13 replies to this topic

[She_Tap]

Hi everyone:

Please let me take your experience with a query: In the company where I work we have as input many ingredients and as you know in some cases these will have to undergo a hazard analysis, sometime I hear there are specific decision tree for ingredients , Could you help me? confirm whether this is true and giving me some reference.

Thank you very much in advance for your attention.

Atte.

ST

[Charles.C]

Hi Sheila,

 

Thks yr query and welcome to the Forum ! 

(You may be the first member from Bolivia )

 

Can you clarify a little regarding -

 

Any particular FS Standard involved, eg BRC, FSSC22000 ?

What kind of ingredients ?

What kind of finished product, eg RTE ?

 

The precise haccp handling of inputs to a manufacturing process can depend on various factors, eg -

 

(1) If the ingredient is classified as "Food Grade" via, for example, compliance to a specification there should be no significant BCP hazards except perhaps for allergens.

 

(2) In other cases (simple) decision trees do exist and have been posted on this forum - typically the ingredients are queried as to whether any potential hazards are present, ( intrinsic or due to contamination, eg environment), and whether such hazards will be removed during the process / including consumer usage. If yes, the hazard is clearly not significant, if no the risk due to the hazard needs to be assessed for its significance. A significant hazard will likely lead to a CCP (somewhere) in a traditional hazard analysis.

 

(3)  some FS standards regard/define the haccp control of input (hazards) as a PRP function.

[Charles.C]

addendum to previous post -

 

some examples of raw material decision trees (there are many others on the forum) are  -

 

http://www.ifsqn.com...nts/#entry38494
(word doc. ref. no longer accessible on the IT)
(excel is based on diagram in - Practical HACCP, Mortimore)

 

 ilsi raw material tree2.pdf   45.49KB   260 downloads

(ex ilsi attachment  in this link -

http://www.ifsqn.com...indpost&p=68853

 

http://www.ifsqn.com...ge-2#entry46754
(oprp oriented, ref.unavailable)

[She_Tap]

Dear Charles,

 

Thanks for the welcome and for your kind attention. Clarify the requested items:

 

(Good thing !!! I joined the forum, for me is a learning experience)

 

We are working under the FSSC 22000 scheme, working in a dairy plant and specifically the ice cream line, where we have coverage of chocolate, biscuits based on flour and prepared jams.

 

Point (1) I helped me a lot and it is true that handle technical specifications for each of the ingredients and materials that make up the finished product, but was not sure that would be enough.

 

Through the point (2) understand that if it meets the technical specification need not submitting to decision trees, should only contemplate the possible sources of pollution under my responsibility in the storage and handling within plant.

 

The point (3) it takes me a while but I will study for understand. 

 

You are the best, thank you very much.

 

Cordial greetings to you from South America.

 

Atte.

ST

[Charles.C]

Hi Sheila,

 

Thks yr reply,

 

In fact, point 3 is important for you since  fssc22000 is specifically included in this clause (with potential overlaps to point 1 and 2.)

fssc requirements involve PRPs complying to the iso22002-1 standard. Section 9 of the iso22002-1 standard covers purchasing/receiving raw materials.

 

you may find the excel sheet / model hazard analysis of yoghurt as per fssc22000 in the post linked below (and the surrounding thread) interesting -

 

http://www.ifsqn.com...ge-7#entry50651

 

note -

 

(a)  "PAS220" is now re-issued as iso22002-1

(b) the first CCP would probably be more correctly handled as a PRP from fssc's POV ( I never had time to revise the sheet )

(c) there are many alternative procedures for distinguishing oprp/ccp which are equally auditorially accepted. It is a highly subjective topic.

 

PS - I should have noted in Post 2 that, for traditional hazard analyses, using decision trees for ingredients is an optional tool for performing a risk assessment but may visually help to explain the logic of the risk assessment. Some people use a "full" Codex decision tree (4 Question format) at every step of the Process hazard analysis although this is somewhat contrary to the Codex/NACMCF original guidelines. Auditors tend to be flexible over the particular method used as long as it appears to be a "logical" risk assessment.

 

But, for fssc22000,  iso22002-1 is mandated (due GFSI requirements) to be used for  specifying  PRP functions via its detailed menu. This is not the case for iso22000 where the minimal choice of PRP functions is given in sec.7.2.3 of the iso22000 standard (although iso22002-1 could be used if so desired).

[Johnson Opoku-Boateng]

Hello Charles,

 

If the ILSI raw material decision tree above is applied, and you answer a 'NO' for Q2, you have a CCP on your hands for that ingredient. What then becomes your control measure and how do you justify your choice of control measure to anyone?

 

Anyone could help  with an answer please.

 

Thanks

 

Johnson

[Charles.C]

Hello Charles,

 

If the ILSI raw material decision tree above is applied, and you answer a 'NO' for Q2, you have a CCP on your hands for that ingredient. What then becomes your control measure and how do you justify your choice of control measure to anyone?

 

Anyone could help  with an answer please.

 

Thanks

 

Johnson

 

Hi Johnson,

 

In fact the ILSI tree is relatively old and current (traditional) haccp technique is perhaps more often aligned to the tree shown in the excel example noted/linked in Post3

 

The details may depend on aspects such as the Standard / Product / Process / Hazard but many current haccp presentations now (as far as possible) tend to "avoid" setting CCPs at the raw material reception step, eg via use of PRPs. i suggest you read the relevant section in Mortimore's standard haccp text (3rd ed. 2013).

 

Just as an example, if the raw material contains intrinsic allergens which are normally not process removable, one option is to use a control measure of  "labelling" so that this later stage could be a CCP. Alternative haccp viewpoints might include "labelling" within an overall "allergen control program" and thereby categorise the latter "program" as a PRP.

 

The distinctions between PRPs and CCPs have become more blurred in modern HACCP. (ISO-HACCP has also added OPRPs into the mixture).

[Johnson Opoku-Boateng]

Thanks Charles,

 

Kindly send me the link to Mortimore's standard HACCP text as suggested in your response.

Once done, I will revert with further insights and probable inquiries on the subject matter.

 

Do you in principle tend to agree that, a decision tree should be applied in the case of raw materials?

At what point do you agree the intrinsic hazard should be resolved through an approved supplier?

 

Thanks

[Charles.C]

Thanks Charles,

 

Kindly send me the link to Mortimore's standard HACCP text as suggested in your response.

Sorry but it's a coprighted Book. Can find it as "Google Book" - "Practical haccp".

Once done, I will revert with further insights and probable inquiries on the subject matter.

 

Do you in principle tend to agree that, a decision tree should be applied in the case of raw materials?

I find the excel referred useful but some situations can require a lot of "thought". Risk assessment can be a subjective issue.

 

At what point do you agree the intrinsic hazard should be resolved through an approved supplier?

Please give a specific example.

 

Thanks

 

Hi Johnson,

 

Hope the above is helpful.

[Johnson Opoku-Boateng]

Hi Johnson,

 

Hope the above is helpful.

Thanks Charles,

 

I will try and purchase this book online.

 

I will give two ingredients as examples;

 

1. Palm oil for inclusion in a margarine formulation. Possible physical hazards could be stones, and palm kernel shells and chemical hazards from pesticides

2. inks for printing on food packaging. Possible chemical hazards from ink composition and migration.

 

You may include other hazards in your response to clarify the solution.

 

Thanks

 

Johnson

[Charles.C]

Thanks Charles,

 

I will try and purchase this book online.

 

I will give two ingredients as examples;

 

1. Palm oil for inclusion in a margarine formulation. Possible physical hazards could be stones, and palm kernel shells and chemical hazards from pesticides

2. inks for printing on food packaging. Possible chemical hazards from ink composition and migration.

 

You may include other hazards in your response to clarify the solution.

 

Thanks

 

Johnson

 

Hi Johnson,

 

TBH, I'm not entirely sure as to any general link between a raw material's intrinsic hazards and an approved supplier other than via the Product Specification.

 

Using approved suppliers is a typical Prerequisite requirement for haccp.

 

I assume the examples are querying  whether, for the inputs/processes mentioned, the hazards referred could generate a CCP at the raw material receiving step.

 

The specific processes are unknown but I anticipate that any hazard from stones/shell  would be removed in the process.

 

Chemical hazards/migration potential  will presumably not be changed by the process..

 

A typical haccp scheme initially defines the group of PRP programs

 

This activity includes setting up Product Specifications to be mutually agreed for all inputs between buyer/seller..

 

IMO, for the process uncontrolled hazards above, these are in principle controllable by the Supplier in order to meet Product Specifications.

 

Accordingly, all the hazards mentioned are either controllable within the process or via (Supplier) PRPs (plus, for example, COAs/sampling/analysis/etc)

 

As you can see, there is often no single, globally applicable, solution. This is also obvious by comparing published haccp plans. Diversity is ubiquitous.

[Johnson Opoku-Boateng]

Hi Johnson,

 

TBH, I'm not entirely sure as to any general link between a raw material's intrinsic hazards and an approved supplier other than via the Product Specification.

 

Using approved suppliers is a typical Prerequisite requirement for haccp.

 

I assume the examples are querying  whether, for the inputs/processes mentioned, the hazards referred could generate a CCP at the raw material receiving step.

 

The specific processes are unknown but I anticipate that any hazard from stones/shell  would be removed in the process.

 

Chemical hazards/migration potential  will presumably not be changed by the process..

 

A typical haccp scheme initially defines the group of PRP programs

 

This activity includes setting up Product Specifications to be mutually agreed for all inputs between buyer/seller..

 

IMO, for the process uncontrolled hazards above, these are in principle controllable by the Supplier in order to meet Product Specifications.

 

Accordingly, all the hazards mentioned are either controllable within the process or via (Supplier) PRPs (plus, for example, COAs/sampling/analysis/etc)

 

As you can see, there is often no single, globally applicable, solution. This is also obvious by comparing published haccp plans. Diversity is ubiquitous.

Hello Charles,

 

I appreciate your responses so far. Thanks 

 

Johnson

[Charles.C]

Hello Charles,

 

I appreciate your responses so far. Thanks 

 

Johnson

 

Hi Johnson,

 

You're very welcome. Members from Ghana are quite rare here.

 

Not sure as to yr HACCP background. If substantial you will already well know the files below, if otherwise = recommended reading.

 

 Codex food hygiene 2009 4th ed..pdf   632.54KB   71 downloads

 NACMCF HACCP Guidelines,1998.pdf   1.17MB   64 downloads

[Charles.C]

addendum

 

Just noticed yr other post so apologies/ i appreciate that you are "HACCP familiar".

http://www.ifsqn.com...e-2#entry112178

 

I also note that there is some "relationship" between the post in this thread and the above link.

 

Personally, I have never, ever, used the Codex Decision Tree. IMO it can be a valuable tool but its "convenience" can also promote a disregard for understanding the basics of Risk Assessment/hazard analysis.

 

Just as a side-comment to yr other post, BRC Food tend to (initially) separate the Risk Status of Input Materials from that of Approved Suppliers. This is only one approach of course, it's another highly subjective topic.

 

FSMA/FDA are currently struggling with anothe part of a related puzzle, generating a meaningful compilation of, so-called, High Risk Foods.