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bakeryscience

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Posted 13 August 2018 - 03:52 PM

I apologize if this is a repeat topic, I tried to search for this and didn't see quite what I was looking for. I know that the formatting of both the Food Safety Plan and the HACCP Plan are generally flexible. However, is it possible to put your HACCP plan inside of your Food Safety Plan? Are there any negatives to doing it this way? My thinking is that it would help to eliminate any duplicate information and therefore eliminate possible inconsistencies.

My thinking is to have it laid out like this: Table of Contents, Background Info, Product Description, Food Safety/HACCP Team (can the members of these teams be the same?), Flow Chart, Process Descriptions, PRPs, HACCP Plan (Hazard Analysis, CPs, CCPs, Validation, Verification and Records), PPCs, Validation, Verification and Records, Allergen PC, Sanitation PC, Supply Chain PC, Recall Program.

 

Let me know if you need any more information or clarification. 



Ryan H.

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Posted 13 August 2018 - 04:09 PM

It should be one thing, or it is at least much easier in most cases. You have it correct in my opinion. 

 

Your outline above is how i would of described it so i think your well on your way. As long as you label everything correctly (CCP, PC, etc.), then i think you fine! 

 

Good Luck! 


All the best, 

 

Ryan Heavner 


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Scampi

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Posted 13 August 2018 - 04:15 PM

Mine is all one, however, my haccp plan has it's own binder........because of the way the federal inspection works here, its much easier all around, but it is listed in my table of contents with reference to a separate location


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Ryan H.

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Posted 13 August 2018 - 04:22 PM

Scampi: We had a similar issue and had to explain to the inspectors that it was all in one, but i can completely understand your stand-point! Ultimately it's whichever is simpler! 


All the best, 

 

Ryan Heavner 


bakeryscience

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Posted 13 August 2018 - 04:49 PM

Great, thank you both.



jcieslowski

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Posted 13 August 2018 - 04:50 PM

I think this is pretty annoying myself.  We had a 'food safety plan' for our normal FDA inspected product and we had a 'HACCP plan' for also FDA inspected seafood (fish and tuna) and another HACCP plan for our USDA inspected normal product.   It's kind of silly and annoying.

 

Basically I just replaced the 'normal' FDA HACCP plan with the 'Food Safety Plan' - updated the risk analysis, changed the wording, etc. and have received no complaints or issues from anyone.  

 

What's doubly annoying, at least to me, is that I had a 'food safety and quality plan' which was basically the entirety of my system but our definition of 'food safety plan' (that is, those of us who have been developing food safety plans on this forum) is a lot larger in scope than the required 'food safety plan' by the government.   I don't know why they couldn't have just updated HACCP requirements to include the safe transport rule, foreign supplier rule, and whatever else they wanted. 

 

All that being said, I think you'll be ok either way as long as you've got your terminology in line.



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bakeryscience

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Posted 13 August 2018 - 04:56 PM

Yes, I completely agree with you that they should have just updated the HACCP requirements. That's politics for you (on either side). Thanks for your feedback.

 

I think this is pretty annoying myself.  We had a 'food safety plan' for our normal FDA inspected product and we had a 'HACCP plan' for also FDA inspected seafood (fish and tuna) and another HACCP plan for our USDA inspected normal product.   It's kind of silly and annoying.

 

Basically I just replaced the 'normal' FDA HACCP plan with the 'Food Safety Plan' - updated the risk analysis, changed the wording, etc. and have received no complaints or issues from anyone.  

 

What's doubly annoying, at least to me, is that I had a 'food safety and quality plan' which was basically the entirety of my system but our definition of 'food safety plan' (that is, those of us who have been developing food safety plans on this forum) is a lot larger in scope than the required 'food safety plan' by the government.   I don't know why they couldn't have just updated HACCP requirements to include the safe transport rule, foreign supplier rule, and whatever else they wanted. 

 

All that being said, I think you'll be ok either way as long as you've got your terminology in line.



Marshenko

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Posted 13 August 2018 - 05:06 PM

CFIA savages...

 

Mine is all one, however, my haccp plan has it's own binder........because of the way the federal inspection works here, its much easier all around, but it is listed in my table of contents with reference to a separate location



Scampi

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Posted 13 August 2018 - 05:30 PM

Marshenko, if you only knew!!!!!!

 

I got my hand-slapped last week because we tried a new process without the process design completed (um need data to do that don't cha think) but was scientifically valid......they were not happy. Then one of the inspectors said to me "traditionally it's done this way...." i kept my cool but I think it will be a while until that inspector is here again lol


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Charles.C

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Posted 13 August 2018 - 07:14 PM

I'm a little bemused.

 

What's the difference between a HACCP Plan and a Food Safety Plan ?

 

Is this some specific US / Canadian Semantics ?


Kind Regards,

 

Charles.C


bakeryscience

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Posted 13 August 2018 - 07:28 PM

Yes, I'm not certain of the Canadian regulations, only the US.

 

Essentially, the Food Safety Plan (through FSMA) was created to address allergens, supply-chain, and sanitation. Instead of just updating the HACCP program, an entirely new system was created and now it's double the paperwork even though they overlap. Both programs require different terminology (control point vs. preventive control, etc.) that can't cross over into the other plan.



Ryan H.

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Posted 13 August 2018 - 07:34 PM

I was waiting for this one! Difference... None really. It's more or less the same. It's all about how you want to break it up, or instead (what i prefer) combine the differences into one it plan and keep it together. In the USA the FSMA (Food Safety Modernization Act) really confused everyone when they started talking about HARPC/ HACCP and Food Safety Plan. In essence, your Food Safety Plan is your HACCP Plan, just more robust. The Food Safety Plan is more in-depth and requires some more thought and documentation then a traditional HACCP Plan. This includes things like "Preventive Controls for Sanitation, Allergens, Supply-chain, among other things as well as PCQI's and QI's. 

 

You could call it a Food Safety/ HACCP Plan and it would be fine, as long as you can explain to your inspectors/ auditors how your meeting the requirements. 

 

Clear as mud! 


All the best, 

 

Ryan Heavner 


bakeryscience

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Posted 13 August 2018 - 07:45 PM

Haha, exactly! I just found this thread that is somewhat of the same topic...

http://www.ifsqn.com...-risk-analysis/

 

It seems as though SQF auditors want the plans to be separate. Luckily, we don't have any customers who are requiring us to be SQF certified yet. I'll cross that bridge when/if we ever come to it.

 

 

I was waiting for this one! Difference... None really. It's more or less the same. It's all about how you want to break it up, or instead (what i prefer) combine the differences into one it plan and keep it together. In the USA the FSMA (Food Safety Modernization Act) really confused everyone when they started talking about HARPC/ HACCP and Food Safety Plan. In essence, your Food Safety Plan is your HACCP Plan, just more robust. The Food Safety Plan is more in-depth and requires some more thought and documentation then a traditional HACCP Plan. This includes things like "Preventive Controls for Sanitation, Allergens, Supply-chain, among other things as well as PCQI's and QI's. 

 

You could call it a Food Safety/ HACCP Plan and it would be fine, as long as you can explain to your inspectors/ auditors how your meeting the requirements. 

 

Clear as mud! 



Ryan H.

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Posted 13 August 2018 - 07:51 PM

In an attempt to help I uploaded some "Food Safety Plan" Templates for anyone who needs them. If you would like to call them HARPC templates be my guest! 

 

Honestly, the information is the important part and if you can prove your doing everything required, you should be fine! Don't over think! .... Too much. 

Attached Files


Edited by Ryan H., 13 August 2018 - 07:55 PM.

All the best, 

 

Ryan Heavner 


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Scampi

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Posted 13 August 2018 - 07:57 PM

For me, I've always run an FSEP HACCP plan........so just like the new USA requirements, excluding food defense

 

BUT to appease the SQF auditor I've pulled it out seperetly because I use the FSEP terminology for my haccp plan

 

At previous post the FSSC auditor got extremely pouty when the FSEP headings....spoiled brat lol


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bakeryscience

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Posted 13 August 2018 - 07:59 PM

I definitely tend to overthink and have to catch myself. I recently took a HACCP training course and one of the groups next to me ended up with around 10 CCPs for a frozen french fry plant...everyone else just had 1. This happened after the instructor mentioned not to overthink it and that the average number of CCPs is 2-3. Definitely easy to overthink!



Ryan H.

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Posted 13 August 2018 - 08:04 PM

Yes be reasonable! I hope they didn't go back to the plant with 10 CCP's! Are they going to monitor them hourly too! 

 

Being effective is key. 

 

Which HACCP course was it if i may? Curious? 


All the best, 

 

Ryan Heavner 


Charles.C

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Posted 13 August 2018 - 08:07 PM

Thanks to the previous.

 

So, in the beginning, we had -

 

Codex/NACMCF's (Primo) HACCP designated "HACCP" (eg FSP0)

----------------------------------------------------------------------------------

ISO issued their version HACCP designated "ISO-HACCP" (ISO22000)

-------------------------------------------------------------------

And, speculating -

 

USA/FDA have issued FSMA containing their interpretation of HACCP designated  HARPC (also apparently designated Food Safety Plan)(eg FSP1)

 

Canada/CFIA issued their interpretation of HACCP designated Food Safety Plan (FSEP) (eg FSP2)

 

SQF issued their interpretation of HACCP (claimed based on NACMCF/Codex) designated Food Safety Plan (eg FSP3)

 

And no doubt there are more.

 

Everyone's got FSPs !


Kind Regards,

 

Charles.C


bakeryscience

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Posted 13 August 2018 - 08:10 PM

Luckily the instructor steered them in the right direction. It was the HACCP for Processors course from NSF.

 

 

Yes be reasonable! I hope they didn't go back to the plant with 10 CCP's! Are they going to monitor them hourly too! 

 

Being effective is key. 

 

Which HACCP course was it if i may? Curious? 



Ryan H.

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Posted 13 August 2018 - 08:11 PM

Charles: I think you hit it on the head! 


All the best, 

 

Ryan Heavner 


Ryan H.

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Posted 13 August 2018 - 08:14 PM

Ok thanks for letting us know redbudke! NSF typically offers great courses and their knowledgeable so that is good. In my experience Eurofins is also really good. Hopefully you have a mentor (in the event this is new to you) to help guide you in the beginning. 

 

Good luck to you! 


All the best, 

 

Ryan Heavner 


bakeryscience

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Posted 13 August 2018 - 08:28 PM

Yes, I thought it was a great course and they gave a lot of material that we could take home. I also recently took an online PCQI course and did not like it as much...I think I just prefer to be in a classroom setting.

 

Unfortunately I'm the one-and-only employee here doing food safety (although I'm currently building up a team...they are in production, marketing, maintenance, etc. and FS is not their only focus) so I've been hanging around this forum a lot lately! I'm very glad I found it!



pghosh

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Posted 14 August 2018 - 02:41 AM

Talking about differences in opinion that leaves people like us developing programs, in limbo.

 

The oven step in our par baked crust processing, has always been considered a quality step. 

 

When developing the FSP, we validated this as a process control, supporting 7 log reduction of Salmonella. 

 

There's no physical segregation or transition zone between pre oven and post oven processing, but we have a robust EMP as an assessment tool. 

 

A consultant once told us not to call the oven a Process Control due to lack of physical segregation and transition zone. On the other hand, our PCQI instructor, instructed us to treat this as a process control, with evidence of no environmental cross contamination. 

 

We kind of lean towards the instructors advice, but would like to know your thoughts in this. 



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Posted 14 August 2018 - 03:50 AM

Talking about differences in opinion that leaves people like us developing programs, in limbo.

 

The oven step in our par baked crust processing, has always been considered a quality step. 

 

When developing the FSP, we validated this as a process control, supporting 7 log reduction of Salmonella. 

 

There's no physical segregation or transition zone between pre oven and post oven processing, but we have a robust EMP as an assessment tool. 

 

A consultant once told us not to call the oven a Process Control due to lack of physical segregation and transition zone. On the other hand, our PCQI instructor, instructed us to treat this as a process control, with evidence of no environmental cross contamination. 

 

We kind of lean towards the instructors advice, but would like to know your thoughts in this. 

 

Hi pghosh,

 

The BRC viewpoint/interpretation is presented on Pgs 4-5 of attachment.

 

Attached File  brc6 F048 - Understanding High care and High risk.pdf   589.79KB   84 downloads

 

Regret that I was unable to comprehend the basic logic (ie initially assume no preventive controls exist)  whereby FSMA developed their hazard analysis so unable to comment on yr consultant's explanation. It sounds somewhat fudge-like so maybe "borrowed" from BRC. :smile:


Kind Regards,

 

Charles.C


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keal9

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Posted 14 August 2018 - 05:59 AM

It should be necessary .. and should be label correctly for in case, it is easier to find to look. .Like in our company, a food manufacturer, we include haccp in our food safety plan and make sure every files labeled correctly..




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