SQE Manual

8/17/2019 SQE Manual

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Issue Date: May 10, 2010

Supersedes: SQE, dated Feb 12, 2008& pSQE dated June 23, 2005

Subject:

Supplier Quality Expectations:

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KRAFT FOODS

SUPPLIER

QUALITY EXPECTATIONS MANUAL

Issued by: Approved by: Reviewed by:

Name: Richard Zuurbier Ron Milewski Maluwa Behringer

Function: Supplier Quality Director Quality & Risk

Management

Global Procurement

Quality


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TABLE OF CONTENTS

CHAPTER 1 - INTRODUCTION ____________________________________________ 4

1.1. Confidentiality _________________________________________________ 5

1.2. Notifying Kraft Foods of Significant events ___________________________ 6

CHAPTER 2 - QUALITY SYSTEM CONTROLS __________________________________ 7

2.1. Quality Management System and Documentation ______________________ 7

2.2. Kraft Foods Audit/Inspection Requirements__________________________ 8

2.3. Internal Audits ________________________________________________ 9

2.4.

Regulatory Inspections and Contacts _______________________________ 9

2 . 5 . Food Defense_________________________________________________ 10

2.6. Testing Controls: Laboratory Requirements _________________________ 11

2.7. Testing Controls: Measuring & Monitoring Equipment__________________ 12

2.8. Corrective and Preventive Action (C&PA) ___________________________ 13

CHAPTER 3 - FACILITY ENVIRONMENT CONTROLS ___________________________ 14

3.1. Good Manufacturing Practices (GMP) ______________________________ 14

3.2. Personnel Training_____________________________________________ 14

3.3. Employee Illness and Communicable Disease ________________________ 15

3.4. Plant Structure _______________________________________________ 15

3.5.

Utilities Management___________________________________________ 15 3.6. Equipment Design & Validation ___________________________________ 16

3.7. Equipment Maintenance ________________________________________ 16

3.8. Sanitation ___________________________________________________ 17

3.9. Pest Management _____________________________________________ 18

3.10. Zoning_____________________________________________________ 18

3.11.

Pathogen Environmental Monitoring______________________________ 19

CHAPTER 4 - PRODUCTION PROCESS CONTROLS ____________________________ 21

4.1. Specification Compliance and Contract Review _______________________ 21

4.2. Hazard Analysis AND Critical Control Points (HACCP) __________________ 22

4.3.

Incoming Materials: Supplier Quality Management____________________ 23 4.4. Incoming Materials: Inspection and Testing _________________________ 23

4.5. Traceability __________________________________________________ 24

4.6. Allergen Management __________________________________________ 24

4.7. Extraneous Matter _____________________________________________ 26

4.8. Rework Control _______________________________________________ 27

4.9. Label Control _________________________________________________ 27

4.10. Weight Control ______________________________________________ 28

4.11. Material Packaging ___________________________________________ 28


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4.12. Storage and Transportation ____________________________________ 29

CHAPTER 5 - INCIDENT MANAGEMENT ____________________________________ 30

5.1. Hold & Release _______________________________________________ 30

5.2. Product Retrieval______________________________________________ 31

5.3. Control and Disposition of Non-conforming Products __________________ 31

CHAPTER 6 - PACKAGING REQUIREMENTS _________________________________ 32

6.1. Introduction _________________________________________________ 32

6.2. Transfer of constituents from a food contact material to food ___________ 33

6.2.1. Packaging Hygiene ___________________________________________ 33

6.2.2.

Constituents from plastic materials ______________________________ 33

6.2.3. Constituents from cellulose fiber materials ________________________ 33

6.2.4. Metal in contact with packaging _________________________________ 34

6.2.5. Recycled post consumer material ________________________________ 34

6.2.6. Consumer acceptance _________________________________________ 34

6.2.7. Odor and Taste transfer _______________________________________ 34

6.2.8. Residual solvents ____________________________________________ 35

6.2.9. Printing inks ________________________________________________ 35

6.2.10. Printing in direct contact with food _____________________________ 36

6.2.11. Packaging Material Ingredients and Processing Aids derived from

Allergenic and Genetically Modified Sources ______________________________ 36

6.2.12. Active and intelligent packaging _______________________________ 36

6.3. Environmental impact of packaging _______________________________ 36

6.3.1. Minimization of heavy metals, and other N-classified substances _______ 36

6.3.2. Registration, Evaluation, Authorisation and Restriction of Chemicals

(REACH)__________________________________________________________ 37

6.4. Packaging Component Information Sheet (PCIS) _____________________ 37

6.5. Reference list of regulations and methods __________________________ 38

APPENDIX 1 - DEFINITIONS ____________________________________________ 41


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CHAPTER 1 - INTRODUCTION

The safety and quality of our products are of the highest importance to us – as are the trust

and confidence of our consumers and customers.

At Kraft Foods, we inspire trust by making safe food. We recognize that the safety of our

products is the foundation on which the success of our business is built. Safe food is at thecore of our heritage and is ingrained in our culture.

Kraft Foods is committed to delivering high-quality products. One of the ways we achieve

this is by ensuring the strength of our food safety and quality systems. We expect that oursuppliers share this commitment. We have several documents that you will need so youcan do your part in ensuring the quality and safety of our products.

The Kraft Foods Supplier Quality Expectations (SQE) outlined here are intended to helpcurrent and prospective new suppliers ensure that their own food safety and quality

systems meet Kraft Foods and Industry standards. These expectations have beendeveloped by Kraft Foods after a review of product defects, quality audits of manufacturingsites and a study of product retrievals throughout the food industry. This review led us to

identify which programs, if executed properly, help to prevent product retrievals, consumercomplaints, rework and plant downtime, and produce high quality, safe products. Allfacilities producing materials for Kraft Foods must meet the expectations in this manual.

This document does not apply to farm operations.

As a companion document to this manual, the Kraft Foods Supplier Quality ExpectationsManual: Resource Supplement contains additional requirements. It also includes guidances

and examples for suppliers to consider in strengthening food safety and quality programsacross the supply chain.

Terms used in the SQE Manual and the SQE Resource Supplement are defined in Appendix

1: Definitions of this document. The English versions of these documents are consideredthe official contractual versions, but alternative languages may be available. For allsuppliers, these documents supersede the previous version of the SQE Manual issued on

February 12, 2008 and the pSQE Manual issued on June 23, 2005.

Our requirements for Hazard Analysis and Critical Control Points (HACCP)/Food Safety

programs are set forth in Kraft Foods Global, Inc. Supplier and External ManufacturerHACCP Manual , which will be provided in conjunction with the SQE Manual and the Kraft

Foods Supplier Quality Expectations Manual: Resource Supplement .

Requirements specific for packaging suppliers are found in Chapter 6, including a tablehighlighting which sections of the SQE are relevant to packaging suppliers.

Suppliers of certain specific ingredients may receive separate Process Guidelines asappropriate, e.g., Suppliers of beef or gelatin materials must comply with the Global KraftFoods Policy for Procurement of Meat Raw Materials Sourced from Beef and the Global Kraft

Foods Policy for Procurement of Gelatin. Other ingredients that have specific guidancedocuments for Suppliers include cocoa/chocolate, dairy, eggs, juice, tree nut and peanutproducts.


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The Kraft Foods SQE Manual, Kraft Foods Global, Inc. Supplier and External ManufacturerHACCP Manual , and Process Guidelines (where applicable) do not dictate how to set upspecific product safety and quality systems. They contain the elements we believe are

essential for the effective management of Food Safety, Quality and Food Defense. Theseare Kraft Foods requirements. They are not intended to alter or eliminate any requirementsthat may be set in any contract, specifications, or government regulation. Any questions

about these standards should be addressed by contacting the appropriate Kraft FoodsContracting Representative.

For Brokers, Distributors and Traders

In cases where materials are being procured through brokers, distributors and traders the

following requirements must be followed:

Only buy from Kraft Foods approved manufacturing locations

Ensure The Kraft Foods SQE Manual, Kraft Foods Global, Inc. Supplier HACCPStandard Manual and Kraft Foods Specification are communicated to supplier andprovide evidence of agreement to requirements by the supplier

The broker/distributor/trader has responsibility to ensure that supplier complies withthose requirements

The broker/distributor/trader shall be required to notify Kraft Foods of any

manufacturing location changes. New sites must be approved prior to use

The broker/distributor/trader must demonstrate that traceability of materials to

manufacturing location level is maintained.

1.1. Confidentiality

The contracts between Kraft Foods and the Supplier will govern confidentiality of

information shared by either company. All Supplier personnel should take care not todisclose Supplier confidential information to Kraft Foods unless there is a contract in placeprotecting such disclosure. Auditors shall not be asked or required to sign confidentiality

agreements as a prerequisite to gaining access for audits prior to or at any time during aquality audit.

Auditors checking compliance to the Kraft Foods SQE requirements will not audit or inspect

financial data, sales data (other than that directly related to Kraft Foods), or pricing data..Kraft Foods employee auditors will not inspect personnel data, other than data relating toqualifications or training of technical and professional personnel performing functions

pertinent to the audit.


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1.2. Notifying Kraft Foods of Significant events

Communication in the supply chain is critical when events occur that could affect food

safety, quality, or processing. The Supplier must establish procedures to ensure KraftFoods is immediately notified of these occurrences.

The Supplier shall notify Kraft Foods immediately of any, but not limited to, the following:

Systematic product quality defect or process control deviation which could lead to a

voluntary or involuntary recall or withdrawal of a Kraft Foods finished product.

Discovery of potentially defective or adulterated ingredients or packaging materialsassociated with product in distribution.

Non-routine regulatory agency investigations, testing, sampling, reporting, or othercontact or action with the potential to affect material produced for Kraft Foods. KraftFoods does not need to be notified of routine inspections, unless the inspection

reveals that material produced for Kraft Foods may not be in compliance withapplicable law.

Inadvertent release from Hold of any material produced for Kraft Foods.

Event that leads the Supplier to suspect that a non-conformance exists in productalready shipped to Kraft Foods.

Product tampering or threat of tampering.

Event or substance that could threaten product security.

Notification by law enforcement or other authority of a potential product security

event.

Identification of an unlabeled allergen in material produced for Kraft Foods. Inability to deliver materials that meet Kraft Foods Specifications

Changes to suppliers processes and/or facilities that could have an impact onmaterials supplied to Kraft Foods.

In the event of a pathogen positive result, Kraft Foods Contracting Representative

must be notified, even if the specific lot is not sent to Kraft Foods.

The Supplier must notify Kraft Foods by a phone call with a live person and by email.Voicemail, even coupled with an email, is not adequate. The Kraft Foods Contracting

Representative shall be the primary contact for any contact or notification required by thisdocument. However if the representative is not available in cases of emergency, contactKraft Foods Headquarters Security at 001-847-646-2000 and ask to be put in contact with

the Special Situations Management Team (SSMT).


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CHAPTER 2 - QUALITY SYSTEM CONTROLS

2.1. Quality Management System and Documentation

The Supplier shall have implemented a written Quality Management System (the “QualitySystem”) to ensure that the material produced conforms to our specified requirements. At

a minimum, the Quality System should ensure compliance with the Kraft Foods SupplierQuality Expectations Manual , Kraft Foods Global, Inc. Supplier and External ManufacturerHACCP Manual, Kraft Foods Specifications for the specific product, and applicable regulatory

requirements of the production country and the destination to which the products will bedelivered (both national and local requirements, as applicable).

The Quality System shall clearly set out the source of each food safety and qualityrequirement. The Quality System shall also set forth the specific personnel responsible forcompliance with each requirement through use of an organizational chart. The Supplier

shall review the Quality System on a regularly-scheduled basis to verify that it remainsadequate to comply with all requirements.

The Supplier shall maintain records sufficient to show effective implementation of the

Quality System. Records must be legible, readily identifiable and retrievable. The QualitySystem will clearly set out the records that must be maintained to show effective

implementation and controls needed for identification, storage, protection, retrieval,retention period and disposition of records. For ingredients delivered to Kraft Foods thatwere produced or will be sold in the United States and Canada, records shall be retained for

at least five years. For other countries, the minimum retention time shall be two years, orlonger if required by applicable law.

In addition to the requirements set out above, the Supplier’s Quality System shall

specifically include controls to ensure the following:

Outsourcing: Any outsourced process that affects material or ingredients produced

for Kraft Foods complies with the same requirements the Supplier must meet.

Manufacturing changes: The supplier must notify Kraft Foods of their intention to

make any change that may affect the safety, quality, security, shelf-life, ingredientstatement, allergen profile, nutritional labeling or functionality of material producedfor Kraft Foods – such as changes in material formula, raw materials, production

line, production facility or processes – and any change shall be approved by KraftFoods before being implemented. Kraft Foods must be notified of such changes in

writing. Special certifications: If Kraft Foods Specifications require particular certifications –

such as Organic, Kosher or Halal certification – then the Supplier facility must be

certified by the appropriate certifying body of the country in which Kraft Foods willreceive the material.

Genetically modified organism (GMO): No raw material shall be supplied that wouldrequire GMO labeling. Supplier shall ensure that raw material does not contain anytrace of unauthorized GMOs in accordance with the regulation in the destination to

which they may be delivered


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No cloned animal products: No milk, meat, or other ingredients derived from clonedanimals shall be used to make Kraft Foods materials.

Ionization: No ionized ingredients shall be used to make Kraft Foods materials.Material itself shall not be ionized either.

2.2. Kraft Foods Audit/Inspection Requirements

All facilities producing materials for Kraft Foods must be approved by Kraft Foods. Thefollowing options will be considered;

Third Party auditing supplier on behalf of Kraft Foods, or

Kraft Foods employee, or

Recognized industry standard.

The frequency and types of audits required by Kraft Foods are available from the Kraft

Foods Contract Representative. Where appropriate, the Supplier shall schedule Food Safetyand Quality Audits on a periodic basis.

Suppliers must permit Kraft Foods or its representatives to enter and audit anyestablishment manufacturing, storing or supplying materials for Kraft Foods. Materialmanufacturing locations usually will be required to complete an on-site Food Safety and

Quality Audit by Kraft Foods auditors or submit an audit report from a Kraft Foods approvedthird party audit agent. To become and remain an approved Supplier, the audit findingsmust be acceptable to Kraft Foods.

Separate audits are required for every facility producing material for Kraft Foods. TheSupplier shall notify the Kraft Foods Contracting representative of any ingredient which is

produced or processed in a plant not entirely owned or operated by the Supplier.

The audit/inspection shall extend to all areas, including all pertinent production and storageareas, deemed necessary to evaluate whether the material produced for Kraft Foods meets

our requirements and specifications. The audit/inspection may include, but is not limited to,equipment, finished and unfinished materials, containers, labeling, records, processes, andcontrols. The Supplier must implement all corrective actions identified in the Kraft Foods

audit within the time frame agreed on in the audit corrective action plan.

Kraft will bear its own internal costs and the Supplier will bear all other audit costs

(including those of the third-party auditors).


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2.3. Internal Audits

The Supplier shall establish and maintain written procedures for conducting internal audits

to verify whether the Quality System is being adequately implemented and whether theQuality System should be revised. Internal audits shall be conducted at set intervals.

The internal audit procedure shall ensure that each relevant function/area is periodicallyaudited. Results of previous audits must be taken into account when planning futureaudits. Employees may conduct audits, but should only be assigned to audit areas in which

they do not work.

The audit procedures shall provide for follow-up audit activities to verify and record the

implementation of corrective actions taken. The effectiveness of the corrective action shallbe verified and additional actions must be implemented where necessary. The audit mustbe completed and closed-out within an established timeframe. Supplier management shallreview audit results, corrective actions and follow-up as part of regular meetings.

2.4. Regulatory Inspections and Contacts

The Supplier shall have written procedures and designated, trained personnel to manageinspections by and contacts with regulatory agencies. Procedures shall address how theSupplier will follow up and obtain closure of any issues arising from such inspection or

contact. The Supplier shall maintain at the facility records of all regulatory inspections andcontacts, including any reports issued by inspectors, facility responses, and correctiveactions taken, for a period according to local regulatory requirements.

In the event a regulatory agency samples material produced for Kraft Foods. The Suppliershall contact the Kraft Foods Contracting Representative for instruction prior to shipment of

the product to a Kraft Foods facility. Supplier will provide Kraft Foods with a duplicatesample of product from the lot examined by the regulatory agency. No further testing shallbe initiated by the Supplier without prior authorization from Kraft Foods.

Consideration must be given to the potential impact of an adverse result. In some cases it

will be necessary to place product and/or material on hold pending results of Inspectorsampling, for example:

Where a non-conformance or defect has become apparent during the inspection.

Where the stated reason for the sample being taken concerns an issue which mayimpact Kraft Foods (e.g. Sampling for Pathogen or GMO testing).


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2 . 5 . Food Defense

Suppliers acting on behalf of Kraft Foods that manufacture, process, pack, or in any way

handle ingredients or final product will develop specific procedures to secure our product, todeter and prevent intentional contamination, and will have protocols in place to quickly andaccurately identify, respond to and contain threats or acts of intentional contamination.

Likewise, suppliers will ensure their suppliers adopt similar protocols and implementappropriate controls. At Kraft Foods we call these efforts Food Defense and we depend onour suppliers to do their part in helping us secure our combined portion of the world’s food

chain.

The laws and government expectations regarding Food Defense vary from country tocountry. Kraft Foods has defined a set of Food Defense standards to help us meet legal andconsumer expectations. The standards may exceed the requirements of a specific countryor area.

(A) US-based suppliers and international suppliers shipping direct materials or finishedproduct into the United States on behalf of Kraft Foods are expected to complete the belowrequirements and be prepared to provide Kraft Foods confirmation that they have

completed these requirements.

1. Adopt and maintain a facility Food Defense program (outlined below (C)).

2. FDA facility registration list. Complete and maintain registration in the KraftFoods FDA facility registration list.

3. One-Up-One-Down records maintenance. Maintain records to identify theimmediate previous source of food or ingredient received and the immediatesubsequent recipient of food or ingredient shipped.

4. Detained product. Ensure detained product is held as directed by Kraft Foods(See Chapter 8 – Measurement, Analysis and Improvement).

5. Meet C-TPAT Import Security Criteria if making shipments to the U.S. butoriginating elsewhere.

(B) Kraft Foods international suppliers which do not ship into the United States are

expected to develop facility Food Defense programs that meet set standards (outlined below(C)) and be prepared to provide Kraft Foods confirmation they have met theserequirements.

(C) A Food Defense Program shall include the following:

1. Program Administration

(a) A documented plan (contact your Kraft Foods Contract Representative toobtain examples) that explains the site’s Food Defense procedures and

strategies.

(b) Clearly-defined roles and responsibilities of those individuals responsible formaintaining the program.

(c) Procedures for reporting threats or acts of intentional contamination to Kraft


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Foods and others (as required by local law).

(d) Annual vulnerability self-assessments (see Appendix 10 for examples) andprocedures for fixing gaps.

2. Access control. An access control system will deter people with the intent ofharming our products from gaining access to do so. Suppliers must implementsystems and procedures to identify people who are regularly on site (e.g., employees

and contractors) as well as to limit access to restricted areas to authorized peopleonly. Specifically:

(a) Processing and manufacturing areas(b) Ingredient and raw material storage areas (to include packaging stocks)(c) Hazardous and chemical storage areas

(d) Shipping and receiving areas

3. Background Screening. Suppliers will conduct background screening checks on

employee candidates as required under the contract with Kraft Foods.

4. Shipping and Receiving. The Supplier shall take deliberate steps, and implementprocedures, to monitor and verify the integrity of incoming and outgoing shipments.

This includes the requirements described in SQE Section 4.12 Storage andTransportation.

Additional information, related regulations and training are described in Section A: Food

Defense in the SQE Resource Supplement

2.6. Testing Controls: Laboratory Requirements

Through procedures in a written program, the Supplier shall ensure that personnel

responsible for conducting testing or monitoring (in connection with the programs requiredin this SQE Manual ) have access to all necessary information, such as laboratory methodsmanuals, raw material specifications, packaging specifications, finished product

specifications, test requirements and parameters, and laboratory procedures, in order to beable to carry out properly their responsibilities with respect to materials produced for KraftFoods.

Testing and monitoring programs shall be based on generally recognized methods or testmethods that have been validated by Kraft Foods for their intended use.

All supplier plant laboratories and laboratory personnel shall comply with Good LaboratoryPractice requirements including, but not limited to, the following:

The Supplier shall implement a procedure to identify samples submitted to thelaboratory to ensure traceability from the sample to the reporting of a final result.

Laboratory chemicals with high toxicity, bacterial positive control cultures andsolvents not in immediate use must be secured and locked, with access restricted to

authorized personnel. A secured laboratory (access controlled, locked when notoccupied, and periodic inventory) is adequate for the storage of chemicals used on aroutine basis.


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Laboratory materials shall be restricted to use in the laboratory, except as neededfor sampling or other appropriate use activities. Unexplained additions and

withdrawals must be immediately investigated and reported to appropriate lawenforcement and public health authorities.

Procedures must be in place for positive control, tracking and disposition of sensitivematerials.

Laboratory requirements for pathogen testing

Pathogen testing required for materials delivered to Kraft Foods shall only be performed bylaboratories that have been approved by Kraft Foods Corporate Microbiology. A list of

approved laboratories in each country is available from your Kraft Foods ContractRepresentative upon request.

Samples from an Environmental Testing Program may be analyzed at the supplier’s

pathogen laboratory provided requirements for internal lab are met. If an on-sitelaboratory is used:

The laboratory design and practices must prevent the potential for cross-contamination of pathogens by restricting access to authorized personnel.

At a minimum, signs must be posted to advise that the area is restricted.

Relative air pressure of the pathogen laboratory shall be negative to the adjacentrooms.

The air in microbiology laboratories shall be filtered by a F8 (MERV 14-15) filter.

Any potentially infectious material shall be sterilized prior to disposal.For more information about pathogen testing requirements, see herein Section 3.11- Pathogen Environmental Testing.

2.7. Testing Controls: Measuring & Monitoring Equipment

The Supplier shall have implemented a written process that is available to all appropriatepersonnel to inspect, test, and calibrate measuring and monitoring equipment. The processshall ensure the precision and accuracy of the equipment such that measurement capability

is consistent with the measurement requirements. Calibration procedures for each piece ofmeasuring and monitoring equipment, including equipment used to control, measure, ormonitor critical control points (CCPs) and equipment used for laboratory testing, shall

include the following information:

Whether the equipment is used to control, measure, or monitor CCPs.

Minimum required accuracy or allowable tolerance for the device.

Corrective actions to be taken when the results of a calibration are out of specified

limits.

The Supplier shall establish and maintain a master list of all measuring and monitoring

equipment that can affect food safety and/or product quality to be controlled by theprogram including:

Name of the equipment and a unique identifier.


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Location of the equipment.

Frequency of the calibration (Note: Equipment used to measure a CCP shall becalibrated at least every six months.)

The method of calibration.

What the equipment is used for.

Personnel responsible for the activity.

Critical Measurement Equipment must be calibrated at or near the process parameter.Calibration shall be against known and valid standards which are traceable to international

or national measurement standards. Where no such standards exist, the method ofestablishing and maintaining the standard for calibration shall be documented.

Calibration shall be performed under suitable environmental conditions, based on stability,purpose and degree of usage of such equipment. Calibration checks shall be documentedincluding date, personnel initials and actual comparison results, and calibration results

indicating the degree of inaccuracy and any adjustments made to bring the equipment backinto calibration.

Product that may have been affected due to equipment being out of calibration shall be

evaluated. If the equipment is used to monitor or measure a CCP, an assessment shall becarried out to determine any potential food safety risk with regard to product tested during

the period when the equipment was possibly out of calibration.

2.8. Corrective and Preventive Action (C&PA)

All programs mandated by this SQE Manual require that Corrective and Preventive Actionsbe taken in the event of non-conformances. The Supplier shall have an effective C&PAprogram tracking such actions to ensure that non-conformances in any program are

addressed in an appropriate and timely manner.

For further requirements and guidance on elements of an effective C&PA program, see

Section B: Corrective and Preventive Actions in the SQE Resource Supplement .


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CHAPTER 3 - FACILITY ENVIRONMENT CONTROLS

3.1. Good Manufacturing Practices (GMP)

All persons entering the Supplier facility (plant personnel, visitors and outside contractors)shall comply with GMP requirements. GMPs must be in writing and available to all personnel

The GMPs must address personal hygiene, handling and storage of equipment andmaterials, proper cleaning and sanitation, and receiving. Section C: Good Manufacturing

Practices (GMPs) of the SQE Resource Supplement sets out a summary of requirements andguidelines for GMP practices.

3.2. Personnel Training

The Supplier shall ensure that all employees receive appropriate training for their jobfunctions. Specific training requirements are as follows:

GMPs. All employees, including temporary and seasonal personnel, must receive

GMP training as part of the orientation process. All employees shall also receiverefresher training or verification of GMP knowledge at defined intervals. In addition,specific training programs to instruct personnel on the requirements of this

document shall be provided as required and applicable.

Production Personnel. Training for Supplier personnel who work in production areas

must include the following principles: Quality, HACCP, Allergens, Foreign ObjectPrevention, and Food Defense.

Critical Control Point (CCP) Monitors. Employees monitoring CCPs must receivefurther specific training on monitoring, documentation, verification and corrective

actions if critical limits are not met.

GMOs. When appropriate, employees involved in handling GMO materials must be

trained as to procedures for handling these products (e.g., preventing co-mingling,how to also handle non-GMO materials).

Additional Requirements. Training requirements for regulatory inspections, pestmanagement, and pathogen environmental monitoring are set forth in other sectionsof this manual (see Section 2.4-Regulatory Inspections and Contacts, Section 3.9-

Pest Management , and Section 3.11-Pathogen Environmental Monitoring).

Training shall be provided to new employees before starting work in production. Refreshertraining on these topics shall be provided at least annually. The Supplier shall maintain

records of personnel education, training, skills and experience. The Supplier shall alsoperiodically evaluate the effectiveness of its training programs.

The Supplier shall provide visitors and contractors with site specific training programs, asnecessary, prior to performing activities which may affect product safety or quality.


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3.3. Employee Illness and Communicable Disease

The Supplier shall establish written instructions for the control of employee illness and

communicable disease that may result in pathogen transmission by food. These instructionsshall be available and communicated to all applicable personnel.

The instructions shall, at a minimum, include:

Information for recognition of symptoms of communicable disease such as: diarrhea,

vomiting, open skin sores, boils, fever, dark urine, or jaundice, as well as symptomsassociated with region-specific diseases as defined by local medical experts.

A process by which the Supplier can evaluate the potential impact to product should

an active employee be diagnosed with communicable disease. Procedures to ensure that employees afflicted with a communicable disease are

removed from the manufacturing facility or are reassigned to a non-food contact

area. In determining suitable work areas for affected employees, the Supplier shallconsider the risk of cross infection to other employees.

Policies regarding employee return to work after illness.

No person shall be admitted into a GMP area if he or she carries, or has been exposed to,

any potential source of a microbial or viral contamination. For a list of relevantcommunicable diseases, refer to Section D: Pathogens Involved with Communicable Disease in the SQE Resource Supplement .

3.4. Plant Structure

The facility shall be of adequate design and construction to ensure production of safe and

high quality materials. The facility, including utility fixtures, shall be designed to preventpotential contamination sources from affecting the products produced or handled. Infacilities handling microbiologically sensitive ingredients, the plant structure shall provide

adequate physical separation to prevent any cross contamination (e.g., raw and processed ,allergen and non-allergen). Facility grounds must be maintained to address food defenseconsiderations. The location and design of waste bins, toilets and hand washing, drying and

sanitizing facilities shall be adequate to comply with GMPs. The Supplier shall ensure thatthe facility is satisfactorily maintained. For more requirements and guidelines, refer toSection E: Plant Structure in the SQE Resource Supplement .

3.5. Utilities Management

The Supplier shall have implemented programs to ensure safe provision of Utility Services in

food production areas. Utility Services include environmental air, compressed air, waterand steam. For specific requirements and guidelines for the management of each of these

utilities, refer to Section F: Utilities in the SQE Resource Supplement .

The Supplier shall control access points for the above referenced Utility Services, as well aselectricity, heating, and ventilation. Access may be controlled by any means deemed

effective, such as locked facilities which only authorized employees can open.


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3.6. Equipment Design & Validation

The Supplier shall ensure that equipment design is adequate for the production of materialsthat meet food safety and quality parameters. Equipment used in the manufacture of food

ingredients or food contact packaging shall be:

Cleanable.

Made of food-compatible materials with smooth and accessible surfaces.

Capable of protecting product from contamination.

Self draining.

Free from openings that could allow product or water to penetrate voids. Designed to allow for proper ventilation.

Each new capital installation or modification to existing equipment design shall undergo aSanitary Design Review by a cross-functional team (e.g., quality, sanitation, production,

maintenance) in the design phase of the project. This review shall address the ease ofcleaning, functionality, material selection (e.g., made of compatible material and smoothsurfaces) and workmanship of the equipment or process under review.

For more requirements and guidelines, refer to Section G: Equipment Design in the SQEResource Supplement .

3.7. Equipment Maintenance

The Supplier shall ensure that equipment and materials used for production are suitable forthe purpose intended and in good repair. The Supplier shall have implemented a writtenprogram for preventive and corrective maintenance that is up to date and includes:

A list of food handling equipment.

Procedures detailing the maintenance required for each piece of equipment, includingrequirements for release back into production and frequency of maintenance.

Measures to ensure that, after maintenance activities (e.g., drilling, cutting, polishingand welding) have occurred, the equipment and facilities are clean, sanitized, and ingood repair prior to release for production.

Appropriate measures to protect products during repair or maintenance activities.

Procedures for isolating maintenance work areas from active production lines.

A description of required maintenance records.

The program shall be tailored to the specific products or facilities. Priority shall be given to

maintenance of pieces of equipment that may affect food safety, quality, or employeesafety.

Preventive maintenance frequency shall be adjusted in accordance with equipment history

and the outcome of the last intervention.

For more requirements and guidelines, refer to Section H: Equipment Maintenance in theSQE Resource Supplement .


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3.8. Sanitation

The Supplier shall have implemented a written sanitation program that ensures cleanlinessof the food processing environment, equipment (including tankers inbound and outbound)

and tools. The program shall address:

Sanitation schedules, methods, and frequencies.

Correct use of appropriate sanitation equipment and tools.

Equipment disassembly and re-assembly.

Verification of sanitation effectiveness.

Non-pathogen environmental monitoring programs. Inspection procedures.

Recordkeeping, record review, and corrective action plans.

Written sanitation instructions shall include (where applicable):

Chemicals to be used and how they are to be used including chemicalconcentrations, contact time, temperatures, frequencies, and rinsing procedures.

Circulation velocity.

Clean in Place/Clean Out of Place (CIP/COP) steps.

Proper tools and materials must be used to prevent extraneous matter, microbiologicaland/or chemical contamination of the product. Items that are known to be potential

sources of contamination must be prohibited. Brushes and utensils for cleaning food

contact surfaces shall be clearly identified (e.g., labeled and/or color coded) and storedseparately from non-food contact tools. Floor drain cleaning brushes and equipment shall

be clearly identified as such and maintained separately from other cleaning equipment.

The Sanitation program shall specify microbiological limits per business or food category

requirements (e.g., Total Aerobic Count, Yeast, Mold, Coliforms, Indicator Organisms).Whenever results exceed or trend toward the specified limits, corrective actions must betaken and documented. If out-of-specification results are obtained, swabs must be

repeated to ensure the corrective action was effective. If swabs are rotated, swabs shouldbe repeated until three consecutive acceptable results are achieved.

For further specific criteria, instructions, and requirements, including details for CIP andNon-Pathogen Environmental Monitoring program, see Section I: Sanitation in the SQE

Resource Supplement .


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3.9. Pest Management

The Supplier shall have implemented a written pest management program to monitor and

control pest activity in the facility and the surrounding area effectively. The pestmanagement program shall include:

Pest management plans, methods, schedules, and available corrective actions.

Inspection procedures and frequencies.

Required documentation of pest activity, and analysis of records for trends inactivity.

Training requirements.

A map showing the location of pest control devices, such as indoor rodent traps,glue boards, insect light traps, outdoor bait stations, and pheromone traps.

Wherever feasible and practical, non-pesticide pest management practices or alternative

methods and tools shall be employed for controlling pests (e.g., strategies of exclusion andtrapping of pests). If pesticides are used, the Supplier shall ensure that they are used inaccordance with local regulations and that pesticide residues do not exceed limits

established by the law of both the location of the facility and the location where Kraft Foodswill receive the material. The Supplier also shall ensure that appropriate measures aretaken to present pesticides from contaminating food products.

Pest control activities shall be performed by certified pest control contractors or personnelwith equivalent training.

More requirements and guidance are described in the Section J: Pest Management in theSQE Resource Supplement .

3.10. Zoning

All Suppliers that manufacture or handle Kraft products shall have a Zoning program toreduce the potential for microbiological contamination of products by preventing

environmental cross-contamination though the application of proper controls.

Zoning principles identify and differentiate processing areas within the facility where

potential sources of pathogen and non-pathogen microbial contamination exist from air ortraffic (e.g., people, equipment, and materials).

The Supplier should refer to the Kraft Foods Biologically Sensitive Ingredient Category List

in Appendix B of the Kraft Foods Global, Inc. Supplier and External Manufacturer HACCPManual to determine whether it manufactures or handles microbiologically sensitivematerials. The evaluation should consider both potential pathogen and non-pathogen (e.g.,

spoilage) contamination.

If the Supplier manufactures or handles microbiologically sensitive materials, the Supplier,

in cooperation with Kraft Foods (if applicable), shall establish a written zoning programcomprised of three steps:

1. Identify potential sources of cross-contamination between processing areas and/or

products (e.g., product handling areas, storage areas, processing areas, rawmaterials). Recognize that intermediate products may not have the same


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susceptibility as the finished product and during the manufacturing of a product therisk may increase from one step to the next. For example, the microbialcontamination of a product before the kill step may not be as critical as its cross

contamination after the kill step, and the controls applied to prevent contaminationbefore the kill step may not be as stringent as the controls applied after the killstep. For a checklist to help identify potential sources of cross-contamination, see

Section K: Zoning in the SQE Resource Supplement .

2. Identify and implement appropriate controls for each zone, based on zoning riskassessment. Examples of such controls include physical measures or barriers, traffic

management, utility controls, GMP measures, and sanitation controls.

3. Periodically evaluate and verify effectiveness and compliance of zoning requirements.This includes, but is not limited to, environmental testing including pathogen testing,GMP audits, and routine pre-operational and operational inspections.

More details on possible sources of cross-contamination among the different plant areas and

examples of area classifications are set out in Section K: Zoning in the SQE ResourceSupplement .

3.11. Pathogen Environmental Monitoring

Suppliers that manufacture or handle microbiologically sensitive materials for Kraft Foods

shall have implemented a program for pathogen environmental monitoring (PEM). Thisprogram shall:

Enable the detection of pathogens, harborage areas, and organisms that indicatepotential presence of pathogens in the processing environment.

Verify the effectiveness of controls for preventing cross-contamination, includingSanitation, GMPs, preventive maintenance, and plant traffic controls.

Provide for periodic training of personnel responsible for PEM activities.

The PEM requirement focuses on two specific pathogens, Salmonella sp. and Listeriamonocytogenes, as well as indicator organisms which predict their presence in theprocessing environment. The written PEM program shall detail the following for each

product or process that presents risk of contamination:

Sampling location, frequency, and method of sampling for each applicable target orindicator organism. Site specific sampling locations shall reflect the most criticallocations. Swab site locations and time frame for taking swabs (e.g., shift, midweek,

end of week) should be audited and changed on a periodic basis.

Criteria for test results to be deemed acceptable.

Corrective action plans, including increased control procedures and verification

requirements.

Whenever product contact surfaces are tested for pathogens, affected product lots shall beplaced on Hold pending the test results (see Section 5.1-Hold & Release). In the event of apathogen-positive result the Kraft Foods Contracting Representative must be notified

immediately, (see Section 1.2- Notifying Kraft Foods of Significant Events), even if thespecific lot is not sent to Kraft Foods. The Supplier shall conduct an investigation to identify


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the potential source and document all corrective actions. They shall also verify theeffectiveness of the corrective actions.

The PEM program shall be reviewed at least every 2 years or whenever a change occurs to

the process or product (e.g., new equipment installation, modification or introduction of anew material).

For further requirements and guidelines, see Section L: Pathogen Environmental Monitoring in the SQE Resource Supplement . Suppliers should also refer to the Kraft Foods -Biologically Sensitive Ingredient Category List in Appendix B of the Kraft Foods Global, Inc.

Supplier and External Manufacturer HACCP Manual . Material specific advice on PEM can berequested from Kraft Foods Corporate Quality.


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CHAPTER 4 - PRODUCTION PROCESS CONTROLS

4.1. Specification Compliance and Contract Review

The Supplier shall ensure that Kraft Foods Specifications are implemented at the productionlocation, or that the Supplier’s own specifications include all chemical, physical and

microbiological parameters present in the Kraft Foods Specifications. The supplier shallensure appropriate plant personnel shall have access to the latest specifications formaterials supplied to Kraft Foods.

The Supplier must deliver materials that meet these Specifications. If the Supplier

anticipates that it will not be able to meet the Specification, Kraft Foods ContractingRepresentative shall be notified immediately (see Section 1.2- Notifying Kraft Foods ofSignificant Events).

Specific testing methods are described in the Specifications. When the Supplier uses a

different method, a validation study must have been performed in order to guarantee anequivalent output.

In cases where Kraft Foods Specifications designate required pathogen analyses as “critical,” each lot must be sampled, and the samples must be collected across the lotaccording to a statistical sampling plan that represents the lot. If target pathogen(s) are

detected in the lot or in similar products produced on the same line, prompt correctiveaction steps shall be taken and Kraft Foods shall be immediately notified, even if the specificlot is not sent to Kraft Foods.

Where Certificates of Analysis (COA) are part of the Specification requirements or havebeen separately requested by the Kraft Foods receiving plant, these must be provided toKraft Foods prior to acceptance of the material at Kraft Foods locations. If a pathogen test

is required for the COA based on Kraft Foods Specifications, the test must be performed bya laboratory approved by Kraft Foods (see Section 2.6 – Testing Controls: LaboratoryRequirements). The COA from the approved laboratory must be supplied to Kraft. Kraft

Foods reserves the right to sample each delivery and to determine the appropriatedisposition.

A COA shall contain:

Supplier name, address, phone number, and contact person.

Address of the manufacturing plant where the material was produced

Material name, lot code, production date and Kraft Foods identification number. Specification number (or purchase agreement) and issue date.

Authorized signature of the Supplier and date of signature.

Statement that the results are actual lot analysis results or composite results

commonly used in commodity industries. The only exceptions would be for analysisthat are indicated in the Kraft Food Specification.

Test and analysis results for each lot, including Kraft Foods Specification target andrange.

Parameter being tested, test method, sample size and sampling method being used.

Laboratory name and location performing the testing.


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The Supplier shall notify the Kraft Foods receiving location if a lot is split between two ormore Kraft Foods locations.

Certificate of Analysis should be written in local language of the receiving Kraft Foods plant.

Material Monitoring Program

Kraft Foods requires that some specific incoming raw materials be part of the MaterialMonitoring Program in order to ensure compliance with our Specifications. The Material

Monitoring Program is designed to check for potential contaminants across the supply chainby verifying that materials meet Kraft Foods Specifications and comply with all applicable

regulatory (federal, state, and local) requirements and industry standards for thedesignated country of the Kraft Foods receiving location. Materials are selected for theprogram based on their Kraft Foods risk profile.

Under the Program, Suppliers must submit samples representative of Kraft Foods specified

materials to a designated Kraft Foods approved laboratory for analytical chemical testing.This testing is in addition to tests that are required for Kraft Foods Specification compliance.

Test results will be released to Suppliers and Kraft Foods, simultaneously.

Program testing may include, but is not limited to: heavy metals, mycotoxins, nitrates,dioxin & PBB, PAH, veterinary drug residues, pesticides, adulteration, melamine, ergot

alkaloid, regional considerations, heterocyclic amines, Rhoda mine B, Sudan red, sodiumthiocyanate, leather protein hydrolysate, lactamases, and lead chrome green.

The specific lot of material submitted for testing may not be shipped to Kraft Foodslocations or to contracted manufacturing facilities producing Kraft Foods branded productuntil the results of the testing confirm that samples meet our Specifications and comply with

all applicable regulatory requirements for the designated country of the Kraft Foodsreceiving location.

Kraft Foods will select the materials to be included in the program and the Suppliers

selected to submit materials for testing will receive further communication from Kraft Foodsdetailing material(s) selected for testing, sample submittal date and shipping protocol and

sample submittal form.

4.2. Hazard Analysis AND Critical Control Points (HACCP)

The Supplier’s products shall be designed, produced, and distributed using HACCP principles

to minimize food safety risks systematically. The Supplier shall have implemented a writtenHACCP plan for all materials produced for Kraft Foods.

The Supplier shall establish a cross-functional HACCP team that is responsible fordeveloping, reviewing, and modifying the plans and maintaining the system. The HACCP

team shall ensure that each HACCP plan and its implementation is properly verified andvalidated on a regular, documented basis.

For Kraft Foods requirements and guidance in developing and implementing a HACCP plan,

the Supplier should consult the Kraft Foods Global, Inc. Supplier and External ManufacturerHACCP Manual .


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When producing goods for Kraft Foods, the performance objective of allprocesses/technologies used to reduce target pathogenic organisms must be defined andvalidated. Data demonstrating effective processing (capable processing) must be made

available to Kraft Foods, upon request. Further, Supplier program requirements mustinclude on-going verification of effectiveness conducted at a minimum frequency of everytwo years or validation when a major change occurs.

4.3. Incoming Materials: Supplier Quality Management

The Supplier shall buy materials only from suppliers who are approved through a program

designed to manage the quality of its own suppliers.

Quality expectations, requirements and/or specifications for purchased goods that areconsistent with the programs in this SQE Manual shall be developed, documented, andprovided to suppliers. Purchased goods specifications shall be consistent with Kraft Foodsraw material Specifications.

Suppliers of purchased goods shall be monitored and tracked relative to their performanceand compliance with quality requirements, expectations, and specifications on an ongoing

basis, Program should include risk assessment and audit by company or 3rd party audits.

Feedback shall be provided to the suppliers to facilitate continuous quality improvement.

4.4. Incoming Materials: Inspection and Testing

The Supplier shall ensure that incoming raw materials, ingredients, and packaging materialscomply with applicable regulations and Supplier’s specifications, including microbiological,

physical, chemical criteria, residue requirements and GMO criteria. The Supplier shallestablish and make available to Kraft Foods testing requirements, parameters and specifiedlimits to ensure food safety and quality of all raw materials, ingredients, and packaging

materials.

The Supplier shall ensure that incoming product is not used or processed until it has beeninspected or otherwise verified as conforming to specified requirements.

Where pathogen testing is conducted, a Hold and Release procedure shall be applied untiltesting is complete (see Section 5.1- Hold & Release).

Raw agricultural commodities and raw material from animal origin must be evaluated toensure compliance with chemical contaminant (e.g., pesticides residues, mycotoxins) andGMO regulations locally and where Kraft Foods receives or uses the materials. Such review

may be conducted through analysis of the commodity or through controlled oversight of thegrower, producer and other persons handling the product.

Prior to accepting incoming materials, the Supplier must verify that delivery vehicles (suchas trucks or railcars) have maintained the quality and safety of the materials during transit.Verification activities may include inspection of internal cleanliness, structural integrity,

inspection of seal integrity, and measurement of internal temperature for refrigerated orfrozen items.

Tankers shall be dedicated to food only – with records available for the previous product

shipped. If applicable, they should be adequately cleaned and sanitized.


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The Supplier’s receiving procedures shall require verification of seals with accompanyingshipping documentation and inspection of other tamper evident devices (e.g., tape) atmoment of receipt (when applicable). Closed trucks shall be locked. When inbound

truckloads and rail shipments are sealed, the Supplier must verify that the seal numbersmatch the transportation documentation (e.g., Bill of Lading) upon arrival in the facility.

Inbound loads suspected of any type of tampering shall be investigated by supplier. The

shipment shall be rejected if the source of tampering cannot be determined.

4.5. Traceability

The Supplier shall have implemented a written program for product traceability following

GS1 requirements, assuring that package and pallet, lot codes, and date information areaccurate and consistent across similar businesses and products. Traceability requirementsapply to all finished products and all components used to produce products, includingingredients, in-process products, rework, primary packaging materials, and/or process

intermediated being shipped to Kraft Foods.

If requested, such as in the event of a product recall or other product-related issue, the

Supplier must provide the relevant traceability information to Kraft Foods within 4 hours.Mock recalls shall be conducted at least once a year to validate the effectiveness of thetraceability program.

For further specific requirements and recommendations for the traceability program, seeSection M: Traceability in the SQE Resource Supplement .

4.6. Allergen Management

The Supplier shall have an effective program to evaluate, identify, and control foodallergens to ensure that specific allergens are not inadvertently incorporated as an

undeclared component of any product. Where possible, allergens must be “designed-out” ofthe product, so that allergen labeling is unnecessary.

An Allergen Assessment shall be carried out as part of HACCP Plan development to identify,review, and document allergens likely to be present. For information on this assessment,please refer to the Kraft Foods Global, Inc. Supplier and External Manufacturer HACCP

Manual . The Allergen Assessment must consider all allergens on the Kraft Foods AllergenCategory List (see Appendix C of the Kraft Foods Global, Inc. Supplier and ExternalManufacturer HACCP Manual) as well as any others identified in local regulations. An

assessment shall be conducted whenever the source of a raw/packaging material, formulaor process that impacts material produced for Kraft Foods has changed.

The Allergen Assessment shall consider possible sources of allergens related to the

formulation, process, and site-specific practices, including: raw materials/ingredients,rework addition and potential for cross-contact in manufacturing, storage or shipmentpractices.

Avoidable allergens introduced through cross-contact from other lines (no commonequipment) or other production areas shall be strictly managed through raw material

handling (e.g., use of color coded utensils and work tools), rework handling, GMP and


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employee allergen awareness training. Allergen-containing materials shall be stored in amanner that will prevent cross-contact.

For processes that are adequately designed for wet cleaning or flushing, avoidable allergens

introduced from manufacturing carry-over (production of a previous product with allergensin the same line) shall be managed through product change-over practices such as productsequencing, flushing, and cleaning. Please refer to Section M: Allergen Management in the

SQE Resource Supplement for requirements and guidance regarding inspection andvalidation of cleaning/flushing following a run containing an allergen not present in the nextproduct to be run on common equipment.

Allergens present through manufacturing cross-contact or carry-over product that cannot be

avoided through product sequencing and cleaning due to technical limitations (e.g., natureof product, design of process) shall be properly identified and labeled. Strict control isnecessary in cases where different varieties have similar labels. However, the cross-contactinformation shall not be used as a substitute for an effective food allergen control program.

Where cross-contact labeling is implemented, all reasonable precautions must still be takento minimize the risk of cross-contact. Producing products containing the same allergens ondedicated lines is preferred if cleaning or other limitations restrict the ability to ensure the

line is free of allergens from the prior run.

Controls shall be in place to make sure that Kraft Foods is notified of all allergens present

(as ingredients or traces). Where a new allergen is identified in a product where it was notpreviously present, and is therefore not labeled (e.g., discovery of an allergen cross-contactor change to the allergen profile of a raw material), Kraft Foods must be notified

immediately (see Section 1.2- Notifying Kraft Foods of Significant Events).

Allergen training must be provided so that all involved personnel are equipped with essentialinformation and skills relative to their job responsibilities and the site allergen risk profile.This includes identifying ingredients and products that contain allergens, knowing the

process steps where unlabelled allergens could be introduced to the product inadvertentlyand understanding the control methods applied.


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4.7. Extraneous Matter

The Supplier shall have implemented a written program to prevent, detect, and control

extraneous matter in material produced for Kraft Foods.

The Supplier shall perform a risk assessment to determine potential sources of extraneous

matter, including: raw ingredients, packaging materials, equipment design, plantenvironment (e.g., ceilings, walls, floors), processing and packaging equipment, utensils,contamination from personnel or other operations such as cleaning and sanitation,

contractor work, rework/work-in-progress protocol, maintenance or repair of equipment,and historical information of types of extraneous matter previously found or reported by

consumers.Periodic reassessments shall be conducted, particularly following changes to the plantenvironment and instances of non-conformances (e.g., consumer complaints, CCP failures).

Based on the risk assessment, the Supplier shall develop an appropriate strategy forminimizing extraneous matter, which may include:

Confirming control strategies at suppliers or sources of materials.

Designing the risk of extraneous matter out of the process (such as eliminatingmetal-to-metal contact on equipment, replacing metal screens with Nitex orequivalent).

Preventing introduction of extraneous matter into the product (for example, through

GMPs, equipment design, preventive maintenance, covers on tanks or conveyor

belts). Detecting and removing extraneous matter (e.g., installation of strainers, screens,

filters, magnets, sieves, metal detectors, X-ray or other devices/programs deemednecessary on the line). For more requirements and guidelines on effective use of

detection equipment, see Section O: Detection and Control of Extraneous Matter in

the SQE Resource Supplement .

When glass and hard plastic exist in the production area, a specific control program shall bein place for the management of these materials. Specific controls shall be applied to

devices that can be a source of extraneous matter when damaged (e.g., sieves). For morerequirements and guidelines on controls for light fixtures and other glass components inproduction areas, see Section O: Detection and Control of Extraneous Matter in the SQE

Resource Supplement .

Appropriate and timely corrective action shall be implemented in case any source ofextraneous matter with potential of falling into the product stream is detected.


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4.8. Rework Control

The Supplier shall have implemented a written program to control the use of rework

materials in any product supplied to Kraft Foods. If rework is to be reincorporated intoproduct as an ‘in-process’ step (not simply repackaging or re-casing finished product), thenthe conditions for use of rework must be clearly set out in the product formula and/or

specifications, and equivalent local documents (e.g., manufacturing recipe, rework matrix).

The conditions of use of rework must include: the type and quantity of rework that can be

added to the target product, conditions of storage, reprocessing steps in which it will beadded, method of addition, identification of allergens, shelf life, special handling

requirements and lot number identification for traceability. If rework is identified aspotentially containing allergens, it must be segregated, controlled, and incorporated only

into the same and/or appropriately labeled product.

Additionally, all rework shall be:

Handled and stored in a manner that ensures the maintenance of product safety and

quality.

Clearly identified with product name, production date and any other relevant

information.

Where rework activities involve removing product from filled or wrapped packages, the

Supplier shall have procedures in place to ensure proper removal and segregation of allpackaging materials to avoid extraneous matter contamination of the product (e.g. use ofappropriate sieves, filters, metal detectors).

The amounts and identification of rework used shall be documented to ensure completetraceability. Rework inventory and usage controls shall include stock rotation practices toensure that the oldest rework is used first. The Supplier shall ensure through its written

program that expired rework is properly disposed of.

The Supplier shall ensure that its use of rework complies with all applicable regulations,

including labeling requirements, for the use of specific materials in the target product. Forexample, use of rework shall not cause the nutritional data or allergen information providedto Kraft Foods to be incorrect.

4.9. Label Control

The Supplier shall ensure that labels are correctly and consistently applied to materialssupplied to Kraft Foods, and that labels meet applicable regulatory requirements and KraftFoods Specifications . In particular, the Supplier shall verify the accuracy of labels for

allergen profile, ingredient information, nutritional information, net quantity and specificclaims.

Each label must clearly exhibit the material name, the name and address of the

manufacturer, packer or distributor, lot number, net quantity, “best if used before” date,storage conditions, preparation instructions (if applicable), allergens and the appropriateKosher symbol if Kosher certification is required. The “best if used before” date shall be

consistent with the shelf life of the material as stipulated by the Kraft Foods Specification.


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The Supplier must ensure through its procedures that labels and pre-printed packages arestored in a manner that minimizes mixed label batches and mixing together with otherlabels and packages. Special attention shall be given to packaging material changeover

practices in line. Unused pre-printed labels at the end of a run must be accounted for ordestroyed to ensure that the next run of materials is not inadvertently mislabeled. TheSupplier also shall have implemented procedures to ensure that labels match products.

Packaging materials must be appropriate for the specific food product being shipped, andmust not impart odor or taste to a specific food product being shipped. Additionally for

shipping to the U.S, packaging materials must meet Food and Drug Administrationregulations for “indirect food additives.”

4.10. Weight Control

The Supplier shall have implemented a written weight control program that complies with allapplicable regulatory requirements. The weight control program shall include the

application of statistical process controls, routine scale verification, periodic calibration,corrective action plans and guidelines for handling non-compliant product.

Sampling criteria for all packaging lines shall be specified in the net weight control plan.Data must be collected routinely and across the compliance lot.

For statistical process controls used, documented results shall indicate that the material is in

compliance with the specification. Corrective actions shall be taken if the process istrending out of control or is not centering on the target.

Out of compliance lots must be held for further evaluation and disposition (see Section 5.1- Hold & Release).

4.11. Material Packaging

All packaging in food contact with the delivered materials must have food-grade certificates.This packaging shall not be from recycled packaging.

Packaging must not alter product organoleptic characteristics and shall not be source offoreign bodies. Staples or metal objects of any kind shall not be used on packaging or on

the pallet. All plastic bags or liners in direct contact with materials must be of a differentcolor from the material itself.

Any proposed change in the size or type of packaging must be submitted to the appropriate

Kraft Foods Contracting Representative for approval prior to modification.


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4.12. Storage and Transportation

The Supplier shall have implemented systems to manage warehousing and transportation to

ensure that the safety, quality, and security of materials and products is maintained at allstages from receipt of materials through delivery of products to Kraft Foods.

The Supplier shall use designated storage areas or stock rooms to prevent damage to,deterioration of or tampering with material. In order to detect deterioration due to suchthings as pest infestation, unsanitary conditions and temperature/humidity control abuses,

the condition of product in stock shall be assessed at appropriate intervals. Storagefacilities shall be neat and orderly. Specific requirements and guidelines for the control of

storage facilities are listed in Section P: Storage and Transportation in the SQE ResourceSupplement .

If the Supplier uses third party warehouses to store raw materials, packaging materials,semi-finished or finished products, the Supplier shall conduct periodic assessments to

ensure that the requirements of this SQE Manual are met.

The Supplier’s transportation program shall ensure that products are properly temperaturecontrolled at all times during transportation, and maintained in good condition, clean, dry

and sealed. For specific requirements and considerations for the transportation program,see Section P: Storage and Transportation in the SQE Resource Supplement .


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CHAPTER 5 - INCIDENT MANAGEMENT

5.1. Hold & Release

The Supplier shall have a written Hold and Release control program that clearly establishesroles and responsibilities for effective implementation. The Hold and Release program shall

apply to product on the Supplier’s premises or in third party facilities used by the Supplier.Materials that are on Hold must be controlled by a defined and effective system which isintended to prevent inadvertent movement. Inventory reconciliation must occur to verify

proper control.

The program shall include controls for non-conforming raw materials, materials pendingtesting (e.g., pathogen testing, sterility testing, Certificate of Analysis (COA) verification),packaging, labels, semi-finished product (work-in-progress), finished product, and rework.The Supplier must maintain records sufficient to enable reconstruction of each hold event

(e.g., quantities, code dates, lot numbers, product numbers, reasons for hold and/orrelease, investigative information, disposition, and traceability information).

The Hold procedure shall address at least two levels of Holds:

Category I Hold – Shall be used when a non-conformity poses a potential food

safety concern or a major regulatory or quality concern. Hold procedures shallensure that product must be placed in a segregated and secured area or is physically

obstructed. Each shipping unit must be labeled as being on hold. Inventory must beconfirmed daily. Hold reasons may be coded for identification, but Hold signs shall

not list the reason for the hold (unless required by a regulatory agency). Examplesof category I holds are:

o Undeclared Allergens identified in product

o Failure to meet CCP requirements

o Failure to meet specified legal requirementso Contamination due to employee illness

o Unacceptable pathogen test result

o Presence of an undeclared ingredient

Category II Hold – Shall be used when a non-conformity poses a potential minorregulatory or product quality concern. A computerized Hold may be sufficient if thesystem effectively blocks selection and shipment of product. Alternatively, productmust be visually labeled as on hold or physically obstructed. Examples of category II

holds are

o Materials that potentially contain unlabelled allergens

o Product undergoing pathogen testing

o A non conformance which causes the last two ingredients on the ingredient listto be in the wrong order

o Foreign material issue with no food safety concern

After release of a lot/code of product to Kraft Foods, the Supplier shall not initiate pathogentesting on either that lot/code of product or any ingredients used in that product.


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If any material produced for Kraft Foods is either inadvertently released from hold or issuspected of non-conformance but has already been shipped to Kraft Foods, the Kraft FoodsContracting Representative shall be immediately notified (see Section 1.2- Notifying Kraft

Foods of Significant Events).

5.2. Product Retrieval

The Supplier shall have written retrieval procedures in place that promptly and effectivelyrespond to product issues that represent an unacceptable risk to Kraft Foods and/or theconsumer.

Product retrieval procedures must include:

Notification procedures, including contact lists and customer contacts.

Protocol for retrieval and disposition of all affected product, with designated authorityand assigned responsibilities to ensure that sufficient controls are followed to allowfor complete retrieval of product.

Identification of delivery points, dates and quantities for affected product delivered

further into the Supply Chain or to customers.

Protocol for isolation of affected stocks and/or materials remaining under control.

The retrieval system shall be tested on an annual basis and after any major system changesto confirm (1) the accuracy of all product and contact data and (2) the continuing

effectiveness of procedures and traceability systems. The results of these tests and anycorrective actions necessary shall be documented.

The Kraft Foods Contracting Representative shall be notified immediately in the event of aproduct retrieval that impacts Kraft Foods products (see Section 1.2- Notifying Kraft Foodsof Significant Events).

5.3. Control and Disposition of Non-conforming Products

Disposition of materials on Hold that do not comply with specific approved Kraft FoodsSpecifications must be effectively controlled and documented. The Supplier shall have

written procedures for the identification, documentation, evaluation, segregation (wherepractical) and determination and execution of the final disposition of non-conformingproducts.

Rejected material shall be clearly identified. The reason for rejection of the material, codedates, quantities involved and its disposition shall be noted on the batch/lot record.

Records of actions and outcomes shall be maintained (for example, certificates or otherevidence of product destruction or burial). Disposition shall be completed in a timelymanner.


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CHAPTER 6 - PACKAGING REQUIREMENTS

6.1. Introduction

The Kraft Foods Supplier Quality Expectations (SQE) outlines the general requirements forall suppliers. Table 1 below details which other chapters of the SQE are relevant for

packaging suppliers. This chapter and the SQE supersede the previous version of the pSQE issued June 23, 2005.

At a minimum, all packaging materials supplied to Kraft Foods must comply with allapplicable laws, regulations, and Codes of Practices and Standards of the production

country and the destination to which the materials will be delivered (both national and localrequirements, as applicable).

All food contact materials shall be accompanied by a declaration of compliance coveringmaterials and conversion (e.g., inks, adhesives, coatings). The declaration shall

demonstrate compliance of food grade quality based on (i) specific migration limits andregulatory requirements for direct or indirect food contact (per application), (ii) Codes of

Practices, and (iii) Standards of the location where the products are produced and thedestination to which products may be delivered. Where no dedicated national foodpackaging legislation for plastic material exists, Kraft Foods requires compliance with either

the European or the U.S. federal (Food and Drug Administration (FDA) (21 CFR), U.S.Department of Agriculture (USDA), U.S. Environmental Protection Agency (EPA)) and stateregulations. All corresponding raw data and documents must be maintained and available.

Requirements for supplier Hazard Analysis and Critical Control Points (HACCP) programs areset forth in the Kraft Foods Global, Inc. Supplier and External Manufacturer HACCP Manual .

Table 1: Applicability of SQE to Packaging Suppliers

Packaging suppliers must comply with sections of the SQE manual except the following

Packaging Type SQE Sections Not applicable to packaging Suppliers

Food Contact Packaging

and/or ContainsIngredient Line

Section 3.10 – ZoningSection 3.11 - Pathogen Environmental MonitoringSection 4.10 - Weight Control

Non-Food Contactand/or Does NotContain Ingredient Line

Section 3.5 - Utilities Management

Section 3.10 - ZoningSection 3.11 - Pathogen Environmental MonitoringSection 4.2 - HACCP

Section 4.6 - Allergen ManagementSection 4.8 - Rework ControlSection 4.9 - Label Control

Section 4.10 - Weight Control


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6.2. Transfer of constituents from a food contact material to food

Packaging materials that come in direct contact with the product, either by design or byforeseeable use, are defined by Kraft Foods as Primary Packaging. Su

Documents

SQE Manual