaging to extend the shelf life. And then the other part is looking at -- is specifically focused on food chain category C1, which is generally focused on animal products. So this is really looking for inspection processes that are in place where animal products are being produced to ensure that those animal products are fit and safe for human consumption. So 2.5.12. And as you can see, this particular additional requirement only applies to certain categories. And really, this requirement is, again, building on an ISO 22000 requirement. And it's very focused on the checks that are made on the PRP programs that are in place. So this particular clause is quite focused on the kind of GMP aspects of the actions that are undertaken by the organization. So really, this is saying that you now need to have some kind of monitoring in place of the PRP checks or of the GMP to ensure that the facility and the environment is appropriate for delivering a safe food product. It will also define the frequency and the routine that needs to be in place in order to ensure that those checks are done. So again, another new requirement. And again, this one is also limited in its applications. It doesn't apply to every single food chain category but only to the ones that are identified on the screen. This requirement is really fundamentally evaluating the product development process. And a lot of clients insist that they have no product development. And that's absolutely fine. You don't have to actually have any product origination or product development activity because what this clause is also looking at is change management. So it's really saying that any change in the product or the process or the environment needs to be considered to determine whether the change has had an impact on the possibility of producing safe products. So if the change is very small even, it may be that there is a significant impact to the process that may then lead to the production of unsafe product. So even though you may not consider yourself conducting product development, in almost every case, there will be some part of this requirement that does need to be considered by the facility in terms of its -- implementation of its food safety management system. 2.5.14 is only applicable to Category D, which is feed and animal food production. And in particular, in this clause, it references ISO/TS 22002-6, which is the prerequisite program that is used for the evaluation of feed manufacturers but also used for the evaluation of pet food manufacturers other than for dogs and cats. So it's important to recognize that if you're a manufacturer of pet food and if you're only manufacturing for dogs and cats, then you would be assessed against the ISO/TS 22002-1 set of requirements. If you're also making food for other exotic animals or other exotic pets or things such as, I don't know, for example, horses or rabbits, then you would need to be assessed against ISO/TS 22002-6 and ISO/TS 22002-1 because both prerequisite programs will be seen to apply to your production process. So this particular clause is really looking at where you have to consider the health status or the health assessment of the employees that you are utilizing in your production areas and, in particular, people that are coming into direct contact with the product. 2.5.15 is the final of the new additional requirements, and this requirement is specifically focused on organizations that have multi-site certification for FSSC 22000. And once again, the multi-site certification is only applicable to a very limited sectors of the industry, so farming, catering, retail and transport and storage. So only if you are operating within those specific categories can you apply for a multi-site certificate. Multi-site certification means that the certification is made of the entire management system through conducting audits of all of the component parts of the management system at all of the sites that are to be certified. As part of that, there is very likely to be some kind of central function management that goes on. And that central function management will have defined activities and defined responsibilities that it will manage on behalf of all of the dependent sites that are seeking certification. So that's the first part. So there has to be this central function, this central management function. It doesn't have to be done at head office location. It could be done at a site location that has responsibility for managing those activities. The second part of this requirement is specifically focused on internal audits and how the internal audit program is managed to ensure that all of the sites are audited in the appropriate way. It also looks at the qualification of the internal auditors that are being used to conduct those internal audits. And it also looks at the frequency at which those internal audits are to be conducted. So this is a very comprehensive way of ensuring that internal audits are being done in an appropriate way within a multi-site certification organization. In most cases, organizations that are FSSC certified would not be able to apply for multi-site certification because they're not within one of the specific categories where multi-site certification is applicable. As I mentioned at the beginning, one of the other significant changes has been in the minimum audit duration. In the current version of the standard, Version 5, the minimum audit time is 1.5 man-days. For Version 5.1, this will increase to 2 man-days. And this audit duration is relevant for all audits in the audit cycle. So it will apply to initial audits, renewal audits and surveillance audits. Any audit that is undertaken as part of the maintenance of the certification will have to be set at a minimum of 2 man-days. It is possible to make reductions to that 2-man-day minimum audit time for organizations that are very small, so organizations that have 5 or fewer employees and 1 HACCP study. And that reduction can allow from an absolute minimum of one audit day on-site. So that will be the smallest amount of time within which an FSSC audit can be completed. The other reduction is possible in very small sites where they have less than 20 employees and a maximum of 1 HACCP study. And in that case, we can reduce the minimum audit duration to 1.5 man-days. So generally speaking, if you have an existing Version 4.1 or Version 5 certificate and you have -- any of your audits are scheduled for less than 2 man-days and you do not fit into the bottom 2 categories, i.e., you have less than 5 or less than 20 employees, then your audit duration for your Version 5.1 audit will increase to 2 man-days as a minimum. So it's really important to take that into consideration that when you receive a new proposal from SGS for your audit, that it will indicate an increase in audit time where you were previously less than 2 man-days. If your audits are greater than 2 man-days, then there will be no impact, and you will not receive any additional audit time. So the final point to note for FSSC Version 5.1 is the addition of food safety culture. Those of you that might be familiar with other GFSI benchmark standards, in most cases, food safety culture has been achieved by introducing new requirements into the standard. So by introducing the new requirements, they've made something that's very focused on food safety culture. The expectation from the GFSI is that the benchmark scheme will include elements that are related to food safety culture, and those include topics such as communication, training, employee feedback and performance measurement. Those of you that are already familiar with ISO 22000 will probably be very familiar with these expectations. Very clearly, they are already included within the ISO structure. So as I mentioned on the previous slide, the requirements of an ISO-based management system scheme already capture most of the expectations of the GFSI in terms of food safety culture. So when the FSSC considered how to comply with the food safety culture requirements, one of the first things they looked at was whether there was something already in the existing system that would allow these things to be properly captured and audited. And as hopefully everybody realizes, the new ISO systems certification standards have their central core risk-based thinking approach, which includes thinking about the overall risk of events to the organization. So rather than just considering risk to the product, as has traditionally been the case in ISO 22000, the new version of ISO 22000 looks at risk as a more -- or consuming topic and looks at risk to the organization from all different kinds of factors. One of those factors is about ensuring that people within the organization have clearly defined responsibilities, that those responsibilities are communicated and that people understand and know what their responsibilities are. Now if we think about food safety culture where we talk about people knowing and understanding what is expected of them and them understanding how they can impact and input into food safety culture, then it's very clear that a well-implemented, well-maintained FSMS system based on ISO 22000 will already be demonstrating the requirements of food safety culture and that those requirements are being properly implemented. If we then add to that fact that one of the other requirements of the food safety culture is focused on continual improvement, and remember this is continual improvement not just of the food safety part but the continual improvement of the management system as a whole, then it starts to become very clear that in actual fact, the requirements for food safety culture already preexist in the ISO 22000:2018 system. So there's no need to generate new additional requirements. As long as people have a well-designed, well-implemented FSMS, then they will already be meeting the requirements of the GFSI standard in terms of food safety culture. So as I mentioned on the previous slide, through well-implemented and maintained FSMS, you can already demonstrate that you are complying with the requirements of the GFSI's expectation in terms of food safety culture. In order to support this and in order to deliver some really comprehensive output from this implementation process, SGS has developed a platform known as Realize. Realize is adding value to your existing system by allowing the individuals within your organization, and these can be any individuals, so top management all the way down through the organization, to complete a very short online questionnaire, which we will receive back, we can review the questionnaire, and using intelligence, we can define and understand how well the food safety culture has been implemented, how well it's being realized and if there are areas where the food safety culture aspects can be improved upon. And the output of the surveys and the report that you will receive will enable you to identify some areas that it's possible to work on. There is also going to be some aspects of that output that can be customized to suit your particular individual requirements. You'll be able to access dashboards and databases to look at the responses and to try and define where improvements could be made within your system, and we can also support you with training or additional mentoring as necessary to really try and help improve your overall performance in terms of food safety culture. So this is something to consider to build on to your already well-managed system that will really help to deliver some additional insight and some additional intelligence about the food safety culture of your individual organizations. Thank you all very much for your attention. If you have questions, please type them into the Q&A box at the bottom of the screen and I will do my best to answer as many of the questions as possible in the time that is remaining to us. If you have something specific you would like to discuss, please send us an e-mail to food@sgs.com. For any other information about upcoming webinars or to subscribe to our newsletter or to view our white papers or for just general inquiries or interest about food safety products that SGS can offer or if you want to find out more about the Realize program, then please follow the links that are shown on the screen now, and you'll be able to access the total amount of information available to you. So with no further ado, I'll launch into the questions. Thank you all very much.

So lots of great questions coming in. So I just -- I'll go through as many of them as I can in the time that's available. And any I don't get to, we will do our best to answer offline. So without any further ado -- so a question regarding food safety culture, which obviously is a new content for the FSSC standard. And so I think this is something that no doubt a lot of people have interest in, in terms of how they can do some of the food safety culture things. And in fact, I think what most people will find is that actually food safety culture is probably already embedded into their organizations. So first one to take on food safety culture is, it's a question regarding performance measurement. So obviously, currently, you're required to measure performance of your food safety management system through numerous topics that you would discuss and probably would have as part of the management review. Food safety culture is no different. Really, what food safety culture is about establishing the expectations that the food safety management system are properly implemented and embedded. So we're still looking at the same things. So it could be things like customer complaints, output from internal monitoring, so that could be results of CCP or OPRP measurements, for example, and those kind of things. So this is not something completely new or completely different with the scheme. And that's why fundamentally, that -- this is captured in the existing ISO 22000 management system or why there is no new additional requirements for it. So moving on. So there's a question about audit duration. So regarding audit duration portions that's for scheduling only. For example, what happens if an audit is completed in 1.25 days when the minimum is 2? Well, the audit wouldn't be completed in 1.25 man-days. Minimum duration based on a standard site, so greater than 1 HACCP study or more than 20 employees will be 2 man-days. So if it wasn't -- if it was completed in 1.25, then it would be required to go back to complete the additional time required. Question on unannounced audits. So is it possible to complete the upgrade audits to Version 5.1 unannounced? Yes, absolutely. If the announced audit is due and it's the next audit in the cycle and it's after the 1st of April, then yes, it would be completed as the upgrade audit to Version 5.1. I have my Stage 1 audit based on FSSC 22000 Version 5. You would need to comply with the Stage 2 requirements if your Stage 2 will be taking place after the 1st of April. If your Stage 2 is scheduled before the 1st of April, then it will be done against Version 5 requirements. When would the new version be published? The new version has already been published. It was published in November last year, so you should be able to go on to the FSSC website and download it. We've just been certified FSSC Version 5 from Version 4. Is there any need or requirement to have compulsory for April 2021? You cannot have a Version 5 audit before April 2021 because the standard only starts from the 1st of April 2021. What if a site is certified with FSSC Version 5 during this month? So anybody that's already had an audit this year, I'm assuming that they have an audit -- they also had an audit in 2020 and they don't have an audit missing, meaning that they've not delayed an audit from 2020 to 2021, then they will go through their upgrade process at the next audit which is likely to be in 2022, assuming they followed the normal audit certification cycle. So our company is FSSC 22000 certified, and we are using a third-party company for storage. Does the new requirement of 2.5.15.1 mean that this third-party storage needs to be compliant with this requirement? No. 2.5.15 is related to auditing of multi-site certification which, if it's a third party that's providing storage, then it would be up to them to seek certification, not you. I'm assuming you're a food manufacturing company. So you would need to include them in your internal audit, but that doesn't make it a multi-site certificate. Should a manufacturing site be focused on requirements for the certification process, Part 3 of the FSSC 22000 scheme Version 5.1 document. No. The Part 3 is really for the certification body that's conducting the certification process on behalf of the certified type. The parts that -- the sites that are to be certified need to focus on will be Part 2, which is the requirement for certification. So for 2.5.10, which is one of the new requirements, actually I think you might have confused -- okay, yes, so 2.5.10 has 2 parts. The first part is about the storage activities, so using FIFO or FEFO technologies. The second part is specifically really related to meat processing. So yes, if you're an abattoir or you're processing animals in some way, then yes, you would need to consider Part B of 2.5.10 as part of your audit. Okay. So there's a couple of questions about the part -- the new requirement for internal laboratories. So previously, obviously, the expectation was that external laboratories would be monitored in some way in order to enable them to deliver consistent results. So typically, it could be through accreditation to 17025, but that's not mandatory. And the same thing would apply to an internal laboratory. You may well have an internal laboratory, but it doesn't necessarily need to be accredited. But there does need to be some way of recognizing whether that laboratory has the capability to continually produce repeatable results. So it might be that you do some kind of round-robin testing with other labs, for example. It's a question about internal auditor qualification. So if we're talking about internal auditor qualification with regard to the multi-site certification, then there are specific requirements for the education and training of those multi-site internal auditors. If it's not a multi-site certification, so you're just a single site with a single certificate, then the -- really, it's down to the individual organization to identify the competence requirements that can be -- that are required for internal auditors. So it may be that they are ERCA registered, but it doesn't have to be. It may be that they've done a recognized lead auditor course. It may not be. It's really down to the individual organization to determine what's appropriate. It may be that actually work experience is more valuable than having a formal qualification because the internal audit could be focused on a specific process. And therefore, it might be more appropriate to have experience of the actual process itself of the internal auditor. It's a question, what is the difference between FSSC 22000 and ISO 22000? So ISO 22000 is a management system standard, and it's one of the core building blocks of FSSC 22000. But ISO 22000 in itself is not GFSI benchmarked, and therefore, it's not GFSI recognized. So it would be important to differentiate between a GFSI standard that has all the components to meet the GFSI benchmarking document and an ISO 22000 standard, which doesn't or hasn't been GFSI benchmarked. Okay. So there's a question, should there be evidence that staff are sensitized on food safety culture, e.g., in animal food safety training? Well, that would really be for you to decide as part of your documented management system, what expectations you have on your staff in terms of their knowledge and understanding of food safety. If you specified that they have to have some kind of annual refresher training related to food safety, then the auditor will be looking for evidence that that's been completed and the staff are demonstrating their understanding of that training. So really, it's down to the individual organization to determine what training is appropriate to enable their staff to demonstrate that they have knowledge of food safety. So a question about FEFO and FIFO. So FEFO and FIFO are not necessarily the same thing. It really depends on what the aspect is it that you're actually monitoring. So first expired, first out, which is FEFO, so that would be something where there is a specific demonstrated expiry date. So that would mean you have to use it prior to that expiry date, and that could be a particular raw material. But that raw material may have an extremely long shelf life. So it may be that it's never going to reach its expiry date. Whereas FIFO, so F-I-F-O, is first in, first out, meaning that you would use the oldest batch or part of that product first to ensure that it never reaches its expiry date. So the 2 things aren't necessarily the same. So really, it's a combination of using what is the most appropriate methodology to enable you to demonstrate that your rotation of stock is adequately and properly managed. Okay. So there's a question, for a meat processing plant with small storage base, e.g. 2 coolers, does the facility need to follow 2.5.10? Yes, it does. All of the requirements would apply to all facilities equally. So question with regards to 2.5.1(b), the review of product specifications is related to the final product or the raw materials? 2.5.1, in particular, is related to supplier approval. So the specification required under 2.5.1 would be specific to the raw materials that are used as part of the finished product. So there's been a few questions regarding frequencies of monitoring. So the scheme itself doesn't specify how to determine the frequency. So the scheme doesn't mandate a specific daily, weekly, monthly, yearly frequency. Really that would need to be established following a risk assessment to determine what was the most appropriate frequency for the inspections or the checks to be done based on the volume of product, on the type of product, on the production period or the production window. So really, you need to think quite carefully about the variable factors around the product and determine which of those is the most appropriate to determine how frequently you need to consider the testing or inspection of products to ensure that they comply. Another question on specifications. So a review process of product specifications is a requirement. Can it be done during food safety meeting? If it was -- if you were meeting with the supplier of the raw material whose specification was being considered for review, then yes. I guess that would be one methodology of doing it. Really, this is more about making sure that the raw materials that are being used as part of the product are still suitable and adequate and meet the expectations. So it may be done as a periodic review, or it might be something that's done as part of a change in specification. So it might be that the finished product specification changes and, therefore, a new raw material is required. And therefore, you need to review the specifications of that raw material. Somebody has asked a slightly contentious question about remote audits. Hopefully, people realize that there is a remote audit option because of the current global pandemic. Unfortunately, at the moment, the GFSI do not recognize remote audits. Is there any likelihood that, that will change? It's difficult to say. I think it's unlikely in the current -- at the current time. But obviously, if these things do change, then the schemes will be making amendments to their programs accordingly. What if your raw material doesn't have a durability date and you are mixing the raw materials to balance flavor, do you still have to comply with FIFO and FEFO principles? That's a great question. So if it doesn't have a durability date or an expiry date, so FEFO, as in first expired, first out, wouldn't apply. But first in, first out would apply because you should use the oldest batch of that particular raw material first. So even if the supplier doesn't specify the shelf life, the internal systems should record the date of delivery, for example, and then always make sure that raw materials are used in reverse order, so you're not retaining stock over a long period of time that potentially may degrade over that extended period of time. So there's a question about PRP verification. Is it a matter of just ensuring that the elements of the PRP are being monitored and stipulated in the procedures? I guess, fundamentally, yes, this is really the extrapolation of the other monitoring that is required through the ISO 22000 system, whereby you're required to monitor CCPs and OPRPs. So this new requirement is now saying, actually, you need to monitor the things that you decide at PRPs as well to ensure that they're continually in place and continually effective. So there's a question about PAS 220. So PAS 220 is no longer current. So it was replaced by ISO/TS 22002-1. So if you're considering implementation of FSSC 22000, then you need to make sure that you're referring to the latest version of the technical specification. So it's a question regarding, is it necessary for chicken processing plants to have internal laboratory? As per FSSC requirements, if it's having testing product validating food safety, it doesn't have to be 17025 accredited. No. But there does have to be some methodology of demonstrating that it's producing consistent results and some kind of round-robin testing would probably be appropriate. There is a question, we are currently ISO 22000 certified and we produce a food contact material. In which category would we fit? It will entirely depend on what the functional purpose of the food contact material is. If, for example, it's packaging, then you would be in Category I. If you're, perhaps, Category J, then you cannot be FSSC 22000 certified currently because the scope of the FSSC scheme doesn't extend to Category J at the current time. There's a question, can virtual qualification be substantial if there is a need for emergency purchase even when there is no pandemic but as a means of reducing stress and cost? Well, the emergency purchase clause is not related to the pandemic. It's general that you may have situations whereby raw material is not available from your normal supplier. So you would be looking at how you source that raw material from an alternative supplier, and the auditor will evaluate what steps you've taken to validate that raw material to make sure that it meets the specification that you've decided is appropriate. So it's really saying that rather than evaluating the supplier, you actually evaluate the products that they produce. And that would be acceptable. There's a question about, can you briefly explain OPRP and process control, if possible, if I think OPRP for FSSC 22000 certification specifically? No, actually, OPRPs are actually defined in ISO 22000. So it doesn't -- it's not an FSSC requirement. It's an ISO 22000 requirement to have OPRPs in place. There's a question about the audit time. Will ISO 22003 be updated soon to reflect new minimum audit time? ISO 22003 is going to be updated, but don't believe there's going to be any changes to the audit duration. In terms of the audit duration, the ISO 22003 defines the calculation and the minimum audit time. But obviously, the FSSC have a great number of requirements than just auditing a standard FSMS. And therefore, the FSSC determine how much additional time is to be added and what the minimum audit duration will be for an FSSC audit. If you have more than one supplier for each of your raw materials, will you still have another emergency supplier? I guess, potentially, you could. If, for example, you use -- all of your suppliers are overseas and you have supply interruptions and you have to use a local source because your overseas suppliers aren't available, then you may have to nominate a local emergency supplier. Really, this is about having a process in place to do so and what you would go through in order to make sure that, that emergency supplier or that emergency sourcing of that raw material was done in accordance with some defined requirements. So it's a question about the availability of the FSSC 22000 standard. It's available to download free of charge from the FSSC website. So if you go to www.fssc22000.com, you can download a free copy of the standard there. So the 1-day minimum duration for companies with less than 5 persons and 1 HACCP is for all categories? Yes, it is. There's no possibility to do less than 1 man-day audit. That's the minimum on-site audit time. Let me just go through and see if I've missed any questions. There's been a few questions on the storage tank cleaning. So there is a guidance document available. But it is guidance, it's not normative. So you wouldn't be audited against it. It's just trying to help to provide guidance to companies that are applying tank cleaning and to give you some kind of reference and guidance on how that should be achieved. There's a few questions -- so it's a question about multi-site certification. I guess the simplest way to explain it is that typically for an FSSC certificate, it's one certificate, one location. So your certificate will say the name of your company and the certified location and the scope of that activity that's been certified. A multi-site certificate will have many sites listed on one certificate and what that means is that your -- the actual certificate is relevant to all of the operations within that organization that have been audited and that certificate is appropriate to all of them. For FSSC, in particular, the multi-site only applies to very limited categories; so farming, catering, retail and transport and storage. So if you're in category C or D or I or K, then we cannot apply multi-site certification to your organization. Let me just see if there's any others that -- okay. So there's a question, we produce dietary supplements. I do not buy animals, fish and seafood but sometimes buy ingredients that derive from them. Does this new requirement also apply to me or only to companies who buy the raw fish, animal and seafood? If it's also my responsibility, is there a database document I can use to know the substances I need to control when I buy animal-based products? I guess the answer to that really is that it should be clarified on the specification for the material that you're buying in terms of what the potential contaminants are, and they should be listed. So if you're buying some kind of fish derivative, then it may be possible that, that derivative could be affected by some kind of pharmaceutical ingredient that's included in the fish food. So you need to talk to your suppliers and just establish whether that was the case and whether they had any evidence or documentation to determine whether those -- whether that was present in your product or your raw material. There's a question about, the changes are only seen in the additional requirements? Yes, in the main -- the most significant changes in terms of the implementation piece are in the additional requirements. So we've just reached the top of the hour. And I'll take one more question. There's a question about labeling. So does it mean that if your product is not labeled but you provide its information, it's acceptable? Yes, absolutely. So for example, if you're a supplier of bulk raw materials, it may be that you wouldn't necessarily label each individual bulk package but that you provide some kind of documentation that would accompany the product. And that might be done electronically. It might be that the specification is available online, for example. So that would be a case where the labeling needs to extend beyond the physical product and into the -- perhaps, into the virtual world. Okay. That's all we have time for today. Thank you all very much for attending. If you do have any further questions, obviously, please do send them into the food@sgs.com e-mail address. We will take all the questions that are being submitted. And any that we haven't been able to answer, we will try and get back to as soon as we can. So again, thank you all very much. I wish you a very good day. Stay safe. Stay healthy. And hope to see you again on one of our SGS webinars. Thank you very much.