9 replies to this topic

[Acunio]

Hi All,

 

We are currently re-writing our HACCP plans and in doing so, have found that we need additional CPs and CCPs.

Now, I understand each product group and plan are specific, but I am confused on how I should be numbering my CPs and CCPs.

 

The HACCP plans that have been written previously had a standard numbering system across all plans and the processes were made to mirror the last. CCP1 has always been metal detection for all plans.

In the review we found a plan that needs different CPs and CCPs before metal detection. Rule of thumb should be to number the CPs and CCPs according to where it falls within the process, whether it is the first critical control in your process, second, and so on.

 

Unfortunately, knowing the rule of thumb is not helping me much. Metal detection is still a critical control for all of our HACCP plans and I feel that if we label it as CCP1 in 3 plans and in the forth plan it falls at CCP4 it will be confusing for all team members to grasp. I also feel that we will need to have specific documentation for the specified CCP which will result in us having more than one form for the same critical point.

 

I have thought a lot on how I can make this work to our advantage and have come up with a solution (I am not sure it is good or if it will work) and I am looking for advice, help, and suggestions.

 

I have broken down all processes throughout all plans (very similar processes but very different product groups) and have a list:

• Purchasing
• Receiving / Storage
• Scaling
• Mixing
• Depositing / Forming
• Baking
• Freezing
• Packing (IW)
• Metal Detection
• Case Packing
• Storage
• Shipping

With this process list I came up with a way to make each CP or CCP specific to each plan but have them named the same throughout all the plans. This involved not using numbers. Below is an example in the same flow as the above process steps:

• CP-P / CCP-P
• CP-R / CCP-R
• CP-S / CCP-S
• CP-M / CCP-M
• CP-DF / CCP-DF
• CP-B / CCP - B
• CP-FZ / CCP-FZ
• CP-PK / CCP-PK
• CP-MD / CCP-MD
• CP-CPK / CCP-CPK
• CP-ST / CCP-ST
• CP-SH / CCP-SH

My Plan is to document the reasoning for pre-determined process names at each step even though they currently may not be considered a CP or CCP.

 

Has anyone ever written a program like this, seen a program like this, or am I just 100% incorrect in my thinking?

 

Any help would be appreciated.

 

Thanks,

 

Angela

 

[joshm]

Your new numbering system seems great as long as everyone is aware of the changes made. We recently became SQF certified and one problem we had to overcome was document numbering and we did the same thing with Food and Human safety documents. For example, we may have had a document for a program called "SOP 1" for one aspect but also had an "SOP 1" for the human safety side, so we renamed the human safety document "SOP 1 SAF" for safety. Our auditor liked this.

 

You are on the right track, in my opinion.

[Acunio]

I guess my next question would be, do I have the same amount of flexibility in a HACCP plan as a would with our SOPs?

[Watanka]

Acunio,

 

AS long as your system is compliant with the Codex, well documented and understood by all, you can use the designations for your HACCP plan that make the most sense for your situation.  Personally I try to keep it simple to avoid confusion and over-building the system.  There are many HACCP consultants out there who can help you design your system to your satisfaction, remain compliant and audit ready.  Good luck!

[Acunio]

Watanka,

 

From the description I gave in my first post would you consider that easily understood?

[Watanka]

Acunio,

 

Yes, I understand the designations.  They seem readily apparent.  At the end of the day it is important that your team understand the designations and system you are building.  That will require sufficient documentation and training. 

[Charles.C]

Hi Angela,

 

I presume this is for SQF since Codex has no CPs ( ). Switching to BRC would instantly eliminate yr CP numbering difficulty.

 

Yr product/process is unknown but I have to wonder just how many CCPs you have located. Hopefully not more than 4. And CPs ?

 

I appreciate the objective of dumbing-down the memorisation of which steps are CCPs but frankly it seems like massive overkill to me. IMO, "simple is best".

 

If the haccp team are unable to comprehend the logic of using  1,2,3,4, it does not IMO augur well regarding their coping with topics like hazard analysis.

 

Regardless, it's only my personal opinion and i wish you Good Luck with this system.

[Acunio]

Hi Charles.C,

 

This is for SQF, in all reality a CP is nothing more than a pre-requisite.

 

We produce baked goods and the process is very simple. Currently the majority of the plans have 1 CCP and 2 CP's. Honestly the CP's were put in for SQF.

 

My concern isn't with our HACCP team comprehending it, or understanding 1, 2, 3, 4. That they understand, but the concern is with the each plan being different and the CPs or CCPs for the same points being labeled differently in each plan.

 

Trust me, your opinion is valued as this is the first plan I am writing. I have worked for larger corporations that had their programs written by corporate..  

[Charles.C]

Hi Charles.C,

 

This is for SQF, in all reality a CP is nothing more than a pre-requisite.

 

We produce baked goods and the process is very simple. Currently the majority of the plans have 1 CCP and 2 CP's. Honestly the CP's were put in for SQF.

 

My concern isn't with our HACCP team comprehending it, or understanding 1, 2, 3, 4. That they understand, but the concern is with the each plan being different and the CPs or CCPs for the same points being labeled differently in each plan.

 

Trust me, your opinion is valued as this is the first plan I am writing. I have worked for larger corporations that had their programs written by corporate..  

 

I suggest you have a look at  NACMCF as referenced in the SQF Code. These are 2 different entities (nominally anyway).

 

(Nonethess I accept that it is possible that SQF auditors will disagree with NACMCF, particularly since CP is absent from the SQF Glossary [7.2])

 

i understand you are trying to rationalise the numbering/(assist the auditor). The majority of SQFusers here seem to attempt likewise. I'm not a SQF user and choose  to make the auditor earn their (my) money. Similary with the documentation layout. This has admittedly caused occasional audit friction.

 

I think the vast majority of the haccp plans I have encountered either use no numbering / the named/numbered step in a flowchart / 1.2.3.4 / CCP-A,CCP-B,CCP-C. For me, your format will be unique but perhaps not for SQF auditors.

[Charles.C]

addendum

 

Just as an afterthought, based on earlier SQF threads here, identifying CCPs (and if unavoidable CPs) using colours on the Flowchart is also a popular technique. There are some quite pretty charts showing, from memory, hordes of CPs in some older posts.

 

Actually the SQF Code Glossary implies that use of Codex-terminologies  only should be acceptable (ie no identified CPs) but clause 2.4.3.v clearly thinks otherwise.

(Clause (c) in the [7.2]Code's Intro (part B) should logically be definitive but is obviously, in practice, Not.)[in fact Clause (c) is incompatible with preceding Clause (b) !!]. Such is SQF. Maybe the incongruity has been resolved in SQF8 but I'm not holding my breath.