Process Control: Start-Up & Changeover Procedures
Aligned with FSSC 22000 Requirements
Requirement Overview
FSSC 22000 requires organizations to implement effective process controls to ensure product safety, legality, and quality during all stages of production. This includes documented and implemented procedures for start-up, shutdown, and changeover activities to prevent contamination, cross-contact, and product misidentification.
Start-up and changeover procedures are essential for maintaining process integrity, preventing allergen cross-contact, and ensuring that equipment and production lines are clean and fit for use before processing begins—particularly in high-risk or high-care environments.
Aligned with BRCGS for Storage & Distribution Issue 4 – Clause 4.3.1 & 4.3.3
Requirement Overview
BRCGS for Storage & Distribution requires that products moved via cross-docking are traceable and controlled at all times, even when they are not held in storage for extended periods.
Clause 4.3.1: “The company shall ensure that traceability is maintained at all stages, including during cross-docking operations.”
Clause 4.3.3: “Procedures shall be in place to ensure that all products handled, including those not stored on-site, remain under control and are not subject to contamination or substitution.”
Cross-docking operations must not compromise product traceability, safety, or integrity. Even with minimal handling and temporary presence, each product must be accurately identified, documented, and protected.
Key Compliance Objectives
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✓ Prevent contamination and ensure equipment is clean at start-up
✓ Avoid cross-contact between different product types or allergens
✓ Maintain process integrity during line transitions
✓ Document all checks and verifications for traceability
Step-by-Step Compliance Implementation
1. Develop and Document Start-Up & Changeover Procedures
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Key Elements to Include:
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• Equipment inspection and sanitation confirmation
• Line clearance verification (removal of previous product, tools, and materials)
• Product formulation or packaging material checks
• Pre-operational verification and release
Evidence to Maintain:
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• Start-up and changeover SOPs
• Cleaning records and verification logs
• Line clearance and pre-op checklists
- • Equipment inspection and sanitation confirmation • Line clearance verification (removal of previous product, tools, and materials) • Product formulation or packaging material checks • Pre-operational verification and release
- • Start-up and changeover SOPs • Cleaning records and verification logs • Line clearance and pre-op checklists
2. Assign Roles and Train Personnel
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Responsibilities Include:
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• QA/Production verifying line readiness
• Operators confirming material and formulation setup
• Maintenance team inspecting equipment readiness
Evidence to Maintain:
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• Training records specific to changeover protocols
• Job descriptions outlining responsibilities
• Verification sign-off sheets
- • QA/Production verifying line readiness • Operators confirming material and formulation setup • Maintenance team inspecting equipment readiness
- • Training records specific to changeover protocols • Job descriptions outlining responsibilities • Verification sign-off sheets
3. Execute and Verify Changeover Controls
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Activities Include:
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• Removal of old product, labels, and packaging
• Inspection of conveyors, hoppers, and dosing equipment
• Allergen control and cleaning validation, if applicable
• Trial product inspection or initial product hold
Evidence to Maintain:
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• Completed changeover logs with time/date/operator
• QA verification reports
• Hold-and-release forms for first production runs
- • Removal of old product, labels, and packaging • Inspection of conveyors, hoppers, and dosing equipment • Allergen control and cleaning validation, if applicable • Trial product inspection or initial product hold
- • Completed changeover logs with time/date/operator • QA verification reports • Hold-and-release forms for first production runs
4. Monitor, Review, and Improve
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Ongoing Activities:
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• Regular internal audits of changeover compliance
• Review of incidents or non-conformances linked to start-up or changeovers
• Improvements based on audit findings or customer feedback
Evidence to Maintain:
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• Internal audit reports
• Root cause analysis of non-conformances
• Updated SOPs and training documentation
- • Regular internal audits of changeover compliance • Review of incidents or non-conformances linked to start-up or changeovers • Improvements based on audit findings or customer feedback
- • Internal audit reports • Root cause analysis of non-conformances • Updated SOPs and training documentation
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| Incomplete or undocumented changeovers | Use standardized checklists and verification logs |
| Cross-contact or mislabeling post-changeover | Strengthen allergen validation and label checks |
| No verification of equipment cleanliness | Implement documented visual and ATP inspections |
| No formal training on procedures | Provide documented role-based training and re-certification |