Dear Simon,
Certainly have to praise SQFI for giving free access to these documents. They
do contain an abundance of information, some of it quite useful in interpreting aspects of BRC in fact.
However IMO their definitions of some of the basic HACCP terminology seem rather confused, for example in the section of Part3 - Annex 3: Level 2 Food Safety Plan; Application of HACCP Food Safety Plans,
A hazard is defined as (Pg 59) -
Any biological, physical or chemical intrusion that will affect product safety or quality if unchecked;
(Certainty?)
The definition of CCP is-
'Any point in a process where loss of control leads to problems affecting product safety or quality'
(serious ?, control can be implemented ?)
In the same list the definition of Control Point is
'Any point in a process where loss of control does not lead to problems affecting product safety or quality'
(Why use a 'control point' for a non-existent problem)
Similarly in the main table (Pg 63) The CCP is restated as -
'A step in the process where loss of control will result in a risk to the safety of the product'
(Serious ?)
Another item I found strange was that they seem to require validation of critical limits but not of the CCP itself. I suppose a decision tree if used can be considered as a covert validation. I would have liked a specific statement here (admittedly I'm not sure BRC requires this either). I personally found the CCP validation one of the most challenging / self-educating aspects of the HACCP process (along with thinking up the hazards in the first place of course).
Nonetheless, plaudits for the info. and letting people evaluate.
Rgds / Charles.C
