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In hazard assessment are control measures only preventive?


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#1 Mohan@

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Posted 25 April 2017 - 10:43 AM

HI

IN HAZARD ASSESSMENT, ARE CONTROL MEASURES SHALL BE ONLY PREVETIVE??

 

OR

 

HAVE TO CONSIDER BOTH PREVENTIVE AND CORRECTIVE?

 

EX: STEP: CHLORINATION OF WATER 

        HAZARD: CHEMICAL - CHLORINE

 

CONTROL MEASURES: 1. APPROVED NaOCl FROM VENDOR

                                          2. WE HAVE FURTHER STEP CALLED ACF (ACTIVATED CARBON TREATMENT) TO REDUCE CHLORINE

 


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#2 FurFarmandFork

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Posted 25 April 2017 - 03:39 PM

Sometimes, and it depends!

 

Your hazard analysis needs to evaluate the risk of something happening, which will take into account what controls you have that are preventative. Your HACCP plan that comes out of the hazard analysis needs to include corrective actions if these controls are likely to fail.

 

If this is a PRP as opposed to a CCP, they may all be kept together. If you're looking for compliance with the preventative controls rule...come up with something and I wish you luck. The important thing is that you have assessed that a hazard exists and have a plan to both control it and deal with it. The rest is just paperwork. :)


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#3 Charles.C

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Posted 26 April 2017 - 02:03 AM

HI

IN HAZARD ASSESSMENT, ARE CONTROL MEASURES SHALL BE ONLY PREVETIVE??

 

OR

 

HAVE TO CONSIDER BOTH PREVENTIVE AND CORRECTIVE?

 

EX: STEP: CHLORINATION OF WATER 

        HAZARD: CHEMICAL - CHLORINE

 

CONTROL MEASURES: 1. APPROVED NaOCl FROM VENDOR

                                          2. WE HAVE FURTHER STEP CALLED ACF (ACTIVATED CARBON TREATMENT) TO REDUCE CHLORINE

 

Hi Mohan,

 

Yr query overlaps Semantics/Philosophy/Operations, or as per the previous Post "it depends". :smile:

 

Yr "ex.step" suggests you may be confused over the meaning of "hazard" in a HACCP context. (the target hazard is micro.pathogens).

 

I assume you are focussing on non-FSMA  HACCP.

 

"Control Measure / Corrective Action" have specific definitions in HACCP. Control Measures in HACCP are typically "pre-CCP" (ie relate to the hazard analysis). Corrective Actions are typically "post-CCP"(ie relate to monitoring/deviations at the CCP). "Preventive Measures"  typically refer to the former category (eg see PS below).

 

Here is a detailed presentation of the meaning and  scope of "Control Measures" (note no mention of "Preventive") in HACCP -

 

Attached File  control measures in haccp.pdf   1.22MB   13 downloads

 

As interpreted above, the answers to yr OP questions are YES / NO.

 

Here is a non-haccp presentation of related terminologies -

 

https://oshwiki.eu/w...rchy_of_prevention_and_control_measures

 

PS - FDA(1997) define Preventive Measure as - an action to exclude, destroy, eliminate, or reduce a hazard and prevent recontamination through effective means.
 

(a) Purposes

   The hazard analysis process accomplishes three purposes:

   (i) Hazards of significance are identified;

   (ii) The hazard analysis provides a risk basis for selecting likely hazards;

   (iii) Identified hazards can be used to develop preventive measures for a process or product to ensure or improve food safety.

 

https://www.fda.gov/...e/ucm054672.htm

 

(also see the CCP decision tree in above link)


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Kind Regards,

 

Charles.C





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