Product Design Safety Evaluations

Aligned with FSSC 22000 – ISO-Based Food Safety Management System (FSMS)

Requirement Overview

Under FSSC 22000, organizations must ensure that the design and development of products and processes are controlled to safeguard food safety, meet regulatory obligations, and fulfill customer expectations. This includes planning, validation, and review of new or modified products, ingredients, packaging, or processes to prevent potential hazards or adverse effects on food safety.

A product design safety evaluation is a proactive approach that supports regulatory compliance, consumer protection, and continual improvement by assessing risks early in the product lifecycle.

Key Compliance Objectives

  • Evaluate food safety risks for new or modified products before market release

    Ensure products meet applicable legal, regulatory, and customer requirements

    Assess risks related to intended use, misuse, allergens, and consumer interaction

    Document and retain safety review and approval records

Step-by-Step Compliance Implementation

1. Establish a Product Safety Evaluation Process

  • Process Elements:

    • Appoint qualified personnel from R&D, QA, and regulatory teams

      Create a formal product safety evaluation procedure linked to FSMS

      Integrate safety reviews into product development stage-gates

    Evidence to Maintain:

    • Documented SOP for product design and safety review

      Process maps outlining approval flow

      Assigned roles and responsibilities for evaluation

2. Conduct Risk-Based Safety Assessments

  • Assessment Criteria Should Include:

    • Intended use, preparation, and end-consumer groups

      Ingredient safety (e.g., allergens, toxins, raw materials)

      Process-related hazards (e.g., cross-contamination, CCPs)

      Labelling accuracy, shelf-life validation, and packaging safety

      Compliance with applicable legislation (e.g., FDA, EU, Codex, FSMA)

    Evidence to Maintain:

    • Risk assessment checklists and reports

      Material Safety Data Sheets (MSDS)

      Allergen risk analysis and packaging compatibility assessments

3. Approve Product for Market Release

  • Approval Requirements:

    • Sign-off by QA, food safety team, or authorized manager

      Verification of hazard controls and process validation

      Documentation confirming legal and regulatory compliance

    Evidence to Maintain:

    • Signed design safety evaluation forms

      Change control and validation logs

      Certificates of compliance, product specifications, and testing reports

4. Reassess Upon Change or Trigger Events

  • Trigger Events:

    • Product design changes or reformulation

      New supplier, raw material, or process changes

      Recalls, complaints, or regulatory findings

      Updates in relevant food laws or standards

    Evidence to Maintain:

    • Updated safety evaluations and risk assessments

      Records of internal reviews tied to change control

      Reports from investigations related to consumer safety

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
No documented product safety evaluation Establish a formal procedure and integrate with FSMS
Incomplete or generic risk assessments Customize evaluations to specific product and market risks
Missing compliance evidence Retain test results, certificates, and legal documentation
No reassessment after changes Link change control with mandatory design safety reviews

Auditor Verification Checklist (FSSC Context)

During an FSSC 22000 audit, be prepared to present:

  • A documented product and process design control procedure

    Risk-based product safety evaluations for new or changed products

    Regulatory compliance records (FDA, EU, etc.)

    Evidence of sign-off and validation by qualified personnel

    Reassessment documentation tied to product or process changes

Implementation Roadmap

Build Your System

  • Develop SOP for product safety evaluations under FSMS

    Assign cross-functional review teams

Evaluate and Approve

  • Perform structured hazard analysis during development

    Obtain regulatory and internal approvals before launch

Monitor and Reassess

  • Link change control to product safety re-evaluations

    Track consumer complaints and incidents for redesign triggers

Document and Retain

  • Keep records for regulatory defense and audit readinesss

    Archive safety reports, risk assessments, and approval forms

Why This Matters?

  • Prevents unsafe or non-compliant products from reaching the market

    Supports regulatory compliance and customer trust

    Strengthens proactive risk management and continuous improvement

    Reduces liability, recall exposure, and reputational risk

Support Tools Available

Food Safety Systems provides:

  • Product safety evaluation templates and workflow guides

    Risk assessment tools customized for food products

    Compliance checklists for FDA, EU, Codex, and FSMA

    Training modules on product design safety and regulatory integration