Managing change without breaking food safety
Plain-language summary
When you change something that touches food safety, plan it deliberately so the change doesn't introduce new hazards.
What the clause is really asking
Many food-safety incidents trace back to an uncontrolled change - a new ingredient, a reformulation, a line modification, a new supplier. This clause makes you think through changes to the FSMS in a planned way, considering the purpose, the knock-on consequences, the resources needed and any impact on existing controls before you make them.
What auditors look for
Auditors pick a recent change - new product, equipment, supplier or process - and trace whether food-safety implications were assessed beforehand. They look for evidence the HACCP plan and PRPs were reviewed, not changed after the fact when something went wrong.
Typical evidence
Change request/management-of-change records; pre-change hazard review; updated HACCP and PRP documents; validation of changes where needed
How to comply — recommendations
Have a simple management-of-change routine that triggers a food-safety review before any meaningful change goes live - new ingredient, supplier, equipment, layout or recipe. Make sure the food-safety team signs off and the hazard analysis is revisited. Capture the reasoning so you can show change was controlled.
Common nonconformities
Changes made without food-safety assessment; HACCP not reviewed after a recipe or supplier change; allergen impact of new ingredient missed
Related clauses
ISO 22000 8.5.4, 8.6, 10.3; FSSC 22000 2.5.13 (product design and development), 2.5.15 (equipment change management)
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Qlause provides interpretive guidance only and is not a substitute for the standard. Refer to your licensed copy of the relevant standard for the authoritative text.