Hi Clearyn,
On the basis of recent revelation with regards to your facility's process, I have to agree with your auditor that you do not "risk assess"" a deviation resulting from a CCP Process. Instead you take immediate corrective action as stated in your "Hazard Control Table" when such an event occurs.
(all mesh sizes are industry standard for food safety/raw material flow).
The mesh size is therefore not a problem. The auditor is only concerned about damaged screens where products get through without being "screened". Issue- How many screens do you have? Are they spread out over different stages of the screening process? If so, the last screen with the smallest mesh size is the
CCP (not the rest). Determine if the "unscreened" products" are life threatening.........in terms of partical size as choking hazards etc, if not this is a quality issue hence a QCP. Clearyn, I am only playing the devil's advocate here. You have to determine if it is in reality a fact.
shutting the gate after the horse and that if as a company we are not committed to dumping product/ raw material,
Risk assessment is then defined as ' contact supplier to attain their
Contacting the supplier to assess the risk is not acceptable by any auditors. Pre-determined Corrective Actions in your H. Control Table when deviation occurs validate your
HACCP Plan. Generally, the corrective action would be to either re-work or dispose off affected product. (But the first option is not possible....maybe not for the second option)......so to appease with the auditor, we would need to put our corrective action plan to sound right and acceptable within the
HACCP Principles.........well, at least to get your facility certified.
Options:
Option 1. You do not have historical incidents of physical hazard contamination on your product and that I assume you have a strict sieve/screen maintenance program which you would need to demonstrate to auditor this by having Screen maintenance and monitoring checks records.
So can I assume that this situation of contamination is extremely unlikely and can be controlled to "zero contamination defects". If so be the case, I suggest that you may want to consider putting your corrective action as "isolate product for disposal"...........although, we are putting the noose round our own neck, you will know that it would not occur if you check or replace your screens or sieve regularly. Afterall, it would be cheaper and a viable commerical decision to replace screens than to "re-work or dispose off the affected products" right!
(Isolating affected product for further investigation no longer support this process point as a CRITICIAL POINT .......de javu!)
Option 2. Get a Letter of Guarantee or Certificate of Analysis (Annualised) from your supplier to assure / confirm that the content of physical contamination, if any, is within the industry acceptable tolerance. (Afterall the supply of Raw Mat. has been pre-screened)
This way your process of sieving is to re-enforce the quality rather than removing safety elements. This way, you would likely get away from the need to classify this process as a
CCP.
Suggest that whichever cause of action that you intend to take, please refer and discuss with your auditor prior to doing a Management Review on the CAR. Once auditor concurs, you are home free.
Clearyn, it is not easy to control or determine commercially acceptable decisions when a deviation from a
CCP occurs. It can be financially damaging. Why have a
CCP in your process when you can safely avoid it........this is what I call "keeping it simple"
I hope I have got onto the right track this time and hope the above helps.
Regards
Charles Chew
