Jump to content

  • Quick Navigation
Photo
- - - - -

Hazard Analysis question

HACCP Hazard Analysis FSSC22000

  • You cannot start a new topic
  • Please log in to reply
21 replies to this topic

#1 Mr. Incognito

Mr. Incognito

    "Mostly Harmless"

  • IFSQN Fellow
  • 1,552 posts
  • 258 thanks
121
Excellent

  • Earth
    Earth
  • Gender:Male

Posted 21 August 2014 - 03:06 PM

Question for all of the HACCP gurus out  there.

 

At my training yesterday the auditor sounded like he was saying that you need to evaluate a risk based  on it's own inherent properties for likelihood and severity  after that you would list what steps/programs you have at that step for mitigating that hazard. 

 

For example he said that any allergen should be considered the highest severity in the scale being used because it will kill people. 

 

We are currently working on our hazard analysis and the way they are running it is that the allergen is rated low because of sorting/sieving/etc.

 

I understand that equipment can lower the severity or likelihood of a hazard but that's what you're doing in the process.

 

Example:

Likelihood: 1 (most likely) - 5 (less likely)

Severity: 1 (most severe) - 5 (least severe)

 

 

Process |  Equipment  |    Hazard | Severity | Likeliness | Rating (S*L) |                PRP                                                     | Process Step | CCP (Y/N) | CP (Y/N) 

 

   XXX    |     XXX         |   Allergen |    1        |        1        |         1           |  Allergen management, labeling, intended use |  NA                 | N                | N

 

Or

 

   XXX    |     XXX         |   Allergen |    5        |        4        |        20          |  Allergen management, labeling, intended use |  NA                 | N                | N

 

So which one is right, or more right, saying that the allergen is going to kill people or saying it's not going to because of the programs and process steps that are in place?

 

If you're confused let me know and I'll try to explain better.

 

 


  • 0
____________________________________________________________________________________________________

Mr. Incognito


:tardis:

Mr. Incognito is a cool frood who can travel the width and breadth of the galaxy and still know where his towel is.

#2 fgjuadi

fgjuadi

    Grade - PIFSQN

  • Banned
  • 898 posts
  • 193 thanks
9
Neutral

  • United States
    United States
  • Gender:Male

Posted 21 August 2014 - 03:13 PM

Well they both are - you have the original hazard, say likelihood is a 5, you put in place a mitigation step, allergen control, that drops it down to a 2. 

We did this a lot with safety risk assessments - two hazard calculations, 1 before controls and 1 after.  I included the 2nd risk assessment column in our HACCP - it actually helped a lot when we looked at anything that was still high risk after controls. 

 

I suppose you should stick with the convention in your plan - if your other hazards are listed as pre-control, I would list this one the same way. 


Edited by magenta_majors, 21 August 2014 - 03:14 PM.

  • 0
.--. .- -. - ... / --- .--. - .. --- -. .- .-..

#3 Mr. Incognito

Mr. Incognito

    "Mostly Harmless"

  • IFSQN Fellow
  • 1,552 posts
  • 258 thanks
121
Excellent

  • Earth
    Earth
  • Gender:Male

Posted 21 August 2014 - 03:37 PM

Well the way I wanted to do it was pre-control but they are doing it post control so they are listing things as low severity or likelihood because of the controls listed on the side. Personally I thought it should be the straight risk of the hazard and then you list what you are doing to mitigate that risk... maybe it's ok both ways... 


  • 0
____________________________________________________________________________________________________

Mr. Incognito


:tardis:

Mr. Incognito is a cool frood who can travel the width and breadth of the galaxy and still know where his towel is.

#4 fgjuadi

fgjuadi

    Grade - PIFSQN

  • Banned
  • 898 posts
  • 193 thanks
9
Neutral

  • United States
    United States
  • Gender:Male

Posted 21 August 2014 - 04:13 PM

Well the way I wanted to do it was pre-control but they are doing it post control so they are listing things as low severity or likelihood because of the controls listed on the side. Personally I thought it should be the straight risk of the hazard and then you list what you are doing to mitigate that risk... maybe it's ok both ways... 

 

Oh...I think standard is to do pre-control...?   A lot of the guidance says "It's whatever the HACCP team decides!" which can be kind of tricky....

You need pre control to know what exactly you're mitigating and why.  If everything was low risk, you wouldn't have any controls in place at all.  Better to have both then if you're going to have post control on there as well. But - I'm not an expert, only been doing risk assessments for 'bout 3 years now.  

 

 

I thought it was really helpful to go through both with the HACCP team and have them  assign before & after risk (with guidance) so that they understood the thought process - "Glass will hurt someone / wow, we have a lot of places with glass,/ oh if we control it, it's okay/ Gee, now I understand why we have to report glass. 


  • 0
.--. .- -. - ... / --- .--. - .. --- -. .- .-..

#5 ChocolatesMyGame

ChocolatesMyGame

    Grade - AIFSQN

  • IFSQN Associate
  • 37 posts
  • 6 thanks
6
Neutral

  • United States
    United States
  • Gender:Female

Posted 21 August 2014 - 05:39 PM

IME, severity is usually the inherent property and the likelihood is based on if no controls were present.  In our plant's case, an allergen is inherently severe since consumers who are allergic can die or become severely sick from them, and since we have many allergens running on similar lines, we also say it's highly likely.


Edited by ChocolatesMyGame, 21 August 2014 - 05:45 PM.

  • 0

Thanked by 1 Member:

#6 Mr. Incognito

Mr. Incognito

    "Mostly Harmless"

  • IFSQN Fellow
  • 1,552 posts
  • 258 thanks
121
Excellent

  • Earth
    Earth
  • Gender:Male

Posted 21 August 2014 - 05:50 PM

That's how I felt about it. I'll keep looking at what other people say.


  • 0
____________________________________________________________________________________________________

Mr. Incognito


:tardis:

Mr. Incognito is a cool frood who can travel the width and breadth of the galaxy and still know where his towel is.

#7 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,460 posts
  • 3246 thanks
347
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 21 August 2014 - 10:44 PM

Dear Mr.Inc.,

 

I suspect some confusion over the terms, severity, likelihood, risk may be occurring.

 

I don't quite agree with yr trainer in the sense that for some hazards the severity is a function of concentration which could change, eg increase, during a process. Maybe it depends on what he means by "inherent". :unsure:

 

I prefer the hazard analysis method where, given the existing process, calculation shows that the likelihood of a risk occurring at the consumer in the event of a variation in the process setting is "significant." The estimation logic is invariably subjective at some level as usually also evident in the subsequent risk matrix (if used).

 

[This is a version of the haccp method known as "What if something goes wrong"?]

 

But, as already indicated in the previous posts, different interpretations/methods for calculating risk exist in haccp textbooks. Personally, I have never seen the pre-post idea used in textbooks ? However, IMEX as long as you can reference a decent source of yr methodology and the result "makes sense", auditors will usually not challenge very much.

 

Should be interesting to see how yr trainer selects CCPs. :smile:

 

Rgds / Charles.C


  • 0

Kind Regards,

 

Charles.C


#8 fgjuadi

fgjuadi

    Grade - PIFSQN

  • Banned
  • 898 posts
  • 193 thanks
9
Neutral

  • United States
    United States
  • Gender:Male

Posted 22 August 2014 - 02:46 AM

Okay, now that I'm not sober the answer is clear.  :potplant:

 

As everyone has said, they should all be the hazard as it exists until you put the control on it.

 

But FMEA analysis take that secondary step of if controls in place are enough (post-control analysis.  That's something Safety does via continuous risk analysis.  QA seems to do initial risk analysis and verification


  • 0
.--. .- -. - ... / --- .--. - .. --- -. .- .-..

#9 Tony-C

Tony-C

    Grade - FIFSQN

  • IFSQN Fellow
  • 2,958 posts
  • 791 thanks
167
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Location:Koh Samui
  • Interests:My main interests are sports particularly football, pool, scuba diving, skiing and ten pin bowling.

Posted 22 August 2014 - 06:27 AM

At my training yesterday the auditor sounded like he was saying that you need to evaluate a risk based  on it's own inherent properties for likelihood and severity  after that you would list what steps/programs you have at that step for mitigating that hazard. 

 

Was this auditor training or HACCP training?

 

Anyway this is not as per CODEX Guidelines:

 

Attached File  CODEX Recommended International Code of Practice General Principles of Food Hygiene Page 25_025.png   210.98KB   17 downloads

 

Further to the above CODEX section: Consideration should be given to what control measures, if any exist, can be applied to each hazard.

 

Just for clarification, you have indicated your control measure is sorting/sieving (allergen is rated low because of sorting/sieving/etc.)?
From your post is seems that a significant hazard is being controlled by sorting/sieving and this reduces the risk of the hazard to an acceptable level?

I assume that you would then use the decision tree to determine if it is a critical control point:
Are Control Measures in place for this hazard? Yes
Does the step eliminate or reduce the hazard to an acceptable level? Yes

 

Attached File  HACCP Example Mr I.png   400.34KB   18 downloads

 

CCP?

CODEX also adds: More than one control measure may be required to control a specific hazard(s) and more than one hazard may be controlled by a specified control measure.
If your HACCP Team determine this is not a CCP? then you may decide it is controlled adequately by a combination of your PRPs (Allergen management, labeling, intended use) and sieving/sorting but this should be reflected in your hazard assessment notes and appropriate procedures/measures taken to ensure these controls are in place.

 

Regards,

 

Tony


  • 0

#10 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,460 posts
  • 3246 thanks
347
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 22 August 2014 - 06:52 AM

Dear Mr.Inc.,

 

The other  factor so far not discussed (and also by the trainer?) is the influence of Prerequisites on the hazard analysis. I assume these are the first defined control measures.

 

At one time, these control measures were mostly restricted to the process environment. But no longer ! Some modern haccp approaches choose to maximise the control of hazards via PRPs (and also minimise number of CCPs). A further consequence of the generated PRPs is that the associated, controlled, hazards may automatically be considered as low risk, non-significant, and thereby exempted from the hazard analysis as far as determining CCPs is concerned.

 

So which one is right, or more right, saying that the allergen is going to kill people or saying it's not going to because of the programs and process steps that are in place?

 

Insufficient data.

 

Rgds / Charles.C


  • 0

Kind Regards,

 

Charles.C


#11 cazyncymru

cazyncymru

    Grade - FIFSQN

  • Banned
  • 1,604 posts
  • 320 thanks
121
Excellent

  • Earth
    Earth
  • Gender:Male

Posted 22 August 2014 - 07:45 AM

I can (almost) understand where your trainer is coming from

 

Lets take, as an example, Oats going into a bircher muesli product.

 

In its original dry form, probably one of the only risks is allergenic / foreign bodies , which we'll ignore for a moment. I would think that not much in the way of micro would grow on an oat (I'm probably wrong and I'm sure someone will tell me if I am!) . But once that oat has been  utelised in say a product such as a bircher muesli, then the risk and the severity from micro contamination could become higher.

 

This is why I use the CCFRA decision tree as I can then demonstrate against this step how the pre-requisites would help "control" this potential contamination

 

Caz x


  • 0

#12 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,460 posts
  • 3246 thanks
347
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 22 August 2014 - 08:30 AM

Dear Mr.Inc,

 

For example he said that any allergen should be considered the highest severity in the scale being used because it will kill people.

 

In no way disputing the potential severity of reactions to allergens, eg anaphylactic shock / death but the above seems a rather debatable statement for someone who presumably knows the meaning of "validation". For example -

 

The Asthma and Allergy Foundation of America estimates that peanut allergy is one of the most common causes of food-related death.[19] However, there is an increasing body of medical opinion that the measures taken in response to the threat may be an over-reaction out of proportion to the level of danger:[18] "About 3.3 million Americans are allergic to nuts, and even more—6.9 million—are allergic to seafood. However, all told, serious allergic reactions to foods cause just 2,000 hospitalisations a year (out of more than 30 million hospitalisations nationwide). And only 150 people (children and adults) die each year from all food allergies combined." Media sensationalism has also been blamed.[20]

 

http://en.wikipedia..../Peanut_allergy

To better quantify the impact of foodborne diseases on health in the United States, we compiled and analyzed information from multiple surveillance systems and other sources. We estimate that foodborne diseases cause approximately 76 million illnesses, 325,000 hospitalizations, and 5,000 deaths in the United States each year. Known pathogens account for an estimated 14 million illnesses, 60,000 hospitalizations, and 1,800 deaths. Three pathogens, Salmonella, Listeria, and Toxoplasma, are responsible for 1,500 deaths each year, more than 75% of those caused by known pathogens, while unknown agents account for the remaining 62 million illnesses, 265,000 hospitalizations, and 3,200 deaths. Overall, foodborne diseases appear to cause more illnesses but fewer deaths than previously estimated.

 

http://wwwnc.cdc.gov...99-0502_article

(Note that above data not particularly current but i didn't notice any recent reports of  sudden upsurges in allergen-related incidents)

 

Rgds / Charles.C

 

PS - a little more recent, 2009 -

 

In her December 8 New York Times article, "Researchers Put a Microscope on Food Allergies," Karen Ann Cullotta cites a statistic commonly used in articles about food allergies: "Up to 200 deaths each year are attributed to the most severe reaction, food-induced anaphylaxis," she writes. A similar statistic appears in Nicholas A. Christakis' recent British Medical Journal article, "This Allergies Hysteria is Just Nuts," which is referenced in the Times' "Well" blog today. Dr. Christakis writes in the BMJ that "Only 150 people (children and adults) die each year from all food allergies combined." Having seen these statistics used over and over again in the media and the medical literature, I wondered: how many people really die of food allergies? 150 or 200? As it turns out, the real number of food allergy deaths is much smaller: just 11. The 150-200 death estimate comes from the media resource kit of the Food Allergy and Anaphylaxis Network, a lobbying and educational group headed by a former marketing executive at Dey Pharmaceuticals, the maker of the EpiPen adrenaline injector (which is prescribed to millions of food-allergic patients). It's time for journalists and doctors to stop using FAAN's exaggerated statistic.

 

http://www.huffingto...s_b_151462.html


  • 0

Kind Regards,

 

Charles.C


#13 Mr. Incognito

Mr. Incognito

    "Mostly Harmless"

  • IFSQN Fellow
  • 1,552 posts
  • 258 thanks
121
Excellent

  • Earth
    Earth
  • Gender:Male

Posted 25 August 2014 - 12:43 PM

a few answers to your questions:

 

First off the original example was just to add context to the question.  One way sifting reduces a possible allergen issue is to remove any soybeans that could be in the wheat... but that's not really what I'm after here.  Please consider that strictly tangential to the conversation.

 

When you are reading the HACCP plan are the numbers for how likely and how severe a risk is supposed to be based on the merit of the risk alone before any PRPs, CPs, or CCPs are defined? 

 

I have magnets, sifters, rollstands, and a metal detector in my process flow.  Just because I have those things doesn't mean that the risk that metal will enter the product stream is any less.  It does mean that metal in the finished bag, or bulk truck, of flour should be less.  And that has been demonstrated through years of production.  So it's my understanding that you should rate the likeliness of the metal getting into the product at the appropriate level for that step and then list the relevant process steps or prerequisite programs that mitigate that risk.


  • 0
____________________________________________________________________________________________________

Mr. Incognito


:tardis:

Mr. Incognito is a cool frood who can travel the width and breadth of the galaxy and still know where his towel is.

#14 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,460 posts
  • 3246 thanks
347
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 25 August 2014 - 01:56 PM

a few answers to your questions:

 

 

First off the original example was just to add context to the question.  One way sifting reduces a possible allergen issue is to remove any soybeans that could be in the wheat... but that's not really what I'm after here.  Please consider that strictly tangential to the conversation.

 

When you are reading the HACCP plan are the numbers for how likely and how severe a risk is supposed to be based on the merit of the risk alone before any PRPs, CPs, or CCPs are defined? 

Traditionally before HACCP was/is GMP (=Prerequisites). But see #10. Risk assessment begets CCPs (and for some people - some PRPs).

 

I have magnets, sifters, rollstands, and a metal detector in my process flow.  Just because I have those things doesn't mean that the risk that metal will enter the product stream is any less.  It does mean that metal in the finished bag, or bulk truck, of flour should be less.  And that has been demonstrated through years of production.  So it's my understanding that you should rate the likeliness of the metal getting into the product at the appropriate level for that step and then list the relevant process steps or prerequisite programs that mitigate that risk.

Hazard analysis IMO is a cumulative procedure. See #7. The fundamental objective of  traditional HACCP is to locate CCPs, eg see the Codex Tree (or later versions).

 Dear Mr. Inc.

 

Seems like a new OP ? :smile:

 

The fact is that many flavours/interpretations of HACCP co-exist (just like RA). A chosen reference point is useful. Especially for audits.

 

If not already perused, I suggest you study the explanative sections of this brilliant document, an oldie but goodie  -

http://www.fda.gov/F.../ucm2006801.htm

(some of the finer details may have changed over time but the basics are pretty solid)

 

Rgds / Charles.C


  • 1

Kind Regards,

 

Charles.C


Thanked by 1 Member:

#15 Mr. Incognito

Mr. Incognito

    "Mostly Harmless"

  • IFSQN Fellow
  • 1,552 posts
  • 258 thanks
121
Excellent

  • Earth
    Earth
  • Gender:Male

Posted 26 August 2014 - 12:24 PM

 Dear Mr. Inc.

 

Seems like a new OP ? :smile:

 

The fact is that many flavours/interpretations of HACCP co-exist (just like RA). A chosen reference point is useful. Especially for audits.

 

If not already perused, I suggest you study the explanative sections of this brilliant document, an oldie but goodie  -

http://www.fda.gov/F.../ucm2006801.htm

(some of the finer details may have changed over time but the basics are pretty solid)

 

Rgds / Charles.C

 

 

"After the list of potential hazards is assembled, stage two, the hazard evaluation, is conducted. In stage two of the hazard analysis, the HACCP team decides which potential hazards must be addressed in the HACCP plan. During this stage, each potential hazard is evaluated based on the severity of the potential hazard and its likely occurrence. Severity is the seriousness of the consequences of exposure to the hazard. Considerations of severity (e.g., impact of sequelae, and magnitude and duration of illness or injury) can be helpful in understanding the public health impact of the hazard. Consideration of the likely occurrence is usually based upon a combination of experience, epidemiological data, and information in the technical literature. When conducting the hazard evaluation, it is helpful to consider the likelihood of exposure and severity of the potential consequences if the hazard is not properly controlled. In addition, consideration should be given to the effects of short term as well as long term exposure to the potential hazard. Such considerations do not include common dietary choices which lie outside of HACCP. During the evaluation of each potential hazard, the food, its method of preparation, transportation, storage and persons likely to consume the product should be considered to determine how each of these factors may influence the likely occurrence and severity of the hazard being controlled. The team must consider the influence of likely procedures for food preparation and storage and whether the intended consumers are susceptible to a potential hazard. However, there may be differences of opinion, even among experts, as to the likely occurrence and severity of a hazard. The HACCP team may have to rely upon the opinion of experts who assist in the development of the HACCP plan."

 

So... that being said.  You should be rating the likelihood and severity of the identified hazard on it's merit alone and not adjusted for already instituted control measures or PRPs...


  • 0
____________________________________________________________________________________________________

Mr. Incognito


:tardis:

Mr. Incognito is a cool frood who can travel the width and breadth of the galaxy and still know where his towel is.

#16 Mr. Incognito

Mr. Incognito

    "Mostly Harmless"

  • IFSQN Fellow
  • 1,552 posts
  • 258 thanks
121
Excellent

  • Earth
    Earth
  • Gender:Male

Posted 26 August 2014 - 12:29 PM

Was this auditor training or HACCP training?

 

Anyway this is not as per CODEX Guidelines:

 

attachicon.gifCODEX Recommended International Code of Practice General Principles of Food Hygiene Page 25_025.png

 

Further to the above CODEX section: Consideration should be given to what control measures, if any exist, can be applied to each hazard.

 

Just for clarification, you have indicated your control measure is sorting/sieving (allergen is rated low because of sorting/sieving/etc.)?
From your post is seems that a significant hazard is being controlled by sorting/sieving and this reduces the risk of the hazard to an acceptable level?

I assume that you would then use the decision tree to determine if it is a critical control point:
Are Control Measures in place for this hazard? Yes
Does the step eliminate or reduce the hazard to an acceptable level? Yes

 

attachicon.gifHACCP Example Mr I.png

 

CCP?

CODEX also adds: More than one control measure may be required to control a specific hazard(s) and more than one hazard may be controlled by a specified control measure.
If your HACCP Team determine this is not a CCP? then you may decide it is controlled adequately by a combination of your PRPs (Allergen management, labeling, intended use) and sieving/sorting but this should be reflected in your hazard assessment notes and appropriate procedures/measures taken to ensure these controls are in place.

 

Regards,

 

Tony

 

Sorry Tony I missed your question.  I took the AIB advanced HACCP course which goes over the basics of HACCP and Hazard Analysis and then take that forward into an auditing perspective where your team goes through a very horrible company HACCP plan where you try to find all of the mistakes.  So it's not technically an auditing course but it does have an auditing component to it.

 

I know that you can, and often do have multiple ways to mitigate the risk of a hazard, but on it's face I want the hazard analysis to look right.  I never really looked deeply into our hazard analysis... but now that I have I see a lot of metal risks at 5 and 5 being not likely to happen in the industry and the severity is 5.... not good.  Honestly if your rating something that it has never happened in the industry it shouldn't even be on your hazard analysis imho...  But that's not what I was really interested in for this thread.

 

I want to know that when an auditor reads through my HA it's right.  We passed FSSC so it can't be that horrible... I just think the way we are doing it is wrong.


  • 0
____________________________________________________________________________________________________

Mr. Incognito


:tardis:

Mr. Incognito is a cool frood who can travel the width and breadth of the galaxy and still know where his towel is.

#17 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,460 posts
  • 3246 thanks
347
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 26 August 2014 - 02:58 PM

Dear Mr.Inc.

 

So... that being said.  You should be rating the likelihood and severity of the identified hazard on it's merit alone and not adjusted for already instituted control measures or PRPs...

 

i stick to my "cumulative" in the quoted context of words like "consequences", "exposure" and  "public health hazard"  (However, the opinion 20 yrs ago might have differed, = Evolution :smile: )

 

Refer to appendix F. Consider queries like Q2 and Q4.

A tricky point is the choice of reference location for determining the CCP (and RA) evaluation.

 

One possible scenario is where there is a likely (high severity) pathogen in a raw material which will not necessarily be removed in the process to a raw final product. An interesting RA issue occurs when the latter product is ultimately commercialised as NRTE, ie must be fully cooked by consumer.

 

The USFDA (seafood) did considerable "mulling" over the appropriate presentation of the hazard analysis for  "receiving  raw material" in such a case. They decided that the likelihood of a hazard at the point of consumption could be considered not significant (ie trusted labelling/consumer). There are clearly some (inestimable?) assumptions involved, ie subjective. (One obvious factor was the age of consumer which re-appears in metal contamination rules. ) IIRC, one can find similar assumptions  within the haccp portion of ISO22000.

 

However alternative analyses to above can undoubtedly be found in the literature. Such is HACCP, and RA. For example in the quoted segment -

However, there may be differences of opinion, even among experts, as to the likely occurrence and severity of a hazard

(Nowadays the above first step is often categorized as a PRP, further simplifying the conclusion :smile: ).

 

I can supply some links to above issues if you are interested. The whole topic of RA for food (and other hazards) is full of subjectivities, some probably more debatable than others. After all, you haven't reached the topic of risk matrix yet. :smile:

 

Rgds / Charles.C

 

PS - I think you will find that many (most) auditors are blissfully unaware of subtleties such as the above. They have a certain expectation for the RA/CCP results for a given process. An approximate, validated match is their primary objective.


  • 0

Kind Regards,

 

Charles.C


#18 Mr. Incognito

Mr. Incognito

    "Mostly Harmless"

  • IFSQN Fellow
  • 1,552 posts
  • 258 thanks
121
Excellent

  • Earth
    Earth
  • Gender:Male

Posted 27 August 2014 - 12:13 PM

Well we run into the NRTE situation with salmonella risk in wheat/flour wherein it is expected that wheat could have it from birds (etc) in the fields.  We bring it in and mill it but we don't cook the flour or wheat so there is no way to mitigate the risk... but we communicate that the flour is not a RTE product and must be cooked properly.

 

Send whatever links you think are appropriate.  I found these in the FDA site your provided and the other in CODEX:

 

http://www.fda.gov/F.../ucm2006801.htm

 

After the list of potential hazards is assembled, stage two, the hazard evaluation, is conducted. In stage two of the hazard analysis, the HACCP team decides which potential hazards must be addressed in the HACCP plan. During this stage, each potential hazard is evaluated based on the severity of the potential hazard and its likely occurrence. Severity is the seriousness of the consequences of exposure to the hazard. Considerations of severity (e.g., impact of sequelae, and magnitude and duration of illness or injury) can be helpful in understanding the public health impact of the hazard. Consideration of the likely occurrence is usually based upon a combination of experience, epidemiological data, and information in the technical literature. When conducting the hazard evaluation, it is helpful to consider the likelihood of exposure and severity of the potential consequences if the hazard is not properly controlled. In addition, consideration should be given to the effects of short term as well as long term exposure to the potential hazard. Such considerations do not include common dietary choices which lie outside of HACCP. During the evaluation of each potential hazard, the food, its method of preparation, transportation, storage and persons likely to consume the product should be considered to determine how each of these factors may influence the likely occurrence and severity of the hazard being controlled. The team must consider the influence of likely procedures for food preparation and storage and whether the intended consumers are susceptible to a potential hazard. However, there may be differences of opinion, even among experts, as to the likely occurrence and severity of a hazard. The HACCP team may have to rely upon the opinion of experts who assist in the development of the HACCP plan.

 

 

CODEX:

 

6. List all potential hazards associated with each step, conduct a hazard analysis, and consider any measures to control identified hazards

(SEE PRINCIPLE 1)

The HACCP team (see “assemble HACCP team” above) should list all of the hazards that may be reasonably expected to occur at each step according to the scope from primary production, processing, manufacture, and distribution until the point of consumption.

The HACCP team (see “assemble HACCP team”) should next conduct a hazard analysis to identify for the HACCP plan, which hazards are of such a nature that their elimination or reduction to acceptable levels is essential to the production of a safe food.

In conducting the hazard analysis, wherever possible the following should be included:

• the likely occurrence of hazards and severity of their adverse health effects;

• the qualitative and/or quantitative evaluation of the presence of hazards;

CAC/RCP 1-1969, Rev. 4-2003 - Annex Page 26

 

survival or multiplication of micro-organisms of concern;

• production or persistence in foods of toxins, chemicals or physical agents; and,

• conditions leading to the above.

Consideration should be given to what control measures, if any exist, can be applied to each hazard.

More than one control measure may be required to control a specific hazard(s) and more than one hazard may be controlled by a specified control measure.


  • 0
____________________________________________________________________________________________________

Mr. Incognito


:tardis:

Mr. Incognito is a cool frood who can travel the width and breadth of the galaxy and still know where his towel is.

#19 Tony-C

Tony-C

    Grade - FIFSQN

  • IFSQN Fellow
  • 2,958 posts
  • 791 thanks
167
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Location:Koh Samui
  • Interests:My main interests are sports particularly football, pool, scuba diving, skiing and ten pin bowling.

Posted 27 August 2014 - 12:28 PM

Well we run into the NRTE situation with salmonella risk in wheat/flour wherein it is expected that wheat could have it from birds (etc) in the fields.  We bring it in and mill it but we don't cook the flour or wheat so there is no way to mitigate the risk... but we communicate that the flour is not a RTE product and must be cooked properly.

 

Send whatever links you think are appropriate.  I found these in the FDA site your provided and the other in CODEX:

 

CODEX:

 

6. List all potential hazards associated with each step, conduct a hazard analysis, and consider any measures to control identified hazards

(SEE PRINCIPLE 1)

The HACCP team (see “assemble HACCP team” above) should list all of the hazards that may be reasonably expected to occur at each step according to the scope from primary production, processing, manufacture, and distribution until the point of consumption.

The HACCP team (see “assemble HACCP team”) should next conduct a hazard analysis to identify for the HACCP plan, which hazards are of such a nature that their elimination or reduction to acceptable levels is essential to the production of a safe food.

In conducting the hazard analysis, wherever possible the following should be included:

• the likely occurrence of hazards and severity of their adverse health effects;

• the qualitative and/or quantitative evaluation of the presence of hazards;

CAC/RCP 1-1969, Rev. 4-2003 - Annex Page 26

 

survival or multiplication of micro-organisms of concern;

• production or persistence in foods of toxins, chemicals or physical agents; and,

• conditions leading to the above.

Consideration should be given to what control measures, if any exist, can be applied to each hazard.

More than one control measure may be required to control a specific hazard(s) and more than one hazard may be controlled by a specified control measure.

 

:doh: As mentioned previously in this forum in my post which you replied to and quoted in post 16 ;)

 

http://www.ifsqn.com...ion/#entry77089


Edited by Tony-C, 27 August 2014 - 12:28 PM.

  • 0

#20 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,460 posts
  • 3246 thanks
347
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 27 August 2014 - 03:55 PM

Dear Mr.Inc.,

 

Send whatever links you think are appropriate.  I found these in the FDA site your provided and the other in CODEX:

 

It’s probably easier  to use the ISO22000 family as a (modern) haccp reference since I presume you are (only too)  familiar with this.

 

The I2k presentation of basic hazard analysis, eg in sections 7.4.1 –  (mostly) 7.4.4 is  IMO excellent and, I think, concurs with  my previously stated suggestions regarding risk/hazard  assessment. For myself, the “mess” in the Standard starts with the OPRP portion but that is another issue.

 

I admire your determination to pinpoint a precise correct/incorrrect methodology for hazard/risk assessment/CCP specification but the multiplicity of (validatable) opinions within this topic may preclude achieving such an objective.

 

Rgds / Charles.C


  • 0

Kind Regards,

 

Charles.C


#21 Mr. Incognito

Mr. Incognito

    "Mostly Harmless"

  • IFSQN Fellow
  • 1,552 posts
  • 258 thanks
121
Excellent

  • Earth
    Earth
  • Gender:Male

Posted 27 August 2014 - 05:10 PM

I agree... some things are not exact.  However if I can show how FDA/CODEX says to do something and everyone agrees I can't be wrong :shades:

 

I want to hurt whoever came up with oPRPs... but that's neither here nor there...

 

I'll reread 22k's section but I don't remember it being very descriptive on this.


  • 0
____________________________________________________________________________________________________

Mr. Incognito


:tardis:

Mr. Incognito is a cool frood who can travel the width and breadth of the galaxy and still know where his towel is.

#22 CMHeywood

CMHeywood

    Grade - SIFSQN

  • IFSQN Senior
  • 318 posts
  • 78 thanks
15
Good

  • United States
    United States
  • Gender:Male
  • Location:Neenah, Wisconsin

Posted 08 September 2014 - 05:00 PM

Severity = how bad would it be?  What's the worse that can happen?  So I agree, the severity of an allergen should be the highest score.

Likelihood (Frequency) = how often would it occur?  If you have controls in place, this would likely be a low score if you have good controls.

I work at a plant that makes film packaging.  We multiply the Severity Score (1-5 highest) by the Frequency Score (1-5 highest).  This is the Risk Score which determines how much control is needed.

  • 0





0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users