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#26 Charles.C

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Posted 10 June 2011 - 10:16 AM

Dear Alfred-d,

Hello,

You are talking about PRP, OPRP and CCP. What about CP (Control points) ?


This terminology is not routinely used in ISO 22000.(and also not in Codex HACCP).

Some people consider CP = OPRP however the problem is that there are a multitude of definitions of CP varying from "very general" to "very specific".

A similar comment can be made about "Control Measure" however this term is well defined in the standard so at least people have a common reference point.

Rgds / Charles.C
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#27 HPG

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Posted 11 June 2011 - 02:24 AM

Dear HPG,


As i interpret the attachment, the answer is no.

I am assuming the hazard you refer is failure to adequately destroy any specified pathogenic bacteria during the baking process.

Assuming the detailed situation at this step is as described in the Codex Tree/Q3, IMO a NO answer implies that the hazard does not pass the screening step 7.4.3 of ISO 22000, ie it is not a CCP or an OPRP. This is also illustrated in Fig3 of ISO 22004.

If you prefer the decision tree posted by Ken, yr result will presumably be that it (the control activity) is an OPRP unless you initially determined that the hazard is not significant enough to be analysed by the Codex Tree.

Interested to hear any other opinions. :smile:

Rgds / Charles.C

PS I daresay yr food consultant prefers to not select the NO answer you are mentioning. :smile:


Dear Charles C.,
Thanks for your reply, always enjoyed reading your post. :thumbup:

Yes, I use similar decision tree posted by Ken, but different at answer for Q4 (if Q4 is yes, I say not a CCP, but not define as an OPRP)

I didn't think that baking process will be fail to destroy any specified pathogenic bacteria, because the temperature is between 150-180°C for 5-6 minutes.
and I can say that baking is not specific step process to reduce or eliminate the hazard (microbiological hazard) since it's for quality aspect.
That's why I don't say that baking is a CCP (I think the food consultant prefer Q2 is Yes. that's why baking becomes a CCP).

Regards,
Hadi
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#28 Tony-C

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Posted 11 June 2011 - 06:29 PM

I didn't think that baking process will be fail to destroy any specified pathogenic bacteria, because the temperature is between 150-180°C for 5-6 minutes. and I can say that baking is not specific step process to reduce or eliminate the hazard (microbiological hazard) since it's for quality aspect.
That's why I don't say that baking is a CCP (I think the food consultant prefer Q2 is Yes. that's why baking becomes a CCP).
Regards,
Hadi


I see lots of members here saying baking isn't a CCP so please somebody explain to me why isn't it a CCP?

Regards,

Tony
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#29 Charles.C

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Posted 12 June 2011 - 07:17 AM

Dear TonyC,

I see lots of members here saying baking isn't a CCP so please somebody explain to me why isn't it a CCP?

Regards,

Tony


Can try this thread which I think contains a lot of the typical argument(s) -

http://www.ifsqn.com...dpost__p__41184

I also hv a suspicion that in some (many?) cases it may simply be another auditor-type decision like metal detectors. Or even regulatory occasionally maybe. To be resisted at one's peril ! :smile:

Rgds / Charles.C
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#30 Ken

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Posted 12 June 2011 - 07:21 AM

Baking may or may not be a CCP depending on what you are baking!.

If we are talking about bread then the raw dough is perfectly safe to eat before baking and it is not critical to cook the dough thoroughly to assure food safety.

If we are talking about baking say a sausage roll which contains raw meat inside pastry then it is critical to bake these off to a specific temperature as they are then eaten cold without any further heating and could result in a food safety issue if not baked correctly.

I often see baking bread as a CCP and the excuse is that a customer / auditors expect a heat process to be a CCP which it clearly isn't.

Ken


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#31 Ken

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Posted 12 June 2011 - 07:21 AM

Baking may or may not be a CCP depending on what you are baking!.

If we are talking about bread then the raw dough is perfectly safe to eat before baking and it is not critical to cook the dough thoroughly to assure food safety.

If we are talking about baking say a sausage roll which contains raw meat inside pastry then it is critical to bake these off to a specific temperature as they are then eaten cold without any further heating and could result in a food safety issue if not baked correctly.

I often see baking bread as a CCP and the excuse is that a customer / auditors expect a heat process to be a CCP which it clearly isn't.

Ken


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#32 Tony-C

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Posted 12 June 2011 - 06:08 PM

Baking may or may not be a CCP depending on what you are baking!.

If we are talking about bread then the raw dough is perfectly safe to eat before baking and it is not critical to cook the dough thoroughly to assure food safety.

I often see baking bread as a CCP and the excuse is that a customer / auditors expect a heat process to be a CCP which it clearly isn't.

Ken


Thank you Ken

I'm not an expert on bread or baking but as you've said it depends what you're baking. There are many types of bread, some of which contain herbs & spices so would that make baking a CCP?

Also would water quality be an issue and how would that fit in?

Regards,

Tony
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#33 Charles.C

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Posted 13 June 2011 - 07:32 AM

Dear HPG,

(Diverting from bread for the moment :smile: )

Thks yr comments. Although I hv seen several other published, modified, Codex Trees similar to the ones in my previous post, I cannot find any exhibiting an OPRP option as per the one you are using. Do you hv any accessible sources referring to yr methodology ?
I would like to expand my earlier (negative) comment regarding the use of the Codex tree for satisfying the requirements of ISO 22000.
IMO, one fundamental objection to the procedure which is so far presented in this thread is that the Codex Tree is traditionally only acting as a filter for CCPs based on two specific items, (c,f) of the ISO set 7.4.4 (a-g). This IMO is not adequate compared to the implied requirements/guidelines of either ISO 22000 or ISO 22004. I am not saying that the principle of the method is incorrect for selecting CCPs, only that it is insufficient as per my interpretation of the ISO text (for both CCPs and OPRPs).
I appreciate that validation of the effectiveness of the selected CMs is required to be carried out prior to the designation of CCP or OPRP but even so….
I further appreciate that the actual input required for the missing items (a,d,e,g) (but perhaps not b?) will often be auto-conformable but again, even so ….

An additional factor is that as per the definition 3.9 and 7.4.2.2b, ISO 22000 is clearly not concerned only with attributing OPRPs to process steps, as focussed on by the Codex Tree.

The longer decision trees covering (a-g) already given on this forum include the CCP-OPRP options as discussed above so the choice is presumably ultimately with the auditors.
(I hv not mentioned the scoring methods which also hv their advocates but are also clearly longer than the Codex Tree method).

Rgds / Charles.C


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#34 HPG

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Posted 16 June 2011 - 07:45 AM

Dear Charles,

Been sick for 3 days, so just now I can read your comments
Thanks for your comments and make more clear about ISO 22000, since I'm new to this standard (I didn't really understand all the sections :uhm:)
So my question is, how do you choose a process become an OPRP?

When we (with food safety consultant) made HACCP Plan, we use decision tree for choose a process become CCP or OPRP (when the hazards are significant).
If the proses isn't CPP, then we choose it as an OPRP.

@Ken: thanks for your comments

Regards,
Hadi


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#35 Charles.C

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Posted 16 June 2011 - 09:44 AM

Dear HPG,

So my question is, how do you choose a process become an OPRP?



I'm happy to answer yr question but have you already studied a copy of ISO 22004.? This attempts to answer the conceptual part of yr question (among others). Although IMO not totally successful it does considerably clarify ISO 22000. It is therefore convenient to refer to this first.

I am also interested to hear from any other users if they are using yr simple procedure (some further discussion on this here also - http://www.ifsqn.com...dpost__p__46619

Rgds / Charles.C
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#36 HPG

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Posted 17 June 2011 - 01:19 AM

I'm happy to answer yr question but have you already studied a copy of ISO 22004.?


Dear Charles,

Unfortunately, I haven't read it since I don't have it. I have only read ISO 22000 (I got it when I first came in this factory, they only have it, not ISO 22004)
Do you think I need to read it first to understand the whole point of ISO 22000?

Rgds,
Hadi
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#37 Charles.C

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Posted 17 June 2011 - 07:24 AM

Dear HPG,

Do you think I need to read it first to understand the whole point of ISO 22000


An easy answer is YES but in reality it is difficult to give a specific answer without more info., eg are you certified already.?

Personally, I am surprised yr consultant is apparently unaware of the significance of ISO 22004 but maybe he is giving you a “ known workable” solution which already contains its conclusions. The “Codex-Tree” method seems to diminish the necessity of understanding the conceptual details regarding “OPRP” but perhaps that is a positive by-product (if auditorially acceptable) :smile: . The issue of whether all Codex tree rejected “defaults” are acceptable as OPRPs is perhaps not quite resolved so far?.

IMO, the method we are discussing is basically an “approximation” with regard to the standard but if this is (accredited) auditor “approved” it becomes a pragmatic reality. Yr consultant presumably has to be able to validate his suggested procedure. Perhaps he has already done so ? (the type of attachment I posted previously could be one route although mine seemingly do not match yr current system).

As also noted previously, the above analysis is focussed on the process steps. If yr auditor requires a deeper assessment of “essential” system control measures, some further thoughts might be involved. Again, perhaps yr current system already includes this or maybe yr process had no such requirements.

added - One more comment. Other decision trees which are slightly or fully (a-g) extended versions of the ones currently discussed also exist. IMO, some of the latter may not require much more effort to use than the “approximation” although obviously taking more columns of a table. Alternatively, if it is considered that (GO/NO GO) methods are not the best solution, the use of (averaged) scoring schemes is possible. ISO 22004 offers some guidelines for prioritisation within (a-g) but also implicitly suggests that any of these "logical approaches" may be justifiable for the categorisation into CCP/OPRP. It also comments that the particular final mix of CCPs/OPRPs is not that important provided that each relevant control measure has been appropriately validated with respect to its capability of producing a safe food. This is a tacit recognition of the degree of subjectivity involved IMO.

Baking bread processes are not my area but it seems to me that, assuming the baking step is associated with removing a significant microbiological hazard, a scoring method for (a-g) might perhaps have a few (negative for CCP) thoughts over (b,d,f) :smile: .

Rgds / Charles.C
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#38 HPG

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Posted 18 June 2011 - 03:36 PM

Dear Charles,

Thanks for your comments.

I'll try to find and read ISO 22004.

Actually the product are biscuits and yes, we've already certified ISO 22000.

So, back to the question, how do you choose a process become an OPRP (using logical approach)?

Regards,
Hadi


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#39 Charles.C

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Posted 18 June 2011 - 06:38 PM

Dear HPG,

Any of the 3 procedures mentioned previously (ie via standard Codex Tree, extended decision tree, extended scoring method) can IMO form the basis of a logical method to categorise control measures for process steps into CCPs or OPRPs. As already illustrated in this thread, it is the details which may be debatable.
To attempt to answer yr question in a systematic way would involve questions like –

How many characteristics from the set (a-g) in 7.4.4 do you (or your auditor) wish to involve in the CCP/OPRP assessment ?

ISO 22004 suggests a possible prioritisation –

The following may guide the organization in the categorization process:
— the impact of a control measure on the hazard level or frequency of occurrence (the higher impact there is, the more likely the control measure belongs to the HACCP plan);
— the severity on consumer health of a hazard that the measure is selected to control (the more severe it is,
the more likely it belongs to the HACCP plan);
— the need for monitoring (the more pressing the need, the more likely it belongs to the HACCP plan).

The precise meaning of the above guide is not exactly crystal clear either IMHO :smile: .

IMO, all the 3 procedures above have some objections but all hv been used and approved (somewhere). Personally, I currently prefer the last one in principle but that’s just me (not myself a user of ISO 22000).

Rgds / Charles.C

PS - If you want a specific opinion of yr current procedure or any suggestions to "improve", you could post the relevant pieces here, eg how to change baking from a CCP into an OPRP :biggrin:

added - As an example, could use an unweighted (albeit subjective)1-3 scoring-type system similar to those previously presented on this forum [“3” representing my interpretation of the CM’s ability to achieve a closest approach to ISO 22000’s “ideal” CCP]. A possible (just guessing the process style) “baking” result for 7.4.4 (a-g) might then be 3,1,3,2,3,1,3 giving total 16. One previously suggested criterion for separating CCPs/OPRPs is (>= 18) = CCP, otherwise OPRP.

added (2) – Reverting to the discussion several posts back regarding use of the Codex Tree to indicate CCPs / OPRPs, as an illustration of the variety of ingenious interpretations in use, an alternative option which "restarts" from Qu2 in the standard Codex tree is illustrated in the published Procert Decision Tree which is attached below. This simply regards the “NO” as automatically yielding a result of OPRP. Qu4 in the standard tree has been (subjectively) dropped which is obviously debatable.
(It should be remembered that ISO 22004 requires any proposed control measure to hv been validated as "food safety control-effective" before categorisation.)

Attached File  ProCert ISO 22000 decision tree.pdf   126.1KB   108 downloads
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#40 HPG

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Posted 20 June 2011 - 06:08 AM

Dear Charles,

Thanks for your effort and time to explain and comments.
It's more clear to me about identifying OPRP.

I used traditional desicion tree to identify OPRP and CCP (if it's not CCP, I identified it as an OPRP)
Back then, I didn't think that sec 7.4.4 is should be included in decision tree :oops:

I think I get it now, why do you always mention about sec 7.4.4 :doh:

Regards,
hadi


Edited by HPG, 20 June 2011 - 10:38 AM.

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#41 Charles Chew

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Posted 20 June 2011 - 06:22 AM

I used traditional desicion tree to identify OPRP and CCP (if it's not CCP, I identified it as an OPRP)
Back then, I didn't think that sec 7.4.4 is should be included in decision tree

I think I get it now, why do you always mention about sec 7.4.4

While having taken many organizations to ISO 22000, FSSC and BRC certifications, it amazes me how a simple approach to conducting hazard identification / risk assessment be taken to such great length when what Hadi (HPG) clearly indicates just how simple it can be if you interpret it correctly i.e. if it is NOT a CCP then it must be a OPRP Of course, the justification aspects need to be supported by technical / scientific references. Congrats Hadi.
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#42 Charles.C

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Posted 20 June 2011 - 02:39 PM

Dear Charles Chew,

I appreciate your clearly stated opinion which I assume is not an isolated one.

If I understand correctly, you are implying that the designers of the ISO Standard 22000 intended the conventional Codex Decision Tree to be an acceptable “logical approach” for solely deciding "not a CCP" and thereby concluding to be an OPRP. (if I misunderstand, please correct me :smile: )

If this is so, I suggest that paragraphs 7.4.4 (a-g) of the 22000 standard and the relevant text in the guidelines of ISO 22004 are essentially meaningless, for reasons such as clarity / irrelevance / redundancy.

A similar comment could also be applied to a variety of published documents on the implementation of ISO 22000 (including one by a member of the team responsible for the ISO 22000 standard).

And also to some procedures which I understand are recommended by consultants / auditors.

However, it is clear that the above "default" procedure to which you refer is seemingly being auditorially accepted in many (all?) cases. If so, perhaps it is time to review the (apparent) ISO Secretariat decision that the scheduled revision of the 22000 Standard was unnecessary.

Or perhaps for the auditing profession to uniformly / publicly support the exceedingly helpful simplification referred above.

(BTW, can you suggest any links to published documents which use the "direct" CDT technique as mentioned above {eg with multiple OPRP defaults such as with >= Ken's example ?) I'm sure HPG would be interested also :smile: )

@HPG

I think I get it now, why do you always mention about sec 7.4.4


Was that a question or a statement ? :smile:
Rgds / Charles.C
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#43 HPG

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Posted 21 June 2011 - 01:14 AM

Was that a question or a statement ? :smile:


A statement, of course. :biggrin:
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#44 Charles.C

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Posted 22 June 2011 - 04:15 PM

Dear All,

I had a further look round on the net for any examples of the direct “CDT” approach to selecting OPRPs as mentioned in previous posts.
Here is a quite nice-looking Excel tool based (I think) on the method. (I hv added a few bits of Google English under 1st input entry to (hopefully) clarify).
Comments welcome. (I have reservations about some aspects, eg post 49, but the tool appears to be auditor-acceptable, eg see post 48)

Rgds / Charles.C

Attached Files


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#45 Tony-C

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Posted 22 June 2011 - 05:32 PM

Dear All,

I had a further look round on the net for any examples of the direct “CDT” approach to selecting OPRPs as mentioned in previous posts.
Here is a quite nice-looking Excel tool based (I think) on the method. (I hv added a few bits of Google English under 1st input entry to (hopefully) clarify).
Comments welcome.

Rgds / Charles.C



So does it conclude if a significant hazard is not a CCP it is an OPRP? :smile:

Regards,

Tony
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#46 Charles.C

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Posted 22 June 2011 - 06:29 PM

Dear TonyC,

So does it conclude if a significant hazard is not a CCP it is an OPRP


Do you mean a Codex-CCP or an ISO22000-CCP ? :smile:

Rgds / Charles.C

Added – regarding the sole use of the Codex tree, my own conclusion based on very limited data is that there is currently no particular consensus over its (default) use in identifying OPRPs. I think My/Ken's attachments previously posted in this thread already indicate such. Whether most auditors simply do not care what procedure is used as long as the associated documentation, eg validation, is acceptably presented I cannot say.

An analysis by one consultancy is linked below (see particularly the last one-third of the document). The text probably requires use of the Google translator but the basic idea is fairly evident. It demonstrates use of the standard Codex Tree as a 1st-stage filter. Completely opposite analyses can probably also be found elsewhere which may be the basis of the tool attached in previous post.

http://www.training....o22000-744.html

The sad part of all this meandering is that I fear that the use of the added terminology has delivered zero benefit for many resulting safety management systems. So if this thread has done nothing more than highlight available, auditably acceptable, “shortcuts”, some value has been gained IMO.
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#47 Simon

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Posted 22 June 2011 - 07:26 PM

I'm glad I don't have a clue about this stuff. Hmmm maybe I'm an expert then. :smile:


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#48 HPG

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Posted 23 June 2011 - 01:42 AM

Dear All,

I had a further look round on the net for any examples of the direct “CDT” approach to selecting OPRPs as mentioned in previous posts.
Here is a quite nice-looking Excel tool based (I think) on the method. (I hv added a few bits of Google English under 1st input entry to (hopefully) clarify).
Comments welcome.

Rgds / Charles.C


Dear Charles,
The attachment that you gave is from one of consluting company in Indonesia (called Premysis Consulting) and my company used this one.
As you can see, the decision tree that we used is just like the attachment (4 questions for decision tree).
That's why, if it's not CCP, then it's become an OPRP :smile:
And the auditor from CB didn't complaint with it, so we never change it :whistle:

Regards,
Hadi

Edited by HPG, 23 June 2011 - 01:57 AM.

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#49 Charles.C

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Posted 23 June 2011 - 08:26 AM

Dear HPG,

Thks yr comment. I am happy that you were happy with yr auditor. :smile:

(I should add that the excel tool is naturally not 100% without criticisms, eg (a) a risk analysis with LxH giving “significant hazard” but “MxM” “not” is somewhat strange IMEX and the former result possibly unacceptable in USA,(b) not too sure of the logic whereby some "non-significant" hazards,eg "MxM", "HxL", are classified directly as OPRPs).

I briefly looked up yr product in the textbooks and, as “graphically” indicated by Ken, “simple” baked bread indeed seems to be regarded as a very low risk product, for example in terms of microbiological safety incidents. I wonder what yr auditor’s reaction would hv been if you had simply decided that based on the initial risk analysis, “pathogens” are not a significant hazard.

Just like metal detectors, the pragmatic reality is probably that the auditorial profession cannot be expected to engage in these philosophical nuances and must work from a long established cookbook/checklist, particularly where the product is not sensitive anyway. I am sure many factories are equally eager to pay for a prescribed set of requirements. Symbiosis at work. :thumbup:

Rgds / Charles.C


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Kind Regards,

 

Charles.C


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Posted 23 June 2011 - 12:07 PM

I should add that the excel tool is naturally not 100% without criticisms

Well, it's not 100% perfect.
Maybe they try to make it more simple, so everyone can more understand.

I briefly looked up yr product in the textbooks and, as “graphically” indicated by Ken, “simple” baked bread indeed seems to be regarded as a very low risk product, for example in terms of microbiological safety incidents. I wonder what yr auditor’s reaction would hv been if you had simply decided that based on the initial risk analysis, “pathogens” are not a significant hazard.

Eventhough biscuits are low risk product, I don't think the auditor will not consider pathogens as a significant hazard :whistle:

Regards,
Hadi
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