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#1 mind over matter

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Posted 07 February 2011 - 09:49 AM

Anyway, assuming the (to be visited) facilities do have a certified HACCP, I think you can assume they will already have a typical (traditional )set of PRPs / SSOPs/CCPs. They are also likely to possess most of the documentation ancillary to hazard analyses such as traceability/recall. It seems rather pointless to try and randomly speculate over details from a vast range of possibilities when the material will probably be shortly available anyway

Ok. I'll just wait for their existing documentation. I am very hopeful that they have PRP's and OPR's already. I think HACCP cannot work if PRP's and OPRP's are not already in place. And if they are really GMP and HACCP certified, I assume that their people are properly trained to do the job.



Taken from HERE


Thanks for your feedback Charles C. If you don't mind, I'd like to discuss this with you again (and with other FSQN members) and get some more feedback. I just received the existing documents from our subsidiary. I will do a document review and deliver to them the result next week. Also, I’ll try to do a gap analysis as soon as I get there. It would be my first time to do a gap analysis. Hope that I can do it properly. )

If possible, please review the attached file (list of existing documents). It's actually our subsidiary’s HACCP manual so it doesn’t cover all ISO 22000 requirements. They have to go for ISO 22000 certification soon so a lot of efforts and processes/activities to document. Please let me know what the lacking documents are.

By the way, I made the draft of seven mandatory procedures already. If you need further details (e.g. actual content of certain documents, etc) to address my concern, please let me know so I can send it to you (but I have to re-type it though, the manual I got is hardcopy :o ).

Any comments, thoughts or recommendations would be greatly appreciated. I want to ensure that documentation will be complete as possible, as compliant as possible. Thank you very much in advance. I really hope we are on the right track but you never know!

EDIT: I also didn't see flowcharts in their HACCP manual but they have hazard analysis and evaluation. Do you think their hazard analysis was wrong?

Attached Files


Edited by mind over matter, 08 February 2011 - 02:11 AM.

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#2 Charles.C

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Posted 07 February 2011 - 01:43 PM

Dear MOM,

One initial query.
I note that you have 10 products and 11 haccp plans. :smile:
Please inform how many ccps for each individual haccp plan, if any ? :smile:

Rgds / Charles.C


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#3 mind over matter

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Posted 07 February 2011 - 02:41 PM

NOTE: I deleted to avoid confusion for other. I updated the attachment in OP instead.


Edited by mind over matter, 08 February 2011 - 02:09 AM.

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#4 Charles.C

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Posted 07 February 2011 - 03:00 PM

Dear MOM,

My query was to "CCP" only.

pls inform.

Rgds / Charles.C

PS there must be a small army for monitoring all those (I hope) control points. Unbelievable. :smile:

added Regarding yr edit query -

EDIT: I also didn't see flowcharts in their HACCP manual but they have hazard analysis and evaluation. Do you think their hazard analysis was wrong?


Probably forgot to include copies. Difficult to carry out hazard analysis without flow chart.
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#5 mind over matter

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Posted 08 February 2011 - 02:19 AM

PS there must be a small army for monitoring all those (I hope) control points. Unbelievable. :smile:

[/size][/font]A good tip to remember.

added Regarding yr edit query - Probably forgot to include copies. Difficult to carry out hazard analysis without flow chart.

i probably should check. Please let me know if you need further details.

Edited by mind over matter, 09 February 2011 - 01:59 PM.

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#6 Charles.C

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Posted 08 February 2011 - 05:33 AM

Dear MOM,

Thks for info.
One more query - i see 9/10 haccp plans have one CCP only. Is it the same CCP in each case ? if yes, what is it ?

and

i probably should check.

Yes because cannot readily evaluate the haccp plan(s) without it(them).

Rgds / Charles.C

added - two more queries -

1. Are all the products raw? ie no heating steps are involved anywhere? if not, please inform which item(s) involve heat step. (should be stated on the product description document)(noticed reference to a "cooling vat" in process list).

2. Only a comment. I noticed "client specifications" in yr list of documents however I think most standards will require the existence of yr own "product specifications" also or some documented evidence of mutual agreement to the former's specs.
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#7 mind over matter

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Posted 08 February 2011 - 08:07 AM

Dear MOM,

Thks for info.
One more query - i see 9/10 haccp plans have one CCP only. Is it the same CCP in each case ? if yes, what is it ?

and


Yes because cannot readily evaluate the haccp plan(s) without it(them).

I’ll try to create a process flowchart per product based from the Hazard Analysis Worksheet. Please see attached details of CCP's.

Attached Files


Edited by mind over matter, 08 February 2011 - 08:08 AM.

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#8 Charles.C

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Posted 08 February 2011 - 10:30 AM

Dear MOM,

(Comments on latest pdf in PS at end)

Reviewing earlier posts/threads, I expect you can see for yourself / via Zeeshan’s framework, where specific items related to ISO 22000 are basically lacking. I also understood that you had no local resource to review the existing HACCP content.

Accordingly, I suggest to concentrate first on the HACCP plans.

I presume the HACCP plans for individual products are in separate sections.

It’s up to you but I understand none of the text is available to you in electronic form so that maybe necessary to initially sample from the 10-11 products then add others as per yr workload/interest.

I suggest to initially select 4 items which are of priority to yourself and hopefully illustrate easy and difficult processes. This suggests two raw frozen and two cooked frozen (strictly I guess this is a pasteurisation or sterilisation process but I will continue to use “cooking” since appears on all CCP tables).

Different people use varying presentation styles but a typical haccp plan usually contains entries detailing the folllowing which I suggest you post –

1. Product description / specification sheet .
2. Process flow chart.
3. Identification of potential safety hazards in raw materials / packaging / ingredients
4. hazard analysis, (including risk matrix/decision criteria [if used][components anyway will be required by ISO 22000])(also see No.8)
5.determination of CCPs
6.description of items / functions associated with ccps, eg critical limits, monitoring, corrective action
7. validation of CCPs / critical limits
8. hazard analysis of raw materials receiving (also see No.4 and PS in next post)

Other items such as verification, traceability, prps etc can follow as required.

What do you think ? If too much work for you, can try (1+1) first if you prefer. Other people please feel free to join in also if have comments. Especially if you are fruit experts.

Rgds / Charles.C

PS – thanks previous pdf. You must be doing a lot of typing. :smile:
I count 9 CCPs. Your posted list implies 12. Never mind.
4 (?) products are not mentioned on pdf. Presume these are raw frozen / one CCP each ?

A few preliminary comments on CCP table - .
It appears that all heat-treated products (except “a”) have cooking as a sole CCP, not impossible but rather unusual IMEX, eg the cooling step after cooking is often a CCP also.
IMEX (not fruit) blasting/freezing is not usually a CCP but not impossible.
Generic E.coli is not typically a safety hazard, O157 is.
In the last column, text for cooking CCPs is visibly not consistent. (Possibly the column is redundant anyway?)


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#9 mind over matter

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Posted 08 February 2011 - 02:41 PM

Charles C.

see attached the process flow for frozen puree.
i'll send the rest of the sample you asked tomorrow, i'm still going to create the process flow.

Thank you so much for guiding me and for being patient and very accommodating. I don't know what I will be doing without your help.

I'll pay you back once I win the lottery.


Edited by mind over matter, 01 March 2011 - 05:56 AM.

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#10 Charles.C

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Posted 08 February 2011 - 05:03 PM

Dear MOM,

Thks for flow chart. Quite a lengthy process. Looks neat.

Seven comments (not familiar this product so apologies if errors due process ignorance) –

(a) It is not mandatory but auditors often appreciate identifying steps where CCPs occur (eg by asterisk / key at bottom of chart.) Assists their memory.
(b) Again not exactly mandatory (I think) but it is customary to show all inputs / associated storages on same diagram, eg receiving (raw material, packaging, ingredients [eg water / additives]) (I realise not so simple with yr present flow chart style). If not directly shown, will probably require an additional sheet (for example, see the flow charts in the yoghurt thread of Tony-C).
© Some people number the steps for later convenience. Only problem IMEX is that later changes may cause text difficulties unless you use sub-numbering. No risk if flow is always standard of course.
(d) I noticed 2 receiving steps at beginning ?
(e) No cooling step required after pasteurisation ?
(f) The mixing step after pasteurisation may be microbiologically / hygienically sensitive.
(g) The pasteurisation exit/subsequent stages should presumably be physically separated from the pre-pasteurisation steps. (Not required to be shown on diagram, just a thought.)

Rgds / Charles.C

PS - I have added one more item (No.8) to list in previous post. Some people do the hazard analysis of raw material (including packaging/ingredients) receiving stage within the overall flow process, others (probably the majority these days) use a prerequisite approach (normally optional but not sure for ISO 22000) . Either way, it is usually a key component, especially from an auditor’s viewpoint IMEX

Good luck with the lottery !. :smile:


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#11 mind over matter

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Posted 09 February 2011 - 01:56 PM

Hi Charles C, Please look at my process flow diagram (10 products) and give me your comments. Let me know whether it is better than what created yesterday or not...if you didn’t find difficulty following it. I hope it’s clear to viewers (even outsiders) now. Comments/suggestions for improvement are most welcome :) After providing the process flow per product and identified CCP’s, what information you need next? I hope you won’t get tired of helping me. I am learning. I really hope to learn EVERYTHING I need to know about HACCP and ISO 22000.


Edited by mind over matter, 01 March 2011 - 05:57 AM.

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#12 Charles.C

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Posted 09 February 2011 - 07:05 PM

Dear MOM,

Thks for the 10 flowcharts. Look better IMO.
Seems basically hv 4 groups of product/processes - purees [pasteurised] (6), premixes [pasteurised] (2), raw (1), bits [pasteurised] (1)

If you agree, suggest sample 1 product from each of first 3 groups, eg Frozen Guyabano Puree, Frozen Fruit Salad Pre-Mix, Frozen Fresh Fruit Cuts

Can you post documentation for the HACCP steps 1, 3-8 (post #8) for the above 3 products ?.
Or if you have a different preference, please inform.

Rgds / Charles.C

PS – I noticed that the “cooking” box seems missing from FCP flow chart and there is probable typo “cooling” in box E3 for FUP and maybe extra "Fresh" in caption for FFFS pre-mix


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#13 mind over matter

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Posted 10 February 2011 - 09:55 AM

Dear MOM,

Thks for the 10 flowcharts. Look better IMO.
Seems basically hv 4 groups of product/processes - purees [pasteurised] (6), premixes [pasteurised] (2), raw (1), bits [pasteurised] (1)

If you agree, suggest sample 1 product from each of first 3 groups, eg Frozen Guyabano Puree, Frozen Fruit Salad Pre-Mix, Frozen Fresh Fruit Cuts

Can you post documentation for the HACCP steps 1, 3-8 (post #8) for the above 3 products ?.
Or if you have a different preference, please inform.

I am attaching Frozen Guyabano Puree. Boss took the existing documents home. 2 other suggested products will follow as soon as she bring the documents back.

PS – I noticed that the “cooking” box seems missing from FCP flow chart and there is probable typo “cooling” in box E3 for FUP and maybe extra "Fresh" in caption for FFFS pre-mix

I’ll check it as well. Thank you for pointing out errors or suspected errors.

Attached Files


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#14 Charles.C

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Posted 10 February 2011 - 12:02 PM

Dear MOM,

Thks for document FGP.

Some observations (hopefully doc #8-1 etc will appear soon)

(1) zero tolerant, micro. pathogens in raw material cannot be self-controlled to an acceptable level (ie “0”) as stated. > Pasteurisation ??
(2) The hazard data (col.2) given in “Cooking” CCP last table do not match that in box D2 (col.3), the latter being more sensible.
(3) You really only monitor the temperature at beginning and end of cook ? By checking 1 piece of product perhaps? Very unusual IMEX. Wrong IMO.
(4) The corrective action seems to not include reprocessing. Very unusual. Wrong IMO
(5) Cooking temp. / Time are usually defined by minima IMEX, not by a range. Wrong unless the lowest values are validated minima (?)
(6) E.coli is not a pathogen as previously informed (O157 etc are)
(7) No idea of meaning “at processing area” in last table.
(8) No idea of meaning (boxG) - “Maintain cold storage room at room temp of 5-18ºC” This is a frozen product ? perhaps -18degC ?
(9) No risk of metal contamination ? :smile:
(10) hazard analysis has so far not considered risks from ingredients, eg water, antibac (??)or packaging (which is glass ???)

The process is all manual or ???

Do you have a copy of the risk matrix used ? And the associated decision principle for selecting “significant” hazards (see#8-4) ?

Do you have a document on validation of your cooking procedure, eg target bacteria, justification of temperature / time. Experts here may know this already (help !) but I personally have no idea. This also determines the (mimimum) species entry in hazard column of cooking. I note the absence of Salmonella although does appear in A1B.

Other people are very welcome to comment of course.

Rgds / Charles.C


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#15 mind over matter

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Posted 10 February 2011 - 03:45 PM

Dear MOM,

Thks for document FGP.

Some observations (hopefully doc #8-1 etc will appear soon)

I thought about post #8 as you mentioned earlier, but not sure what you mean. Next I'd like to ask you what does Q1, Q2, Q3, Q4 mean? (I am referring to columns under principle 2 of the Hazard Analysis Worksheet I attached earlier. Sorry for asking very basic question but I don't understand it though it's our (subsidiary) document. I am really ashamed to ask such a simple question but I wanted to learn.

(1) zero tolerant, micro. pathogens in raw material cannot be self-controlled to an acceptable level (ie “0”) as stated. > Pasteurisation ??
(2) The hazard data (col.2) given in “Cooking” CCP last table do not match that in box D2 (col.3), the latter being more sensible.
(3) You really only monitor the temperature at beginning and end of cook ? By checking 1 piece of product perhaps? Very unusual IMEX. Wrong IMO.
(4) The corrective action seems to not include reprocessing. Very unusual. Wrong IMO
(5) Cooking temp. / Time are usually defined by minima IMEX, not by a range. Wrong unless the lowest values are validated minima (?)
(6) E.coli is not a pathogen as previously informed (O157 etc are)
(7) No idea of meaning “at processing area” in last table.
(8) No idea of meaning (boxG) - “Maintain cold storage room at room temp of 5-18ºC” This is a frozen product ? perhaps -18degC ?
(9) No risk of metal contamination ? :smile:
(10) hazard analysis has so far not considered risks from ingredients, eg water, antibac (??)or packaging (which is glass ???)

Taking notes. All your questions above will be clarified at the plant on monday.

The process is all manual or ???

Do you have a copy of the risk matrix used ? And the associated decision principle for selecting “significant” hazards (see#8-4) ?

Do you have a document on validation of your cooking procedure, eg target bacteria, justification of temperature / time. Experts here may know this already (help !) but I personally have no idea. This also determines the (mimimum) species entry in hazard column of cooking. I note the absence of Salmonella although does appear in A1B.

Other people are very welcome to comment of course.

Rgds / Charles.C

Sorry if I wasn't able to answer some of your questions due to limited documents at hand. I'll answer it later anyway. As for risk matrix, I don't have a copy. Too many things to learn, too little time. I feel the pressure.
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#16 Charles.C

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Posted 10 February 2011 - 05:26 PM

Dear MOM,

No problem to ask. We all had to start somewhere. :smile: It's not exactly a small subject though.

I thought about post #8 as you mentioned earlier, but not sure what you mean

Look at top right hand corner of any post, you will see a # plus a running number, eg this one is #16 . used to specify a post within a thead.

Q1-Q4 refer to questions in a risk analysis / decision tree used to determine if step is CCP or not. tree here is probably based on Codex reference method. The tree with questions Q1-Q4 is on pg 30 of attachment below (ah1).

i don't personally use this method but I can point you to one fairly easily understandable / quickly readable explanation of its Q1-Q4 usage for Cheese in the attachment ah2 below (see pg25-27). This uses a very slightly expanded version of Codex tree (5 questions instead of 4) but questions 2 - 5 are identical to the codex (1-4) and you can effectively ignore the Q1 of the 5 question set.
ah2 also uses a special tree for the starting raw material (pg22) where the questions are similar to codex but slightly re-formulated. Can ignore this first time if you like and jump to process flow page (34). (However you will quickly see that the answers in Codex, Q1-Q4 format, are "deducable" from the (pg22) set in some cases.)

There are many directly matched examples to the Q1-Q4 in textbooks / IT but not too familiar myself with any quick, easy-to-understand ones since i don't normally do risk analysis in this format.

Attached File  ah1 - codex 2003 hygiene document .pdf   74KB   43 downloads
Attached File  ah2 - cheese haccp thesis.pdf   572.99KB   45 downloads

Rgds / Charles.C
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#17 mind over matter

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Posted 11 February 2011 - 02:58 AM

(1) zero tolerant, micro. pathogens in raw material cannot be self-controlled to an acceptable level (ie “0”) as stated. > Pasteurisation ??

I think it should be self-controlled. That’s why pasteurization is being practiced, IMO.

(2) The hazard data (col.2) given in “Cooking” CCP last table do not match that in box D2 (col.3), the latter being more sensible.

My mistake. It should be D3. Sorry.

(3) You really only monitor the temperature at beginning and end of cook ?

I think the appropriate monitoring practice should be from start to end of the process, right?

By checking 1 piece of product perhaps? Very unusual IMEX. Wrong IMO.

What is the reasonable quantity of product to check?

(4) The corrective action seems to not include reprocessing. Very unusual. Wrong IMO

So it could be reprocessed? Please forgive my ignorance. I’m very new in the food industry.

(5) Cooking temp. / Time are usually defined by minima IMEX, not by a range. Wrong unless the lowest values are validated minima (?)

So the minimum critical limit should be used. Assuming that 82ºC (taken from HACCP Plan Summary) is the correct minimum critical limit, the actual temperature should be validated against 82ºC (not within 82ºC to 85ºC). Same with time, the minimum time should be used. Let me know if I understand you correctly.

(6) E.coli is not a pathogen as previously informed (O157 etc are)

According to this link http://www.all-creat...-pathogens.html, E. Coli pathogen is deadly. Yes, O157:H7 was mentioned.

(7) No idea of meaning “at processing area” in last table.
(8) No idea of meaning (boxG) - “Maintain cold storage room at room temp of 5-18ºC” This is a frozen product ? perhaps -18degC ?

For item 7&8 - Perhaps preservation of finished product stage – could be storage at the freezer inside the plant, or freezer van during the delivery to customer. This stage needs to be verified at the plant.

(9) No risk of metal contamination ?

This needs to be verified at the plant.
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#18 mind over matter

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Posted 11 February 2011 - 03:01 AM

(10) hazard analysis has so far not considered risks from ingredients, eg water, antibac (??)or packaging (which is glass ???)

Oh, no! They failed to consider these things. Perhaps due to absence of process flow chart/diagram per product. You are blessed with a very good pair of eyes Charles C.

The process is all manual or ???

This needs to be verified at the plant. What are the implications of manual from automated process?

Do you have a copy of the risk matrix used ? And the associated decision principle for selecting “significant” hazards (see#8-4) ?

Matrix they used? None so far. I simply referred to the materials you attached from your post (#16). Great source of information, valuable and excellent.

Do you have a document on validation of your cooking procedure, eg target bacteria, justification of temperature / time. Experts here may know this already (help !) but I personally have no idea. This also determines the (mimimum) species entry in hazard column of cooking. I note the absence of Salmonella although does appear in A1B.

I’ll check this out and will get you back.

Edited by mind over matter, 11 February 2011 - 04:32 AM.

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#19 Charles.C

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Posted 11 February 2011 - 04:27 AM

Dear MOM,

(1) zero tolerant, micro. pathogens in raw material cannot be self-controlled to an acceptable level (ie “0”) as stated. > Pasteurisation ??

I think it should be self-controlled. That’s why pasteurization is being practiced, IMO.


*** Point is that "later pasteurisation step" shud be included in boxA, data row1, col.12

(3) You really only monitor the temperature at beginning and end of cook ?

I think the appropriate monitoring practice should be from start to end of the process, right?

***Yes, optimally continuous

By checking 1 piece of product perhaps? Very unusual IMEX. Wrong IMO.

What is the reasonable quantity of product to check?


***Sarcasm only :smile:

(4) The corrective action seems to not include reprocessing. Very unusual. Wrong IMO

So it could be reprocessed? Please forgive my ignorance. I’m very new in the food industry.


*** In principle yes, or reject

(5) Cooking temp. / Time are usually defined by minima IMEX, not by a range. Wrong unless the lowest values are validated minima (?)

So the minimum critical limit should be used. Assuming that 82ºC (taken from HACCP Plan Summary) is the correct minimum critical limit, the actual temperature should be validated against 82ºC (not within 82ºC to 85ºC). Same with time, the minimum time should be used. Let me know if I understand you correctly.

*** Critical limits : the CL are typically a linked T/t data pair such that as temp inc.,time dec. for achieving the same relative bacterial reduction, and vice-versa. the validation procedure involves measuring the lethality achieved and comparing to minimum requirement. Operationally, a practical (minimum) temp. is usually defined first and the appropriate minimum associated time got from tables. It is not obvious what the actual CL is from the posted table.

The process is all manual or ???

This needs to be verified at the plant. What are the implications of manual from automated process?

******** for example, metal contamination, ability to control


Rgds / Charles.C
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#20 mind over matter

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Posted 11 February 2011 - 08:31 AM

Hi Charles C,

I am attaching the second sample – The HACCP plan for Frozen Fruit Salad Premix. I see similar items you’ve pointed out in Frozen Guyabao Puree but still want to see your comments. Thank you for the great help and willingness. Being that my company won't send me to any training, I have been reading on this site to find out how to do the HACCP and ISO 22000. I truly appreciate your untiring comments; tips etc. as I have nobody here our company to help me. Also, I cannot send myself to a training class due to time and budget constraint.


Edited by mind over matter, 01 March 2011 - 06:16 AM.

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#21 Charles.C

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Posted 11 February 2011 - 10:33 AM

Dear MOM,

Quick comments. Process has 3 stated CCPs, (2Cooling, 1 Cooking)

1. Similar comments for Cooking CCP step/data as per previous.
2. Stated Cooling CCP is absent from summary so no details.
3. Depending on Decision tree in use (eg if Codex), entries in Q1-Q4 columns seem mixed up (eg YYN-) in various steps including the stated CCPs ? (not myself a routine user of decision tree).

It is preferable IMO to have data for Note 2 above / the product specifications / risk matrix / details of process / raw materials to properly evaluate the risk of cooling steps.

Rgds / Charles.C


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#22 mind over matter

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Posted 01 March 2011 - 05:59 AM

Can you post documentation for the HACCP steps 1, 3-8 (post #8) for the above 3 products ?.

Attached is the existing HACCP documentation.

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Edited by mind over matter, 07 March 2011 - 06:05 AM.

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#23 Charles.C

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Posted 02 March 2011 - 07:15 AM

Dear MOM,

You might be interested in this detailed haccp study of a high-tech (I think) process for similar products to the current discussion.

Attached File  HACCP plan fruit purees - s.africa .pdf   714.03KB   31 downloads

I also found this FAO compilation quite interesting on yr product area, eg I enclose one example page below.

Attached File  FAO,mango, guava processing technologies.pdf   56.14KB   14 downloads
( http://www.fao.org/d...00.htm#Contents )

Both the first article above and yr own documents (so far) seem to be missing one critical component of a typical haccp plan - Validation (eg see my earlier posts).

Rgds / Charles.C


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#24 mind over matter

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Posted 02 March 2011 - 08:07 AM

Dear MOM,

You might be interested in this detailed haccp study of a high-tech (I think) process for similar products to the current discussion.

Attached File  HACCP plan fruit purees - s.africa .pdf   714.03KB   31 downloads

I also found this FAO compilation quite interesting on yr product area, eg I enclose one example page below.

Attached File  FAO,mango, guava processing technologies.pdf   56.14KB   14 downloads
( http://www.fao.org/d...00.htm#Contents )

Both the first article above and yr own documents (so far) seem to be missing one critical component of a typical haccp plan - Validation (eg see my earlier posts).

Rgds / Charles.C

And I didn’t see any documents about allergen control as well. Doesn’t HACCP require allergen control? ISO 22000 does speak of allergens. (See ISO 22000 3.3 note 3).

Since said item missed in HACCP key steps, can we deal with it outside of the hazard analysis?

If not, what should be the best way to address it?

By the way, thank you very much for the materials. I'm sure it would be very useful as usual.

As for the validation, I saw the policy statements in the existing HACCP manual that speak of Corrective Action and Process Validation and Verification. Perhaps the team is doing validation and verification activities- but I could be wrong. And I must admit I found validation and verification confusing. My brain hurts.


Can anyone provide examples? Can the same person verify and validate same transaction?

Edited by mind over matter, 02 March 2011 - 09:50 AM.

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#25 Charles.C

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Posted 02 March 2011 - 09:00 AM

Dear MOM,

And I didn’t see any documents about allergen control as well. Doesn’t HACCP require allergen control? ISO 22000 does speak of allergens


Yes indeed. And the possibility may exist, eg

http://www.wholesome...foodrecipes.htm

Since said item missed in HACCP key steps, can we deal with it outside of the hazard analysis?


Yes, by a prerequisite procedure, if there is one ? (assuming it is a significant hazard in current process, is it :smile: ?)

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