11 replies to this topic

[mettlert]

last fall my SQF auditor told me to make sure that my HACCP plan was not part of my FSMA food safety plan or otherwise I would not pass my audit.  Can someone please explain to me why this would be?  Is it just because SQF is HACCP based?  I was just trained as a PCQI, which I understand there are some control measures used in HACCP that would not be used in the FSMA food safety risk analysis.  Example.  A magnet would not be included on FSMA because you would never know if you "caught" 100% of the material however it would be used in HACCP.  Same thing with screens.

 

I would like to know what everyone else is doing that has SQF certificates and FSMA regulations. Are you doing two stand alone programs?  I was also advised by the PCQI trainer that this might be the best way to go beings SQF wants to look at way more information then what we would let the FDA look at.  He told me that whatever is in my FSMA food safety plan would now be fair game for the FDA to look at, which is different from before.

[ffkmm]

From my understand a separate plan will need to be made. When you think of FSMA you think of preventative measure instead of control points and critical controls points. I instead made all my control points and critical controls points from my HACCP plan into preventative measures in my HARP plan. It is just wording changing at the end.

 

and a magnet will be included in you FSMA plan as well. It is not considers a CCP but instead a preventative measure.

[mettlert]

Thanks for the info.  I received word back from the auditor that it can be both ways but he cautioned me that SQF requires that you have a HACCP plan that is based on the 12 steps of HACCP and follow the Codex Alimentarious where as FSMA does not.

  Which told me I will be keeping my plans completely separate.

[Scampi]

I'm sorry but am I the only one who thinks this whole business is getting out of hand?  When the new regs come in here (Canada) it will essentially be the same thing!!!!!

[mettlert]

Yes, it is out of control.  

[MsMars]

I'm sorry but am I the only one who thinks this whole business is getting out of hand?  When the new regs come in here (Canada) it will essentially be the same thing!!!!!

 

To me it's been out of hand all along here in the US... FDA vs USDA... I could spend all day going round and round about that one.  And we are dual jurisdiction at our facility.    

[Scampi]

Craziness!!!  Same here Health Canada and CFIA fighting for top spot

[FurFarmandFork]

I just identified any "process preventive controls" as Codex CCP's in my food safety plan. Auditor said that was good and it would have been a minor NC for not following CODEX if I hadn't used the language CCP on those control steps.

[Charles.C]

JFI, here is the (tabular+) SQF-commissioned comparison of SQF Level2 (modules 2,11)  vs FSMA -

 

 SQFLevel2 vs FSMA,2015.pdf   109.24KB   187 downloads

 

 

 

 

[GrainGirl]

 

From my understand a separate plan will need to be made. When you think of FSMA you think of preventative measure instead of control points and critical controls points. I instead made all my control points and critical controls points from my HACCP plan into preventative measures in my HARP plan. It is just wording changing at the end.

 

and a magnet will be included in you FSMA plan as well. It is not considers a CCP but instead a preventative measure.

 

 

Glad you brought up magnets, because we are installing a rare earth magnet and have to add it to our FSMA food safety plan (we are subject to the preventive controls rule for human food). Under FSMA, a magnet would be a process preventive control, right? Among other things, FSMA requires process preventive controls to (1) have associated parameters (e.g., max or min values), and (2) be validated.

 

How would you establish parameters for a magnet? Unlike a metal detector, there are no obvious limits. In the same vein, how would you go about validating a magnet? We would like to establish the magnet as a FSMA preventive control, but we are struggling with how to fulfill these requirements.

[Charles.C]

Glad you brought up magnets, because we are installing a rare earth magnet and have to add it to our FSMA food safety plan (we are subject to the preventive controls rule for human food). Under FSMA, a magnet would be a process preventive control, right? Among other things, FSMA requires process preventive controls to (1) have associated parameters (e.g., max or min values), and (2) be validated.

 

How would you establish parameters for a magnet? Unlike a metal detector, there are no obvious limits. In the same vein, how would you go about validating a magnet? We would like to establish the magnet as a FSMA preventive control, but we are struggling with how to fulfill these requirements.

 

Hi GrainGirl,

 

Based on previous magnet threads this can be complicated. i assume you have no subsequent metal detector.

Validation has a variety of interpretations. Using a "CCP" analogy, i asssume you mean validating the "critical limits".

 

For metal detectors this usually involves using test pieces to demonstrate that a suitable minimum sensitivity is achieved/maintained. Not so practically simple for a magnet though. The result seems to be a preference to define the "appropriate" operational parameters and validate these instead.

 

Can see these previous posts / links / threads -

 

http://www.ifsqn.com...ccp/#entry25805

(especially see attached pics in bottom half of post)

 

http://www.ifsqn.com...n-a-flour-mill/

 

http://www.ifsqn.com...magnet-program/

 

Of course FDA may have elsewhere published a desired procedure for the dreaded FSMA/HARPC juggernaut which would supercede all the above.

[clrmwebb4350]

^{My company produces food contact packaging. We are SQF certified. I didn't think we fell under FISMA because we do not produce food. Am I wrong? Do I need to have a FISMA plan as well as a HACCP plan?}