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Is it possible to combine FSMA-HACCP and BRC-HACCP?


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#1 Rancy Sharma

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Posted 14 September 2017 - 08:10 PM

Hi Everyone,

 

 

I have a question about FSMA HACCP. We are Canadian company and have strong BRC HACCP established. Is it possible to combine FSMA- HACCP and BRC- HACCP together or we need to make it separately?

 

Any information will be greatly appreciated!

 

Thank you


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#2 Charles.C

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Posted 14 September 2017 - 09:32 PM

Hi Everyone,

 

 

I have a question about FSMA HACCP. We are Canadian company and have strong BRC HACCP established. Is it possible to combine FSMA- HACCP and BRC- HACCP together or we need to make it separately?

 

Any information will be greatly appreciated!

 

Thank you

 

Hi Rancy,

 

I haven't checked but I thought there was a version of Food BRC in which the "haccp" is supposed to be "FSMA compatible".


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Kind Regards,

 

Charles.C


#3 Ryan M.

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Posted 20 September 2017 - 09:39 PM

Yes.  Just add a column in your BRC Hazard Assessment for "Preventive Control Measures for Human Food (FSMA) Required (Process, Allergen, Sanitation, Supply Chain)".

 

Then you will have a "Preventive Controls Summary" like you have a HACCP Hazard Summary.

 

See attached screenshot of a line from our hazard analysis.

Attached Files


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#4 Nikki R

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Posted 21 September 2017 - 08:03 AM

Yes it is possible. I was signed up to emails a little while ago for a lady called Kassy Mash with techni -K who wrote a series on how to comply to both standards at once.

This is the link to the newsletter archive, hope it helps

https://techni-k.co.uk/FSMA-Articles


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#5 Charles.C

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Posted 22 September 2017 - 03:23 AM

Yes.  Just add a column in your BRC Hazard Assessment for "Preventive Control Measures for Human Food (FSMA) Required (Process, Allergen, Sanitation, Supply Chain)".

 

Then you will have a "Preventive Controls Summary" like you have a HACCP Hazard Summary.

 

See attached screenshot of a line from our hazard analysis.

 

Hi Ryan,

 

Thks for the detailed screenshot although I'm a bit puzzled at the risk assessment scheme/entries/calculation.

 

Is "1" the maximum level of severity ? (Presumably not Low?)

Is "C" a medium level of Likelihood of Occurrence ? (seemingly concluded as Low)

 

How do you end with "4" ? (an additive scheme although 25 implies not ?)(non-linear scales ?) and what is a "significant" result ?

 

I also (a lot) wondered what the last (chopped) column was titled/stated ?  YES ?....[to ?]  :smile:

 

Regardless this looks like an elegantly logical/simple add-on appproach to FSMA if it's auditorially OK. Many thanks for sharing.


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Kind Regards,

 

Charles.C


#6 Ryan M.

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Posted 22 September 2017 - 01:37 PM

Hi Ryan,

 

Thks for the detailed screenshot although I'm a bit puzzled at the risk assessment scheme/entries/calculation.

 

Is "1" the maximum level of severity ? (Presumably not Low?)

Is "C" a medium level of Likelihood of Occurrence ? (seemingly concluded as Low)

 

How do you end with "4" ? (an additive scheme although 25 implies not ?)(non-linear scales ?) and what is a "significant" result ?

 

I also (a lot) wondered what the last (chopped) column was titled/stated ?  YES ?....[to ?]  :smile:

 

Regardless this looks like an elegantly logical/simple add-on appproach to FSMA if it's auditorially OK. Many thanks for sharing.

 

That was only half of the picture Charles.  The first sheet in our hazard analysis workbook deals with the measuring of the hazard significance and frequency of occurrence.  This is assessed by the ingredients & materials related to each process step, personnel practices, environmental hazards (within the facility), recall history, equipment risk as it relates to a specific hazard type, etc.  See attached.

Attached Files


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#7 Charles.C

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Posted 22 September 2017 - 10:49 PM

That was only half of the picture Charles.  The first sheet in our hazard analysis workbook deals with the measuring of the hazard significance and frequency of occurrence.  This is assessed by the ingredients & materials related to each process step, personnel practices, environmental hazards (within the facility), recall history, equipment risk as it relates to a specific hazard type, etc.  See attached.

 

Hi Ryan,

 

Thanks for pic. I now recall this is a published SQF matrix with non-linear, asymmetric scales.

 

If I understand correctly the conclusion in column L of 1st pic is that the step analysed is (risk = 4) significant despite being controlled by GMP.

 

Just for contrast, I enclose another published matrix with similar qualitative logics but linear, symmetrical scales. The interpretation for analogous inputs is now non-significant.

 

Illustrates the subjectivity of risk assessment. :smile:

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Kind Regards,

 

Charles.C


#8 Ryan M.

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Posted 23 September 2017 - 02:56 PM

Hi Ryan,

 

Thanks for pic. I now recall this is a published SQF matrix with non-linear, asymmetric scales.

 

If I understand correctly the conclusion in column L of 1st pic is that the step analysed is (risk = 4) significant despite being controlled by GMP.

 

Just for contrast, I enclose another published matrix with similar qualitative logics but linear, symmetrical scales. The interpretation for analogous inputs is now non-significant.

 

Illustrates the subjectivity of risk assessment. :smile:

 

Yes, quite subjective.  The key to the risk assessment and hazard analysis is to backup any claim or decision.  


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#9 FurFarmandFork

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Posted 25 September 2017 - 05:43 PM

I actually rewrote my own matrix to make it more accessible to my food safety team, as well as provide a clear line between hazards requiring a PC or not (I hate the matricies that use a "yellow" section), and allow room for the "likelihood" section to take into account FDA hazards guidance, which may otherwise fall off my scale for actual likelihood but are expected to be seen in my plan.

 

 

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For discussions related to food safety, production, and agriculture. Check out my blog at http://furfarmandfork.com/.

 


#10 Charles.C

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Posted 26 September 2017 - 05:47 AM

I actually rewrote my own matrix to make it more accessible to my food safety team, as well as provide a clear line between hazards requiring a PC or not (I hate the matricies that use a "yellow" section), and allow room for the "likelihood" section to take into account FDA hazards guidance, which may otherwise fall off my scale for actual likelihood but are expected to be seen in my plan.

 

Hi 3F,

 

Still contentious IMO due the notoriously ambiguous "Likelihood of occurrence in the absence of a preventive control". And the "10"s. :smile: But no doubt very FSMA-friendly.

 

Just by their nature/design risk matrices exhibit varying degrees of linearity/risk averseness. And likelihood/severity biasing.


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Kind Regards,

 

Charles.C





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