6 replies to this topic

[Andy W]

Hi All,

Firstly please forgive my ignorance on this matter, I am fairly new to this.

The company I work for provide hot and cold meals to approximately 5000-7000 customers per day.

We have a HACCP plan which has been verified and validated with the flowchart etc, we identified our CCP's to be temperature control from receipt, storage, issue, preparation, cooking/cooling and service. Our OPRP's are all in place and it is a fairly well maintained system.


We are audited several times a week by our client and in the past we have been given what they call Breaches of CCP's (BCCP), they refer to HACCP Principles as evidence.

My question is, should we be audited against our own HACCP Plan and not HACCP Principles in general? Some of these Breaches we have received have been nothing to do with temperature control, which are our only CCP's. I want to argue with them that these other incidents or any future should be considered non-conformances as opposed to a BCCP. I want to do this as there are different financial implications between them.

Any help would be much appreciated.

Regards

Andy

[abhagat]

I agree with you that if the non-conformance has nothing to do with 'CCP' in your HACCP program it cannot be a BCCP. It should just be a non-conformance. I would try to convince them in that light. I am sure you have tried that. We have all had our share of unreasonable auditors!

Thank you.

[Charles.C]

Hi All,

Firstly please forgive my ignorance on this matter, I am fairly new to this.

The company I work for provide hot and cold meals to approximately 5000-7000 customers per day.

We have a HACCP plan which has been verified and validated with the flowchart etc, we identified our CCP's to be temperature control from receipt, storage, issue, preparation, cooking/cooling and service. Our OPRP's are all in place and it is a fairly well maintained system.


We are audited several times a week by our client and in the past we have been given what they call Breaches of CCP's (BCCP), they refer to HACCP Principles as evidence.

My question is, should we be audited against our own HACCP Plan and not HACCP Principles in general? Some of these Breaches we have received have been nothing to do with temperature control, which are our only CCP's. I want to argue with them that these other incidents or any future should be considered non-conformances as opposed to a BCCP. I want to do this as there are different financial implications between them.

Any help would be much appreciated.

Regards

Andy

Dear Andy,

Not sure what you mean by OPRP. This is normally unique to a FSMS certified to iso 22000 but not, I think, in yr case.?

Is yr haccp plan approved by yr client. ? If not, why not? (maybe not complete/ready yet ?). Normally clients are themselves the driving force for availability / approval (eg BRC) (to cover their [onwards] back).

If already approved, his complaints should relate to your haccp plan, ie if the complaint is valid (ie you accept it) it will indicate a deficiency in yr haccp plan which should then be modified accordingly.
If you don’t agree with the complaint, then yr client should justify the support for his position. Probably followed by an argument but this is often the (constructive) way to learn more for oneself or educate other people.

IMEX, the terminology BCCP is unknown / ambiguous and possibly (yr) client-originated. A first reaction might be to wonder if yr client is simply “having you on”. But maybe not.

If you wish for comments on a specific (eg disputed) complaint, could consider posting an example here. There is usually no shortage of opinions forthcoming.

Rgds / Charles.C

[Andy W]

Dear Andy,

Not sure what you mean by OPRP. This is normally unique to a FSMS certified to iso 22000 but not, I think, in yr case.?

Is yr haccp plan approved by yr client. ? If not, why not? (maybe not complete/ready yet ?). Normally clients are themselves the driving force for availability / approval (eg BRC) (to cover their [onwards] back).

If already approved, his complaints should relate to your haccp plan, ie if the complaint is valid (ie you accept it) it will indicate a deficiency in yr haccp plan which should then be modified accordingly.
If you don’t agree with the complaint, then yr client should justify the support for his position. Probably followed by an argument but this is often the (constructive) way to learn more for oneself or educate other people.

IMEX, the terminology BCCP is unknown / ambiguous and possibly (yr) client-originated. A first reaction might be to wonder if yr client is simply “having you on”. But maybe not.

If you wish for comments on a specific (eg disputed) complaint, could consider posting an example here. There is usually no shortage of opinions forthcoming.

Rgds / Charles.C

Hi Charles,

Thanks for the input. In answer to your question, yes our HACCP plan has been approved by our client. The term BCCP is probably unique to our client and I had never heard of the term prior to my arrival. I will of course accept any non-conformance penalty issued if we are at fault and we wil take every measure to provide the necessary corrective action in order to prevent a recurrence.

An example of a recent Breach was this:

We have set recipe cards and must produce each dish in accordance with the card. On this particular day Sour Cream was on the menu, due to it not being in stock the chef decided to use natural yoghurt with lemon juice, however the menu label displayed on the service line stated Sour Cream.

The auditor decided this was a Breach of a Critical Control Point and cited HACCP Principles 1,2 & 6 as reference evidence.

I argued this was not a Breach of our CCP's as our CCP's are all temperature control related. I would have accepted a non-conformance but the client decided to ride roughshod over us and issued a Breach.

I just want to be clear for future battles that to Breach us it must be an event that contravenes our own HACCP plan and not the generic principles of HACCP.

Sorry if it's all a bit log winded!

Thanks for your time.

Regards

Andy

[Charles.C]

Hi Charles,

Thanks for the input. In answer to your question, yes our HACCP plan has been approved by our client. The term BCCP is probably unique to our client and I had never heard of the term prior to my arrival. I will of course accept any non-conformance penalty issued if we are at fault and we wil take every measure to provide the necessary corrective action in order to prevent a recurrence.

An example of a recent Breach was this:

We have set recipe cards and must produce each dish in accordance with the card. On this particular day Sour Cream was on the menu, due to it not being in stock the chef decided to use natural yoghurt with lemon juice, however the menu label displayed on the service line stated Sour Cream.

The auditor decided this was a Breach of a Critical Control Point and cited HACCP Principles 1,2 & 6 as reference evidence.

I argued this was not a Breach of our CCP's as our CCP's are all temperature control related. I would have accepted a non-conformance but the client decided to ride roughshod over us and issued a Breach.

I just want to be clear for future battles that to Breach us it must be an event that contravenes our own HACCP plan and not the generic principles of HACCP.

Sorry if it's all a bit log winded!

Thanks for your time.

Regards

Andy

Dear Andy,

Hmmmm. Tricky.

As you indicate, there may be confusion as to what the (agreed?) scope of the auditor’s inspection covered.

I will try and answer based on my experience with routine 3rd party audits so you can see a “worst-case” scenario. Only you know the exact details of yr agreement with client (or maybe not ??).

I should add that I have experienced analogous problems / experiences where supply of raw materials is concerned. Last minute occurrences can be troublesome during an audit!.

I presume you have a haccp plan for each recipe prepared as per Codex format.

Typically an audit of a haccp system involves an appraisal of all the components, eg its compliance with the 12 steps (7 Principles) as suggested by Codex, not just a look at activities directly related to a CCP. The audit usually covers documentation and implementation of the documented plan/system.

As you describe it, yr staff changed one of the ingredients due to shortage. I assume the related haccp plan did not mention this alternative ingredient, eg in product specifications, flow chart, hazard analysis etc. I assume no difference in micro. risks between the alternative ingredients (?) and no difference in any allergenic factors involved.

From a strictly documentation point of view (POV), this change, I guess, could be seen as conflicting several of the 12 steps in Codex document, eg 1, 2, 4, 6. I suppose the auditor could also argue that the changes rendered yr procedure to choose CCPs invalid. From a purely implementation POV, the change obviously conflicted with step 5.
(The usual avoidance measure for this kind of difficulty (especially if anticipated to re-occur) is to include an appropriate exception clause somewhere in the text (or flow chart) although yr client may take exception to this of course. Or, depending on yr client relationship, you could separately specify agreement for such variations.)

Additionally, in the case of private FS standards, NCs are also usually graded, eg major / minor etc depending on the perceived relevance to food safety and an overall tolerance is used for drawing conclusions. IMEX, clients tend to use similar logics otherwise confrontations are likely ad infinitum due to, for example, alleged “nitpicking”. Yr client appears to be relatively "hard-nosed".

I agree with you that the inspection should be with reference to yr approved haccp plan. However the net result may well be the same since yr plan layout should also follow the Codex format (?). IMO it is always the auditor's obligation to clearly spell out the exact source of any NC although sometimes this can take some extracting.

Not sure if the above helps or hinders, please revert if unclear.

Other people welcome to comment / disagree of course.

Rgds / Charles.C

[Andy W]

Dear Andy,

Hmmmm. Tricky.

As you indicate, there may be confusion as to what the (agreed?) scope of the auditor’s inspection covered.

I will try and answer based on my experience with routine 3rd party audits so you can see a “worst-case” scenario. Only you know the exact details of yr agreement with client (or maybe not ??).

I should add that I have experienced analogous problems / experiences where supply of raw materials is concerned. Last minute occurrences can be troublesome during an audit!.

I presume you have a haccp plan for each recipe prepared as per Codex format.

Typically an audit of a haccp system involves an appraisal of all the components, eg its compliance with the 12 steps (7 Principles) as suggested by Codex, not just a look at activities directly related to a CCP. The audit usually covers documentation and implementation of the documented plan/system.

As you describe it, yr staff changed one of the ingredients due to shortage. I assume the related haccp plan did not mention this alternative ingredient, eg in product specifications, flow chart, hazard analysis etc. I assume no difference in micro. risks between the alternative ingredients (?) and no difference in any allergenic factors involved.

From a strictly documentation point of view (POV), this change, I guess, could be seen as conflicting several of the 12 steps in Codex document, eg 1, 2, 4, 6. I suppose the auditor could also argue that the changes rendered yr procedure to choose CCPs invalid. From a purely implementation POV, the change obviously conflicted with step 5.
(The usual avoidance measure for this kind of difficulty (especially if anticipated to re-occur) is to include an appropriate exception clause somewhere in the text (or flow chart) although yr client may take exception to this of course. Or, depending on yr client relationship, you could separately specify agreement for such variations.)

Additionally, in the case of private FS standards, NCs are also usually graded, eg major / minor etc depending on the perceived relevance to food safety and an overall tolerance is used for drawing conclusions. IMEX, clients tend to use similar logics otherwise confrontations are likely ad infinitum due to, for example, alleged “nitpicking”. Yr client appears to be relatively "hard-nosed".

I agree with you that the inspection should be with reference to yr approved haccp plan. However the net result may well be the same since yr plan layout should also follow the Codex format (?). IMO it is always the auditor's obligation to clearly spell out the exact source of any NC although sometimes this can take some extracting.

Not sure if the above helps or hinders, please revert if unclear.

Other people welcome to comment / disagree of course.

Rgds / Charles.C

Thank you for the response Charles, I guess as I'm fairly new to this I may have to take a few jabs to the chin from my client until I'm well versed enough to argue my case.



Regards



Andy

[Charles.C]

Dear Andy,

You’re right. It can take a little time to get conversant with the rules of the "game". In fact, there are so many possible twists and turns that I doubt any of us get that conversant.

It sounds like you are probably handling a large number of recipes.? If not, maybe no need to read on.
If so, yr setup may be analogous to systems like centralized school kitchens which have come up several times on this forum. The usual primary request is how to document the vast array of mixes in order to develop a manageable haccp plan(s). Any simplification obviously depends on the range of variations in menu make-up but in the US, one quite successful methodology has been to divide/group the meals according to their CCP pattern (usually 1-3 temperature CCPs, prob. similar to your own). This then results in 2-3 categories. As a result, only 2-3 basic haccp plans are required, each of which is correlated to a large number of recipes. Cross- referencing facilitates the documentation being updated and flexible. The US groupings have been published and are attached / linked in several threads here. But it doesn't simplify so easy where a large variety of fundamentally different inputs are involved.

You may know all the above already of course. If otherwise and you are interested, I / other people can point you to some of the relevant links.

Rgds / Charles.C