5 replies to this topic

[dj.E]

Hi our company is currently reviewing our HACCP plans for marinated meats. However during our review for hazard analysis, our R&D declared they cannot declare the ingredients used in 3 of our premixes used to make our marinades. They can only provide us certificates of compliance or letter of guarantee.

 

For some time we accepted these but when we attended an orientation on the basics of ISO 22000, it is a requirement to have the ingredients declared and go through hazard analysis. The company eventually plans to undergo certification.

 

I was wondering how are we going to go about this given that as of now our R&D wishes not to disclose the ingredients for the premixes.

By the way, our R&D supplies the premixes to us.

 

Has anyone encountered the same dilemma? I would really really appreciate if you could share how we can resolve this issue?

thanks.   

 

 

[Charles.C]

Hi our company is currently reviewing our HACCP plans for marinated meats. However during our review for hazard analysis, our R&D declared they cannot declare the ingredients used in 3 of our premixes used to make our marinades. They can only provide us certificates of compliance or letter of guarantee.

 

For some time we accepted these but when we attended an orientation on the basics of ISO 22000, it is a requirement to have the ingredients declared and go through hazard analysis. The company eventually plans to undergo certification.

 

I was wondering how are we going to go about this given that as of now our R&D wishes not to disclose the ingredients for the premixes.

By the way, our R&D supplies the premixes to us.

 

Has anyone encountered the same dilemma? I would really really appreciate if you could share how we can resolve this issue?

thanks.   

 

hi dj.e,

 

I'm unclear how you could have a meaningful, auditable, COC without its specifying what it refers to.

 

It is impossible to perform/document a hazard analysis on an ingredient without knowing what it is.

 

A decision for Top Management will be required as to the necessity for pursuing iso22000 certification or not.

[dj.E]

hi dj.e,

 

I'm unclear how you could have a meaningful, auditable, COC without its specifying what it refers to.

 

It is impossible to perform/document a hazard analysis on an ingredient without knowing what it is.

 

A decision for Top Management will be required as to the necessity for pursuing iso22000 certification or not.

 

 

Thanks Charles.C

 

Auditing is also another concern for us. How will we be able to conduct complete audit/validate our system if we are restricted on that part of our operation. I will definitely communicate this to the Top Management. Thanks again.

 

Another approach R&D suggests is that they will be doing a separate hazard analysis and documentation that they will provide to auditors so it is available during audit.

They will be the one to explain to the auditor.

[Charles.C]

Thanks Charles.C

 

Auditing is also another concern for us. How will we be able to conduct complete audit/validate our system if we are restricted on that part of our operation. I will definitely communicate this to the Top Management. Thanks again.

 

Another approach R&D suggests is that they will be doing a separate hazard analysis and documentation that they will provide to auditors so it is available during audit.

They will be the one to explain to the auditor.

 

Should be interesting for Top management to explain the reason for having 2 independent haccp teams / 2 independent haccp plans.

 

I suppose  Coca-Cola must have found an acceptable solution.

[QAGB]

Should be interesting for Top management to explain the reason for having 2 independent haccp teams / 2 independent haccp plans.

 

I suppose  Coca-Cola must have found an acceptable solution.

 

 

Charles: I've always wondered how Coca-Cola handles QA. They must have several QA departments with little to no comingling so information doesn't get inadvertently shared.

 

 

Dj.E: We have a couple of items that are considered trade secrets by customers. We know what these items are, but we give them a name as you are doing with "premix". In this scenario, we would list "premix" in the flow diagram and in the process analysis, and include all hazards for the premix itself.

 

As part of your ingredient hazard analysis, I don't know exactly why each ingredient can't be listed. You should be able to list all of your ingredients in your facility to maintain a good assessment. We do list out the ingredients for our "premixes" in the ingredient hazard analysis; we just don't share what those ingredients relate to in finished product. You can still maintain confidentiality without compromising the HACCP plan.

 

I suppose the separate HACCP plans or separate hazard analyses done between your department and R&D will work, but be sure to include R&D on the Food Safety/HACCP team and include them in meetings and training for HACCP.

 

 

QAGB

 

QAGB

[swanswal]

Seems to me that perhaps your R&D is just continuing to act and behave in traditional ways.  As your company evolves and seeks to gain certification etc., the company will need to make certain adjustments to suit the changing environment it finds itself in.

 

In this case, if the Company seeks certification, then R&D need to be brought along on the journey so that they understand the need for disclosure.  My experience is that once all parties understand the requirements to move forward, the necessary changes occur.

 

Regards