9 replies to this topic

[Skye]

As an independent technical consultant, I recently attended a BRC GSFS audit on a bakery and a minor non-conformance was raised by the auditor that the critical control point required validating. By this he meant that I needed to validate why the process step, metal detection, was identified as a CCP and document the validation. However, my interpretation of this clause in the standard is that the control measures in place for the CCP require validation to ensure they are effective in controlling the hazard and preventing critical limits being exceeded. I would be interested in members opinions on this.

[Jayqc]

As an independent technical consultant, I recently attended a BRC GSFS audit on a bakery and a minor non-conformance was raised by the auditor that the critical control point required validating. By this he meant that I needed to validate why the process step, metal detection, was identified as a CCP and document the validation. However, my interpretation of this clause in the standard is that the control measures in place for the CCP require validation to ensure they are effective in controlling the hazard and preventing critical limits being exceeded. I would be interested in members opinions on this.

Hi, maybe he mean't that he wanted to see your decision making process that this is a CPP documented and how this was decided i.e using a decision tree??

[Charles.C]

Dear skye,

I rather agree with previous poster. Sounds like a question of semantics.

In fact, "Validation of CCP" (VoC) as such does not occur (I think) in the Codex presentation of HACCP to which BRC is referenced although "validation of critical limits" does (plus "validation" being used in a more general way.) However yr interpretation of VoC is the typical one IMEX and usually focuses on finding (or developing) a scientific justification for the effectiveness of the chosen control measure and associated critical limits. For example as per this well-known Codex document -

 cxg_069e.pdf   206.71KB   226 downloads

As per previous poster, the other bit sounds seems more like a "validation" of the risk assessment procedure which is also a common auditor requirement, eg "how do you justify the necessity for the CCP".

I suppose both viewpoints could be correct in some respect although assuming you are specifically referring to clause 2.8.3 (BRC5) yr interpretation seems more "valid"

Rgds / Charles.C

[Skye]

No he didn't mean that because I have a documeted CCP Decision Summary which shows the decision making process and he said that was not validation of the CCP.
Kind Regards
Skye.

Hi, maybe he mean't that he wanted to see your decision making process that this is a CPP documented and how this was decided i.e using a decision tree??

[Carlos Leoncini]

How about validating the operation for metal detection?. I mean establishing a procedure and a criteria of acceptance that proves that your devise will work fine under the actual operational conditions?. Would that satisfy the auditor?

[Skye]

Thanks Carlos, yes I'm thinking along the same lines, but I'm also trying to decide how to set out the document.

[Gourav]

As an independent technical consultant, I recently attended a BRC GSFS audit on a bakery and a minor non-conformance was raised by the auditor that the critical control point required validating. By this he meant that I needed to validate why the process step, metal detection, was identified as a CCP and document the validation. However, my interpretation of this clause in the standard is that the control measures in place for the CCP require validation to ensure they are effective in controlling the hazard and preventing critical limits being exceeded. I would be interested in members opinions on this.

you are absolutely right. validation is required to prove the control measure applied is adequate enough to control the hazard identified. no validation for hazard identification is required. decision tree is just one of the options. You can straigt way say this could be the possibility hence thios control measures and that critical one.
Correct me if Iam wrong.

Thanks

Gourav

[Skye]

Thanks Gourav, I'm glad to know that you agree with me. The issue has been driving me crazy for the past week!

[Charles Chew]

As an independent technical consultant, I recently attended a BRC GSFS audit on a bakery and a minor non-conformance was raised by the auditor that the critical control point required validating. By this he meant that I needed to validate why the process step, metal detection, was identified as a CCP and document the validation. However, my interpretation of this clause in the standard is that the control measures in place for the CCP require validation to ensure they are effective in controlling the hazard and preventing critical limits being exceeded. I would be interested in members opinions on this.

Skye,
1. The nonconformity raised on the HACCP Plan is a MAJOR not a minor if indeed "validation" had not been conducted. I believe the auditor had erred in his judgment

2. CCP identification only needs to be justified however the sensitivity of the MD requires validation. Perhaps, in this case, he wants you to validate the correctness of the selected MD sensitivity by testing the test pieces BEFORE each production (if you do not have one). Otherwise, there may be a fundamental error in judgment by the auditor.

[latchaporn]

Thx for sharing