Jump to content

  • Quick Navigation
Photo
- - - - -

HACCP Plan Critique Requested


  • You cannot start a new topic
  • Please log in to reply
13 replies to this topic

#1 mtmoore4

mtmoore4

    Grade - Active

  • IFSQN Active
  • 10 posts
  • 1 thanks
0
Neutral

  • United States
    United States

Posted 10 August 2017 - 02:43 AM

I would like to post my HACCP plan. Will anyone be willing to critique it? I am currently working toward Basic Hygiene for a corrugated packaging company.


  • 0

#2 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,366 posts
  • 3218 thanks
343
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 10 August 2017 - 05:20 AM

I would like to post my HACCP plan. Will anyone be willing to critique it? I am currently working toward Basic Hygiene for a corrugated packaging company.

 

Hi Michael,

 

If it's understandable, probably Yes.

 

JFI, Hygiene is typically a Prerequisite to the HACCP Plan.


  • 0

Kind Regards,

 

Charles.C


#3 mtmoore4

mtmoore4

    Grade - Active

  • IFSQN Active
  • 10 posts
  • 1 thanks
0
Neutral

  • United States
    United States

Posted 10 August 2017 - 06:22 PM

If anyone can look over and provide feedback it would be appreciated. This is for BRC clause over Hazard and Risk Management.

 

 

Thanks in advance. Michael


  • 0

#4 mtmoore4

mtmoore4

    Grade - Active

  • IFSQN Active
  • 10 posts
  • 1 thanks
0
Neutral

  • United States
    United States

Posted 10 August 2017 - 06:25 PM

See attached

Attached Files


  • 0

Thanked by 1 Member:

#5 mtmoore4

mtmoore4

    Grade - Active

  • IFSQN Active
  • 10 posts
  • 1 thanks
0
Neutral

  • United States
    United States

Posted 10 August 2017 - 09:40 PM

Please review attached

Attached Files


  • 0

#6 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,366 posts
  • 3218 thanks
343
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 11 August 2017 - 02:19 AM

Hi Michael,

 

Thks for the attachments.  I note you prefer the US haccp question-table style. i am more familiar with the simple hazard/control measure/risk assessment layout but no doubt both are BRC-acceptable.

 

I should state that i am not a Packaging person however (and it's just my opinion) it seems to me that the BRC packaging standard is a bit of a mish-mash of topics borrowed from the BRC Food Standard and then "adjusted". It is well known that some food haccp concepts can be awkward to expand into the packaging arena.

 

I can make a few basic comments -

 

1. The hazard analysis as tabled seems to not use the methodology given in its introduction, eg there is no quantitative risk assessment ?.

2. All the entries in Column4 of the haccp table are "N/A" (presumably "not applicable"). I'm not sure what this actually means in current context ?

3. The Plan/Manual seems to not contain or refer to any specific Prerequisite programs other than in the PP definition. I am unclear whether BRC requires specific cross-referencing to exist.(?).

4. Some of the entries in the haccp table columns 5/6 seem incompatible with the associated statements in column 3.

5. The Plan/Manual seems to have not explicitly considered some of the factors listed in Clause 2.2.5. I have noticed other Packaging Plan examples posted here which did include such.

6. Some of yr listed Food Safety "hazards" are not actually regarded as such, eg Enterobacteriaceae, Yeasts, E.coli (generic), hair.

 

Whether the above observations are major etc from a BRC Packaging POV I am unable to judge. Other BRC-certified Packaging members here can likely say more.


  • 0

Kind Regards,

 

Charles.C


#7 garyjgatf

garyjgatf

    Grade - Active

  • IFSQN Active
  • 4 posts
  • 0 thanks
0
Neutral

  • United States
    United States

Posted 22 August 2017 - 02:55 PM

Charles:

 

Can you provide links to the other Packaging Plan examples that have been posted?

 

Thanks,

Gary Jones


  • 0

#8 mtmoore4

mtmoore4

    Grade - Active

  • IFSQN Active
  • 10 posts
  • 1 thanks
0
Neutral

  • United States
    United States

Posted 24 August 2017 - 07:38 PM

Charles C. would it work if I were to use these methods but add food safety on the registers?

 

 

Thanks

Michael


  • 0

#9 mtmoore4

mtmoore4

    Grade - Active

  • IFSQN Active
  • 10 posts
  • 1 thanks
0
Neutral

  • United States
    United States

Posted 24 August 2017 - 07:39 PM

Please see attached


  • 0

#10 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,366 posts
  • 3218 thanks
343
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 24 August 2017 - 08:06 PM

Charles:

 

Can you provide links to the other Packaging Plan examples that have been posted?

 

Thanks,

Gary Jones

 

Hi gary,

 

IIRC I did post a list of links previously but unfortunately was a few years ago. If i can find it, i will post a link.

 

I think the most frequently posted source in recent times is probably this -

 

https://www.iopp.org...cfm?pageID=2267


  • 0

Kind Regards,

 

Charles.C


Thanked by 1 Member:

#11 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,366 posts
  • 3218 thanks
343
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 24 August 2017 - 08:09 PM

Charles C. would it work if I were to use these methods but add food safety on the registers?

 

 

Thanks

Michael

 

Hi Michael,

 

Sorry but I'm unsure what "methods" you are referring to ? Please clarify.


  • 0

Kind Regards,

 

Charles.C


#12 mtmoore4

mtmoore4

    Grade - Active

  • IFSQN Active
  • 10 posts
  • 1 thanks
0
Neutral

  • United States
    United States

Posted 25 August 2017 - 02:18 AM

The method of simple hazard/control measure/risk assessment layout but no doubt both are BRC-acceptable


  • 0

#13 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,366 posts
  • 3218 thanks
343
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 25 August 2017 - 02:45 AM

Charles C. would it work if I were to use these methods but add food safety on the registers?

 

 

Thanks

Michael

 

Hi Michael,

 

It's difficult to comment without seeing an example of what you mean. Is that possible ?

 

Alternatively you might compare yr present haccp plan with a typical example of a BRC-compatible Packaging HACCP response since this will also illustrate the detailed requirements of the Standard and perhaps answers to some of the comments in Post 6.

 

There are a few BRC-examples on this forum but offhand i don't remember where. Maybe try scanning the BRC Packaging sub-Forum.

 

PS - One detailed Packaging example is linked below. A lot of the material in the attached zip file is still relevant but the hazard analysis relates to a much earlier BRC version than present and does, I think, not include "safety" aspects such as "quality" / "legality". However handling of the latter items are, IIRC, exampled in some later posts.

 

http://www.ifsqn.com...kaging-company/


  • 0

Kind Regards,

 

Charles.C


#14 Madam A. D-tor

Madam A. D-tor

    Grade - PIFSQN

  • IFSQN Principal
  • 553 posts
  • 166 thanks
20
Excellent

  • Netherlands
    Netherlands
  • Gender:Female
  • Interests:meat, meat products, ready to eat, food safety, QMS, audits, hazard analyses, IFS, BRC, SQF, HACCP, ISO 9001, ISO 22000

Posted 25 August 2017 - 07:01 AM

Dear mtmoore4,

 

I have studied the first uploaded materials.

 

Let me say first that I have no experience in packaging material HACCP plans. So my remarks are generally speaking with a food back ground and actually I just checked if I understand it and would approve it.

 

What I did not found in your HACCP  Manual is the definitions/descriptions of occurrence and severity. On page 8 of 14 you describe that both can be low, medium or high. But you did not declare what low, medium and high is. For good understanding for external readers (e.g. auditors) and to help HACCP team to asses the hazards consistently, you should determine what you mean with low, medium and high. Give it a number! Is high occurrence monthly, weekly or daily? And low occurrence is this monthly, quarterly, annually or once in 5 years? It makes a lot of difference in your assessment. If possible and easier you can also use terms as once every order, once every 10,000 packs, etc. Just what fits your process and organization. The same for severity. Is low severity: receiving a complaint and high severity: people might die?

 

Then on page 9 of 14 hazard identification and assessment starts.

per ingredient/process step you identify the hazards. (again, with my background it is hard to see if you are missing relevant hazards)

for each hazards you than decide if the potential hazards is significant for food safety. This decision should be justified in the next column.

I think it is very strange that you decide for all identified hazards, that these are not including significant food safety risk. A few years ago there have been incidents with heavy metals from printing ink on the carton going through the plastic inner bag into the products. Please keep in mind that food products might be stored for years in your cartons.

As motivation for this NO-answer you gave N/A (not applicable). I expect a justification here related to the NO answer. WHY is the hazard identified not a relevant food safety hazard. It would be great if you can justify with scientifically literature, reports of authorities or practically experience.

Then, out of the blue, there is a decision if the hazard is a CCP or not. I expected to find per hazard an assessment with occurrence and severity. Just as you indicate on page 8 of 14. For each identified hazard I expect the estimated occurrence (low, medium, high), the motivation for this (on with ground do you think the occurrence is low, medium or high), the estimated severity (low, medium, high) and the motivation for that (on which ground did you decide the severity is low, medium or high). The occurrence X severity leads to a risk and the risk leads to the conclusion CCP or not. I would like to see this all in a HACCP study. As reader (auditor) I would like to follow and understand your thoughts and motivations during your HACCP study. Therefore it should al be documented. Also for your own purpose. If you are to review after a year, you will find that, if you did not proper document this, you can not tell anymore why a hazard had a medium severity, etc. Especially if some members of the team has changed. This is my experience as HACCP team leader.

 

Missing hazards in your hazard identification:

- on page 5 of 14 at food safety characteristics you state that printing and labeling is very important to prevent allergen or legality non-conformities at your customers. This is not included in your hazard identification. Also not the hazard of mixing up different sleeves/printed packaging materials. This is something I frequently hear in food companies. (I just do not understand how this can happen) (within a stack of labels/sleeves some other labels/sleeves are found)

- the hazards you name on page 6 of 14 (general factory wide contamination risks) are not found in the hazard identification and risk assessment tables.

- Also on page 7 of 14 you name hazards that are not found in the hazard identification and risk assessment tables.


  • 0
Kind Regards,

Madam A. D-tor




0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users