
Best Answer Charles.C, 10 December 2013 - 06:50 AM
Dear Tigo,
I presume this is a USDA audit.
I deduce you are only querying the frequency of yr direct observation procedure (my reservations to this activity as a sole verif. procedure already stated)(added later - I subsequently noticed that additional verif.reqs are listed in para. 417.4.)
Not in USA myself but there are several meat people on this forum who will probably know if there is a specific (USDA) maximum interval specified. I doubt there is a minimum.
For a typical (US) overall haccp reference can see -
http://www.fda.gov/F...06801.htm#app-g
(especially appendix G)
and see Fig.2 for example of schedule. (The frequency for corrective actions records review is unusually long IMEX)
As per above treatment, verification includes validation. I am unsure if CFR details follow same logic, probably yes.
IMEX (Codex haccp) most verification activities are regarded as a review function. Daily is often applied for record reviewing. Other routine functions are often done at longer intervals. One approach if unsure is to initially use short intervals, eg daily, then extend after a reasonable time period if no discrepancies.
Rgds / Charles.C
PS - (added) - the FSIS viewpoint on Verification/Validation (using CFR documentation) is here -
I noticed this text (my underlines) -
Following the 90 calendar day period of initial validation, an establishment uses its findings during the initial validation period to fully implement its system and solidify its monitoring and on-going verification procedures and frequencies. The establishment then continues on a daily basis to perform monitoring and verification activities to ensure that the HACCP system continues to be implemented properly. Establishments are required to support both the monitoring and verification procedures selected and the frequency of those procedures as part of 9 CFR 417.5(a)(2). Data gathered during initial validation, during which critical operational parameters are monitored at an intense frequency, is one source of information that can be used to support monitoring and verification procedures and frequencies (see examples in Appendix 4).
Importantly, not all critical operational parameters that are measured during initial validation are monitored on an ongoing basis after the initial validation period is over. For example, some parameters such as spatial configuration or ingredient formulation, may not change over time and therefore, do not need to be monitored. In addition, ongoing verification may include activities that were not performed as part of initial validation, because the purposes of these two processes differ.
Nonetheless, the later text, eg pgs 27-28, rather suggests that in practice verification frequencies are ultimately somewhat arbitrary.
Here is another criterion for the frequency -
It is generally recommended (or required under HACCP regulations) that HACCP verification be done at least annually, and whenever there is a significant change in the food processing and handling system. However, many HACCP verification activities (e.g., equipment calibration) may require more frequent verification. The frequency should be determined by the HACCP team after careful consideration and must be sufficient to ensure and document that the HACCP plan is being implemented properly.
A polite way of saying that it's arbitrary subjective.
PPS - A very readable analysis of haccp verification requirements is extracted below from the famous US Blue Book. This, i think, is primarily oriented to seafood but the basic principles should be equivalent. As noted in the text, frequencies for certain activities are regulatorily specified, for others the logic influencing the choice of frequency is discussed in some detail. But ultimately IMO the typical result is "subjective".
P3S - added later - here are two references containing verification "observation" examples of which (a) supports yr original frequency and (b) supports yr modified rate (latter due Kansas State University) -
