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2.6.1 - How long should a HACCP Review take?

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Marzena

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Posted 03 May 2017 - 10:08 AM

Hi All,

We've got a non conformance related to timing on annual review of the HACCP plan, in auditors opinion 1.5h hour was not sufficient enough. Any thoughts?

 



GMO

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Posted 03 May 2017 - 10:56 AM

Ooh that's tough!  There is nothing in the standard which says how long a review needs to be so from a pure compliance view, I think this is a bit naughty of the auditor.

 

BUT as a technical person do I think a 90 minute review once a year is enough?  No.  I can't think of any HACCP plan I've ever worked on where the review has been that short and I bet it's not that short for you either because most people have a very rigid interpretation of the word "review".  What I do is turn every HACCP meeting into a review.  In this meeting, we ask all the questions required to be asked by the BRC in your review process, except because HACCP is always changing, we end up proving we actually review our HACCP plans as a minimum 6 times a year (and often much more) so our "review" is therefore a minimum of 6 hours p.a. when actually we've done nothing more than we would do just to keep the plan up to date.



Setanta

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Posted 03 May 2017 - 12:59 PM

If you have not made any major changes to your production flow, there is no reason for a HACCP review to take that long. 


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OG Bean

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Posted 03 May 2017 - 01:43 PM

If you have not made any major changes to your production flow, there is no reason for a HACCP review to take that long. 

 

I agree with Setanta, if you haven't made any major changes or are not looking to make any major changes then the review shouldn't take that long.  Even if it was an internal audit of your HACCP plan I struggle with an auditor saying something didn't take enough time as long as it's not 10 minutes.  If you're well organized you're going to be more efficient. 



Simon

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Posted 03 May 2017 - 01:51 PM

Surely the most important factor is the quality of the content in terms of the review agenda and records / action points.

I've been to very long useless meetings and also very short and productive ones.


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Marzena

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Posted 03 May 2017 - 02:11 PM

Thanks a million :)



GMO

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Posted 03 May 2017 - 03:56 PM

I'm not sure the review can just be 10 minutes if you're reviewing a year.  Remember that you should really be reviewing verification data as well as part of your review, not just "is it up to date?" 

 

We literally have the following questions on our HACCP meeting minutes and we ask them of ourselves each time we have a meeting:

 

Has there been or do we think there may be coming up...?

• change in raw materials or supplier of raw materials

• change in ingredients/recipe

• change in processing conditions, process flow or equipment

• change in packaging, storage or distribution conditions

• change in consumer use

• emergence of a new risk (e.g. known adulteration of an ingredient)

• a recall

• new developments in scientific information associated with ingredients, process or product.

 

This question bothered me though so I checked the interpretation guideline.  There is nothing which says a minimum time.  Also you could argue that the meeting time does not necessarily reflect the time actually spent reviewing it as the attendees also prepared for the meeting.  It's possible this is appealable if you want to go that far but if I'm honest I never bother unless it changes the "score".

 

 

Interpretation Review of the HACCP plan
 
 
The HACCP plan and associated prerequisite programmes must be reviewed on a regular basis, as a minimum at least once per year even if there have been no changes to the product range or processing methods. A review of some or all of the HACCP plan should occur whenever there is a significant change, for example in response to:
change in raw materials or supplier of raw materials
change in ingredients/recipe
change in processing methods and equipment
change in the process flow used in production or storage areas
change in packaging, storage or distribution conditions
change in consumer use
new product design and development
emergence of a new risk (e.g. the adulteration of an ingredient)
an incident or recall resulting in the production of an unsafe product
developments in scientific information related to ingredients, process or product.
Changes that may affect product safety, such as those listed in the Standard, need to be evaluated in the context of the HACCP plan before they are introduced, and the HACCP plan amended as necessary. This may be achieved by documenting a procedure that lists the activities or changes that trigger a HACCP review, but this must be backed by evidence that the review has actually been carried out, for example by documenting minutes of the meeting or an agreed action plan.

 

 



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Scampi

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Posted 03 May 2017 - 06:38 PM

I would agree with GMO, my annual review probably takes a full month to perform (done in sections throughout the year) My program has to meet  FSEP requirements, where by there are 7 sections each with 5-8 subsections with records attached to each sub section as well as process flow, ingredients labelling etc etc etc. 

The FSEP manual that I follow actually has instructions on what an annual reassessment MUST entail.

 

I know its not BRC, but the link below may be helpful

 

http://www.inspectio...9/1345821716482


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Simon

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Posted 03 May 2017 - 08:47 PM

Should you also include a review of relevant customer complaints, internal defect, incidents and out of specification results in the HACCP review?


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Charles.C

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Posted 04 May 2017 - 04:03 AM

I have always focused my Annual haccp review on (a) analysing Corrective actions/RCA/implications/trends over the year , (b) Relevant local-international, FS events, eg disasters, in my specific category over the year and their direct/indirect implications if any, (c) Revalidations where undertaken.

 

Never less than a Day to organize/analyse/predict.

 

Semantically a "Review" is surely indeterminate unless defined otherwise.


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Charles.C


GMO

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Posted 04 May 2017 - 01:54 PM

Should you also include a review of relevant customer complaints, internal defect, incidents and out of specification results in the HACCP review?

 

Yes we do that and I've just realised it's not on the BRC list which is odd (we've also added things from other standards over the years).  It's vital to make sure you are recording that you're reviewing the verification checks somewhere.

 

I was thinking though that at least part of your HACCP review actually could overlap with your management review?



Charles.C

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Posted 04 May 2017 - 02:44 PM

Hi marzena,

 

I'm unclear as to the "BRC  2.6.1" you refer.

 

Is this what you meant ?

 

2.14 REVIEW THE HACCP PLAN

The HACCP food safety team shall review the HACCP plan and prerequisite programmes at least annually and prior to any changes which may affect product safety. As a guide, these may include the following, although this is not an exhaustive list:
•  change in raw materials or supplier of raw materials
•  change in ingredients/recipe
•  change in processing conditions, process flow or equipment
•  change in packaging, storage or distribution conditions
•  change in consumer use
•  emergence of a new risk (e.g. known adulteration of an ingredient)
•  following a recall
•  new developments in scientific information associated with ingredients, process or product.
Appropriate changes resulting from the review shall be incorporated into the HACCP plan and/or
prerequisite programmes, fully documented and validation recorded.

 


Kind Regards,

 

Charles.C




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