I was hoping some of you would be able to review a couple of HACCP plans and provide general feedback. I am trying to beef up our food safety program and figured this would be a great place to start. Any and all criticism and suggestions welcome and appreciated! Thank you in advance!
One of these plans is for a cookie dough line (pre portioned frozen cookie dough pucks) and the other is for a baked and individually wrapped cookie line.
Scampi has a lot of good suggestions with the edits made. Also, you probably should add "receiving packaging" and "storage of packaging" to both of your HACCP processes. If you really wanted to, I suppose you could combine that with your receiving of ingredients and ingredient storage. Also, if you do rework, that should be added. Rework can pose additional hazards especially if you work with numerous allergens. At that point, you'd definitely have to make sure you only rework "like with like".
I'm a little confused about the risk justifications for your biological, chemical, and physical hazards. The items you placed under "justification for determination of hazard significance" should probably be in the same column as your B, C, and P. Under the "justification for determination of hazard significance" you should place the reason why you are finding the hazard to be significant or insignificant. For example, in receiving ingredients, you have "could receive wrong ingredient". I'd move that over to the "P" column for foreign material, and under the justification, state something like "Our warehousing employees are trained to review COAs and inspect product".
I'm not sure why all of the control measures are labeled SOP. It should be clarified which prerequisite programs (or preventive controls), or CCPs are used to reduce the hazards. You could indicate allergen control program, sanitation, supplier approval, COA, CCP/process control, inspection, GMPs etc. in that column rather than SOP.
Also, CCP critical limits really should be defined and quantifiable. How do you quantify ambient temperatures, visible contaminants, and allergen residues? Ranges or thresholds (not to cross) should be identified for each CCP. You could use (just random example numbers) <75 deg F for temperature, or <2.5 PPM for allergen residues. The critical limits that come from the manufacturer for the allergen swabs should suffice for that. I can totally see an auditor questioning you about "No visible rust, soil, or contaminants seen on equipment. No visible personnel effects in product at any time" as a CCP or at least making you dig into that one. I'm not sure how you quantify that as a CCP, other than Pass vs. Fail. You could probably analyze that to be a CP rather than a CCP if you really wanted to.
In your Classic Cookie HACCP Plan, under the CCP corrective actions you have listed "Products may be discarded if critical limits are not met. Cooking conditions will be adjusted". Your phrasing should be more definitive in what your plans would be for product that does not meet critical limits.
Do you perform an ingredient hazard analysis? That would be extremely important to your plan to identify hazards that come from the ingredients and not necessarily the process itself. Also, you should consider doing a vulnerability assessment (food fraud) for your products, and if you're gearing towards FSMA, adding Irradiation as a possible hazard.