26 replies to this topic

[ajahmoh]

Hi all,

 

 

I need to ask your expertise regarding implementation of ISO 22000. Is it necessary to have a hazard analysis on utilities like air, water, drainage and the like? It is the first time i heard about it. I have attached a reference document from our consultant on how to do it. but i find it odd and not mandatory on the implementation of ISO 22000.

 

 

Looking forward to anyone's help.

 

 

Regards,

 

Adrian

[Watanka]

Adrian,

 

Each item you mentioned should be evaluated in terms of their potential impact to your product's safety and quality.  For example, if you use compressed air to stir tanks of liquids the air has to be exceptionally clean or it will lead to contamination issues.  If you use water as an ingredient or processing aid you have to make sure it is potable, meets all legislative standards for purity and that any treatment you give it does not adversely effect its quality.  Drainage is important to analyze because you want to make sure waste water, sewage and so on does not contaminate your clean water supply.  Back flow inspections should occur at least annually and be performed and documented by a firm licensed or recognized by your local water district. 

 

Without knowing much more about your business and facility environment it is difficult to offer up much more than generalities. 

[carine]

Adrian, 

 

Hazard analysis for compressor air is mandatory in comply with ISO/TS22002-1. 

[ajahmoh]

Hi,

 

Isn't it ISO/TS22002-1 is mandatory if you are acquiring an FSSC Certificate?

[Charles.C]

Hi all,

 

 

I need to ask your expertise regarding implementation of ISO 22000. Is it necessary to have a hazard analysis on utilities like air, water, drainage and the like? It is the first time i heard about it. I have attached a reference document from our consultant on how to do it. but i find it odd and not mandatory on the implementation of ISO 22000.

Looking forward to anyone's help.

Regards,

Adrian

 

 

Hi Adrian,

 

i do not see any attachment ?

[ajahmoh]

Hi Charles,

 

 

Sorry, Here's the attachment.

 

Additionally,as per our consultant Utilities, e.g. water (drinking, cleaning, production or used in jacketed pipelines), AC’s steam etc., having direct contact or may come in contact with food, in this case Flow chart, hazard analysis & HACCP plan shall be prepared.

 

Are these necessary?

 

 

 

Regards,

 

Adrian

Attached Files

•  Air Hazard analyses1.xls   40KB   273 downloads

[Charles.C]

Hi Charles,

 

 

Sorry, Here's the attachment.

 

Additionally,as per our consultant Utilities, e.g. water (drinking, cleaning, production or used in jacketed pipelines), AC’s steam etc., having direct contact or may come in contact with food, in this case Flow chart, hazard analysis & HACCP plan shall be prepared.

 

Are these necessary?

 

 

 

Regards,

 

Adrian

 

Hi Adrian,

 

Afaik, in the context of iso22000, utilities are handled within sec.7.2 et seq. So basically as PRPs.

[ajahmoh]

Dear Charles,

 

Thank you for your feed back..

 

 

Here's what i did before the consultants introduced a hazard analysis for our utilities. (which i find unnecessary and potentially questioned during an audit)

 

I have attached part of the Hazard Analysis I have drafted you will see under "panning step in which it uses air from air conditioner to cool/solidify chocolates" , you can zoom in for better vision of the screenshot.

 

You can read under " Hazard Justification and/or cause"  Identified Hazard justification and/or cause are:

B- contamination from poor personnel hygiene, improper cleaning and contaminated water used in cleaning machine, equipment, tools and utensils, Dust from air conditioner used to dry/solidify chocolate, Salmonella infected personnel and fallen hair of personnel.

C - Cross-contamination and improper cleaning .Excess chemicals effect cannot be seen at present time but may develop in the future. Allergens are naturally present in food which reacts to people with weak threshold on some food substance. Couvertures and Fillings used contain allergen.

P- May cause customer disgust, broken tooth and choking when consumed. Contamination from Air used to dry/solidify chocolate , Ineffective Pest Control and Fallen hair of personnel. Metal Shards from the collision of metal (wear and tear) during preparation of couverture and filling.

 

Risk Analysis, Decision Tree and Control Measures are also mentioned. (Please refer to the PRP Utilities i have attached)

 

 

Will this be enough to satisfy the auditor or will be enough to satisfy That we are controlling whatever it is present in the utilities which may reasonably contaminate our products?

 

 

Regards,

 

Adrian

 

Attached Files

•  Hazard Analysis.png   426.47KB   4 downloads
•  Doc. FSMS-PRP-003 Pre- Requisite Program- Utilities rev 00.docx   85.77KB   152 downloads

[Nofish]

Hi Adrian 

 

some small points on the  reference document from our consultant..  

The use HACCP method - gives/states ...  3 x CCP  on a air supply ... 

Control measure :preventive maintenance -  every day /week / year ? 

 

 

And the hazard analysis dont conclude on  any  chemical hazard ,  please check that you are operating with "oil free " compressors..

 

If you are operating with oil lubricated compressor ( most common :-( ) , the filter systems and oil trap in the compressor machines( our #1) reduces the  chemical hazard of 

lubricating oil / hydrocarbon in the compressed air. So in many cases our step #1 preventive maintenance might reduce  a hazard 

  ... in  our # 3#4 & #6#7 the step reduces water/ moisture and oil vapors . 

 

 

 

 BR

nofish

[ajahmoh]

Dear Nofish,

 

Thank you for the additional points to consider.

 

Can you send me a reference on how you did yours?

 

 

Regards,

 

Adrian

[Charles.C]

Hi ajahmoh,

 

Regret I have little idea what “panning” is but seems near the end of process. I assume there are no “BC” hazard elimination stages after panning.

 

Although iso22002 not mandatory for iso22000, I daresay an auditor may evaluate the expectations of a PRP for  “utilities” as per iso22002-1, eg section 6 (similar Post3). For the present case (and especially assuming steps as above) IMO this would likely require evidence that the quality of the air precludes any significant contamination risk (cf sec 6.4). Typical requirements for quality exist and have been discussed here previously in considerable detail.

[ajahmoh]

Panning Process is when you put solid food to be coated with chocolate. one good example is maltesers.

 

Considering that the auditor will raise a question about it, although non-mandatory to ISO 22000. Will the current practice described in #8 of this topic enough to say that we do not contaminate the product? Evidence we are to show is micro test (APC) and Suspended Particulate?  To prove that products are not contaminated with micro and dirt? Additionally, it can be supported by the conformance of End Products to micro standards set by the Kingdom of Saudi Arabia and historical data of customer complaints?

 

 

After all, despite the provision of Hazard Analysis in Utilities auditor will still ask for an evidence that the control measure in this case (preventive maintenance, cleaning and filters installation) in water supply, AC and the like are effective.

 

 

Regards,

 

Adrian

[ajahmoh]

panning machine rotates to coat solid food with chocolate. the machine is similar to a pan used in construction, but in this case it has an air blower to dry/solidify the chocolate.

[carine]

Hi Ajahmoh, 

 

We have used air compressor to blow plastic film before product filling. we know there is a min chances of oil will introducing into our product, nevertheless we use Food Grade Oil to solve our problem. 

[Charles.C]

Panning Process is when you put solid food to be coated with chocolate. one good example is maltesers.

 

Considering that the auditor will raise a question about it, although non-mandatory to ISO 22000. Will the current practice described in #8 of this topic enough to say that we do not contaminate the product? Evidence we are to show is micro test (APC) and Suspended Particulate?  To prove that products are not contaminated with micro and dirt? Additionally, it can be supported by the conformance of End Products to micro standards set by the Kingdom of Saudi Arabia and historical data of customer complaints?

Maybe not. ISO air quality standards exist, and also BCAS. It's all detailed in older thread (not in front of my usual PC wth links stored).

 

 

After all, despite the provision of Hazard Analysis in Utilities auditor will still ask for an evidence that the control measure in this case (preventive maintenance, cleaning and filters installation) in water supply, AC and the like are effective.

Is this a question or a statement ? if the former, see previous red answer.

 

 

Regards,

 

Adrian

 

Hi Adrian,

 

See above. Post 14 is a good start.

[ajahmoh]

Hi All and Charles,

 

Compressed air is all clear to me.

 

Please see post 6, 7 and 8. The need of Hazard Analysis for AC, Water and the like confuses me.

 

 

Regards,

 

Adrian

[Charles.C]

Hi All and Charles,

 

Compressed air is all clear to me.

 

Please see post 6, 7 and 8. The need of Hazard Analysis for AC, Water and the like confuses me.

 

 

Regards,

 

Adrian

 

Hi Adrian,

 

Note that PRPs are a preliminary to the Codex hazard analysis (and ISO IMO). PRPs do not require a formal "hazard analysis" IMO. hence sec. 7.2

 

Conceptually For Codex haccp, PRPs are mainly system-wide controls, focussed more on hygiene environment of facility, workers eg GHP,  rather than specific process steps. The latter generate the "formal" hazard analysis

 

Currently PRP interpretation has expanded to more overlap the process, eg see iso22002

 

Notably OPRPs (which are somehow PRPs) have muddied the concepts.

 

PS - the advantage of using iso22002 is that this defines (=validates) the PRP's requirements. Occasionally perhaps too well.

[ajahmoh]

Thanks Charles! But i need to clear one thing, In our case that we use water as ingredient, Air from air conditioner and air from the environment recycled/utilized to create a blower which have contact in food do we need a formal "hazard analysis" for water supply and Air conditioner? Regards, Adrian

[ajahmoh]

 

Thanks Charles!But i need to clear one thing, In our case that we use water as ingredient, Air from air conditioner and air from the environment recycled/utilized to create a blower which have contact in food do we need a formal "hazard analysis" for water supply and Air conditioner?Regards,Adrian

 


Basically, this is where the consultants are coming from requiring as to make a hazard analysis for this utilities, IMO we have PRPs why do we need to create a "hazard analysis"?

[Charles.C]

Hi Adrian,

 

i suggest you have a look at the (excel sheet) layout for the fssc22000 model hazard analysis previously done here for yoghurt which I expect you are already aware of (?). This illustrates the way PRPs can be included into the hazard analysis.

 

It's easier to see an example than to explain.

 

Perhaps yr consultants like doing hazard analyses.

 

PS - The hazard analysis layout should be logically defined by steps on yr flowchart.

[ajahmoh]

Dear Charles,

 

Indeed i have considered the example of the yoghurt. Attached is the Hazard Analysis I created and the PFC.

 

As per the screenshot, it is the process in which we use air from air conditioner to dry/solidify chocolate to look like "Maltesers"

 

 

 

I guess our consultants like to create Hazard Analyses.

 

 

But Generally, as per the Hazard Analysis I created, the need for a Hazard Analysis for the (AC) as source of our air which have contact in food is not necessary. or do we need it?

 

PS - I have also attached the PRP that we use to control safety of AC.

 

Regards,

 

Adrian

 

 

 

Attached Files

•  Hazard Analysis.png   426.47KB   2 downloads
•  Doc. FSMS-HACCP-004- Hazard Analysis.xlsx   134.29KB   121 downloads
•  Doc. FSMS-PFC-001 FSMS Process Flow Chart.xlsx   49.1KB   91 downloads
•  Doc. FSMS-PRP-003 Pre- Requisite Program- Utilities rev 00.docx   85.86KB   90 downloads

[Charles.C]

Hi ajahmoh,

 

Thanks for the documents. i assume this is "traditional" haccp, not ISO. I'm unaware of the local regulatory requirements (if any) so comments generic.

 

I had a quick look (there is a lot of material). A few initial comments -

 

(1) (a) The flow chart is insufficiently detailed with a side-effect to the haccp plan, eg receiving/storage raw materials.

      (b) Numbers would enormously assist.

      (c) MD seems in  illogical location. May render the subsequent steps incorrect from a hazard POV.

 

(2) Column R  IMO should be moved "leftwards"

 

(3) column F looks massively "repetitional" (by eye). Just a thought.

 

(4) cell 14C, some of yr "biological hazards" are incorrect, eg plate count

 

(5) metal detection step is strangely described due 1c. subsequent steps thereby debatable for metal.

 

(6) i deduce there is no pathogen kill step in this process. The PRPs are likely going to be very scrutinised since salmonella is a well-known hazard in main raw material plus a lot of added materials.

 

(7) Control measures have no mention regarding Time. This is pathogen relevant and especially due (6). Reason is listing PRPs only can be insufficient.

 

(8) allergen control in finished product seems absent ?.

 

(9) IMO yr PRP document  as shown here is inadequate for the reasons discussed previously. But not due to lack of individual hazard analyses.

 

If i have missed (visually/knowledge) seeing the reasons for any of above, my apologies in advance (chocolate not one of my process-familiar areas ).

 

PS - the hazard analysis as shown is probably 80%+ complete. The PRPs needs more working on/cross-referencing IMO.

But maybe this customer's haccp requirements are less demanding than USA etc ? (or maybe i am over-estimating USA)

[Sean Archer]

Although the discussion appears to be over now, I need to add something at his point to make clear for other members as well.

In the first hazard analysis, 'Air Hazard analyses1.xls' prepared by the consultants, the relationship between a process step and hazard is not correct. Each hazard analysis step should include process step and all the hazards only introduced at that step, not the hazards generated or caused by that step. If you examine very first Excel sheet carefully, you can find that the process steps involved are in fact sources of hazards and they will actually introduce the contaminants at another point in the production system.

 

'Physical contamination with dust' of a Microfilter is not a food safety hazard simply because it is Microfilters task to be contaminated as to protect other players from contamination. Or 'physical contamination with moisture' of a moisture trap is what we are looking for since we want to keep the rest of the compressed air line less moist.

 

On the other hand, the analysis assumed some elements of the production premises as control measure. Clause 3. 'Terms and definitions' of the FSMS define 'control measure' as a ⟨food safety⟩ action or activity that can be used to prevent or eliminate a food safety hazard (3.3) or reduce it to an acceptable level. 'Use of stainless steel tank' to control 'physical contamination with water and rust' of air tank is not a control measure in this regard and should be excluded from hazard analysis.

 

Kind Regards,

Sean

[Charles.C]

Hi Sean,

 

Thks for input.

 

It may be easier to use PRPs.  Avoids discussion over the difference between words like "introduce" and  "generate".

 

From Codex HACCP –

 

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

 

The  HACCP  team  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.

 

[Sean Archer]

Hi Charles,

 

Glad to hear you again.

 

Lets blame it to my bad English   

 

and replace phrases like 'introduce' and 'generate' with a less specific, boring 'occur'.