51 replies to this topic

[Gaskit]

In preparation for version 3 of the BRC/IoP Packaging Standard where now we are required to produce a risk management matrix sec 1.9, I knocked this together, hope it can be of help (although I do not like utilising such matrix as borderline cases always get reduced to the lower category).

Regards,

Steve

New link added 10022008 to replace broken original / Charles.C -

 Risk_Matrix_steve_gasket_saferpak_.xls   18KB   2004 downloads

(also available as No1 in Ch.C post in this thread, ca. 09022008)

[Charles.C]

Dear Steve,

A nice classical example.

I have never had an auditor query me as to my method of classifying between for example occasional/seldom or marginal/negligible. They typically look at my slightly varied English explanations (has happened / may happen etc) for each and rapidly (hurriedly?) pass on to the final CCP’s. It depends on the specific case of course but this step is surely about as subjective as it gets. I won’t mention oPRPs.

How about you ?

Rgds / Charles.C

[Madam A. D-tor]

Dear Steve,

I have never had an auditor query me as to my method of classifying between for example occasional/seldom or marginal/negligible. They typically look at my slightly varied English explanations (has happened / may happen etc) for each and rapidly (hurriedly?) pass on to the final CCP’s. It depends on the specific case of course but this step is surely about as subjective as it gets. I won’t mention oPRPs.

Hi Charles,

I really have to react on that!
It really depends on the systems you were audited against (is this proper English?). During BRC or IFS audits there is too less time to do an in-depth investigation of the HACCP analyses. When I am auditing the Dutch HACCP Requirements, I really evaluate the HACCP analyses. But, only once in three years or when changes or amendments are made.

I think mentioning the OPRPs and PRPs is a good thing. It makes it very clear that those risks are taken care of, that they are controlled in one way or another.

Don't worry! No defence! I have seen both sides of the fence myself and as an auditee, I always hated it, if the auditor did not take time to look at the important things. I'm trying to do a better job now, but as you probably know, it is not as easy as it seems.


Dear Jane and Steve,

There are also matrices with 5 X 5 or 3 X 3 occurrence and severity.


Steve,

With your matrix you are saying that a hazard which does not occurs very often, but has a catastrophic (death?) effect is no CCP.
Can you give me an example of this? What is the definition you used for unlikely? And what for seldom?

[Gaskit]

Dear Madam A.D-tor,

Thanks for your comments, as I attempted to convey, utilising a matrix in my opinion is a waste of time as there is always the borderline cases, anyhow here goes with the explination:

UNLIKELY TO OCCUR: As opposed to cleaning packaging machinery with Food Area Degreaser, one of the operatives would utilise Non Food Degreaser and a dirty rag full of C.DIF and not rinse it of effectively, this if transfered to food stuff (RTE for example) in processing would in my opinion be catastophic, however; THIS IS UNLIKELY TO OCCUR due to all relevant OPRP and PRP in place.

SELDOM: Transport companies turn up with non food items on the same load as food grade items (external contractors utilised by suppliers on occasion), it seldom happens, but on occasion it has / may do in the future, again mainly controlled by OPRP / PRP, but one can not always control the mind set of a trucker.

A little far fetched, however I hope it provides a little food for thought.

Kind regards,

Steve

[Charles.C]

Dear Madam ADT,

Yr query regarding high severity producing a low risk illustrates the difficulty of providing exact answers. Without looking it up in detail, I think it is common to see a prioritisation (subjective obviously) on the side of “likelihood of occurrence”. For example can have a look at pgs 17,18 in this reference where there is a variety of interpretations of the consequence/ likelihood parameters –

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Jean refers to a “buffet”, this is probably regarded as a high risk topic, (does it also include things like oysters ?) which will cause some preliminary sharpening of auditor knives in all likelihood (and I guess rightly so from an epidemiological viewpoint).

No mention is made regarding literature validation of any CCPs for the above – I would expect the IT to offer substantial help for such a sensitive process ? Presumably the auditor had a similar query ? Similarly a validated non-CCP would be equally meaningful, you can see some comments regarding hygiene defects in the above ref. but the actual process will presumably dominate. I have found that providing one can validate one’s interpretations, an auditor will tend to be relatively non-argumentative even if he/she disagrees with yr opinion ( providing that he/she does not have a superior counter-reference , this has rarely happened IMEX with well-documented systems but it depends on the process again).

One has to remember that probability is the basis of the above via historical / scientific data whatever so some people prefer numbers as in the worked example in this forum (dwl section) but you still have the same borderline / linear /exponential decisions to make. I would suggest that there is also somewhat of a temptation to choose the matrix format so as to achieve a self-perceived requirement (reverse probability). All these complexities promoted the Codex tree option but this still necessitates a risk analysis somewhere even though it’s often not explicitly shown, in this respect ISO22k should perhaps be congratulated. Or not ?

I didn’t initially notice Steve’s inclusion of the prp evaluations in his upload. This is the first example of a published matrix on this site which includes such AFAIK. Very generous IMO (and brave).

Rgds / Charles.C

added - Personally, I have only seen one other example of an ISO 22000 oriented risk matrix analysis on the IT, namely at this link - http://www.nordicinn..._img/heggum.pdf
This latter approach has, I think, preemptively removed the "prps" from consideration within the risk matrix stage so that only oprps and CCPs potentially remain, this is perhaps more closely aligned to the I22k philosophy ?

[Bobby]

"I request you to provide some assistance in the risk assessment for below:-
Process: No cook step (catering operation)

Step: Preparation

Hazard : Biological (M, C) - due to improper handling,poor personal hygiene, poor cleaning &   sanitizing, temperature abuse

Risk assessment:- Likelihood –M ; Severity- H

Using the Codex decision tree I have decided to consider this step as CP.
But as per the auditor, this step should be a CCP because severity is High. "

Jean,
What is the Critical control point and the critical limit the auditor is looking at in this step?????
Goes on to show that HACCP auditing is miserable when it comes to catering operations!
My professor used to say " If you want a perfect system, every step is a CCP!"

however, do not rely on the number of complaints to identify a CCP.

try answering the following questions:

Did the auditor find something that indicated poor personal hygiene?

Do the food handlers wear gloves when they handle ready to eat foods?

How about hand and food contact surface swab test results?


Bobby Krishna
Food Inspector
Dubai Municipality

[Madam A. D-tor]

Madam A.D-tor:</U> Can you advice as from where to obtain info on matrices with 5 X 5 or 3 X 3 occurrence and severity.

Hi Jean,

I have no links or documents available at this moment. I will look this up this weekend and come back to you.

I request you to provide some assistance in the risk assessment for below:-
Process: No cook step (catering operation)

Step: Preparation

Hazard : Biological (M, C) - due to improper handling,poor personal hygiene, poor cleaning &amp;&nbsp;&nbsp; sanitizing, temperature abuse

Risk assessment:- Likelihood –M ; Severity- H

It depends on your used definition on high severity and medium Likelyhood. If for example high severity means death can occur and medium likelyhood is something between monthly and once in 3 months, your company management is actually saying: "We accept that once in 3 months someone dies from our products". Probably your company won't take that responsability. So you have to make sure things can not go wrong, and set a CCP. A CCP is the highest protection you can give to the customers despite from forbid them to eat your products.
It is really a theoretical problem. It may occur and the effect may be very high. So you have to take measurements. If you are saying by your risk assessment that people can die from it, and after that decide it is not important enough to control by a CCP, it makes a strange of your company. Probably in production every thing is controlled very well, because you do not seem to have any problems (complaints, bad results on hygienic checks, etc.)
The auditor should also report if you are able to perform a good HACCP analyse. This is an example that seems strange in theoretical way but is probably allright in the practical way. But maybe you make the same "mistake" with other hazards, which was the auditor not able to detect.
That is why (in my opinion) an auditor should always discuss the HACCP-analyses. To find out if the company understands what they are doing and if they are using an adequat method.

I hope this explenation (in poor English) helped you in oone way or another.

[Charles.C]

Dear Jean,

I think you should be thanked for initiating this thread since some very interesting comments being made.

With all respect to the previous posts, I suggest that you detail the process a little more if some further specific advice required. I think this was the idea behind Bobby’s comment ?.


(BTW, the non-use of gloves for RTE items is a major defect in some Food Codes, USA for example, although previous threads here have shown very mixed opinions on this subject.)

Eg, What is the product? Chicken sandwiches ?

Eg, What is the Hazard ? It is usually demanded IMEX (by the auditor also) to specify a microbiological hazard, not generalise by (MC) as above, eg >> Salmonella. This demonstrates that the auditee understands the process and focuses the risk assessment. (Perhaps you have x-referenced this elsewhere in the HACCP plan but my auditors would not accept such a presentation).
Assuming Salmonella, I certainly agree with Madam DTA’s comment that a routine occurrence of Salmonella every 3 months in a RTE food would be unsatisfactory ! Perhaps more like catastrophic !

Risk assessment:- Likelihood –M ; Severity- H

I find yr own assessment of “M” a little surprising/worrying, why not "L"?, ie, how did you decide ? Does this reflect the specific input (cooked) materials you are using or your own assessment of the surrounding hygiene (the latter ok from yr previous post)

What risk matrix are you / the auditor using at the moment ?

There is a freely dwlable 3 x 3 matrix on this site thanks to Simon (> General Discussion>Doc Exchange>HACCP Manual Example for Packaging ). This uses numbers and you can see that M x H does not lead to a CCP although the auditor might not agree with this matrix of course. A comment could be that there is a problem with the matrix size limiting the options, especially for a sensitive product/process. If you compare with the matrix in Steve’s or my post, you can see a CCP is equally possible there (= a return to the subjective aspect). Nonetheless, if you are able to validate yr result to the auditor for an analogous process, this should help, can you? (I rather doubt the auditor wud accept the one here as a valid xref (no lit.ref. ) but maybe ??)

Rgds / Charles.C

added - BTW - @Madam A. D-tor - Yr English is excellent and yr posts are very much appreciatd

[cazyncymru]

This is the matrix i use

My front page has all of the relevant legislation on it.

Word of advise, we have a supporting document to our HACCP plan, which this is in, but during my BRC audit, it was recommended that i put this into the actual plan.

New link added 10022008 to replace broken original / Charles.C -

 haccp_matrix_cazx_risk_analysis.xls   17KB   905 downloads

( also available as No3 in Ch.C post in this thread ca 09022008 )

[Charles.C]

Dear All,

Just as an illustration that small does not necessarily mean simple, here is an official 3x3 matrix developed for the Dutch Animal Feed Industry (2000) HACCP manual (particularly see pages 17-20). Contains some elegant text and some thoughtful analysis regarding implementation IMO. I think some of the concepts presented here might have contributed to the approach presented in the ISO 22000 Standard ?

LINK BELOW HAS REPLACED ORIGINAL LINK WHICH WAS BROKEN (charles.c/09022008)
 haccp_animal_feed_manual.pdf   1.59MB   504 downloads

Rgds / Charles.C

[Jean]

Dear All,

I have attached a matrix which is used to determine the significance of hazards in food safety.


BR,

J

Attached Files

•  Microsoft_Word___Hazard_significance_matrix_for_food_Safety.pdf   58.32KB   912 downloads

[Charles.C]

Dear Jean,

Thks for sharing. Always interesting to see what people use.

Nice to see that cell “1E” =11. Many would probably have chosen 10. This would then require changing several others to maintain symmetry of course.
Yr choice of categories like product recall is perhaps a bit debatable here since could be caused by a non- food safety defect also ?
Just out of curiosity, how would you rate the severity of a Staph.aureus infection ? 2.5? (I once saw a reference with a clever added comment that in the event of a split, a microbiological defect always took the more serious option, convenient but may give undesired conclusions regarding the control workload )

Any similar validating reference?

Best Regards / Charles.C

[Jean]

Dear Charles,

I do not have any validating reference, moreover I happened to get this matrix recently. As you said, product recall can be due to non-food safety reason in the manufacturing industry like in-correct labelling etc.. but in catering I havent seen a product re-call yet...

I would rate the severity of Staphylococcal food poisoning as "customer complaint", as it results in acute illness and most of the people get over it within a day and rarely any deaths reported.

Thats how I would think, what do you comment ?

I am sure many people will give a different rating....

BR, J

[Charles.C]

Dear Jean,

I agree that a range of opinions is inevitable.

The ICMSF (1986) previously issued a sort of relative ranking of pathogens and as you suggested, I think from memory S.aureus was in the 2nd or 3rd tier (the top rank included items such as S.typhi, V.cholerae). This table (and modifications) has been used in some HACCP presentations, eg –

"Severity
Severity is the magnitude of a hazard or the degree of consequences that can result when a hazard exists. Disease-causing hazards can be categorized according to their severity. One system uses the categories of:
• High (life-threatening) - examples include illnesses caused by Clostridium botulinum, Salmonella typhi, Listeria monocytogenes, Escherichia coli 0157:H7, Vibrio cholerae, Vibrio vulnificus, paralytic shellfish poisoning, amnesic shellfish poisoning
• Moderate (severe or chronic) - examples include illnesses caused by Brucella spp., Campylobacter spp.. Salmonella spp., Shigella spp.. Streptococcus type A, Yersinia entercolitica, hepatitis A virus, mycotoxins, ciquatera toxin
• Low (moderate or mild) - examples include illnesses caused by Bacillus spp., Clostridium perfringens, Staphylococcus aureus, Norwalk virus, most parasites, histamine-like substances and most heavy metals that cause mild acute illnesses"

(module 6 in http://www.fao.org/d...00.htm#Contents )

On the other hand, this is an extract from some material I found on the CFIA website some while ago – used for a 3x4, Sv-Lkh matrix -

“The Health Risk Assessment Model is a tool which may be used by the inspector/auditor as guidance when evaluating the health risk of a product.
The model uses Severity of Consequences (horizontal axis) and Likelihood of Occurrence (vertical axis) to determine the rating for deficiencies which impact on health and safety.
The Severity of Consequences for an identified hazard is set based on the health outcome. (Subclinical = low, temporary disability = medium, permanent disability/death = high). As well, severity of consequences is based on the worst case scenario as it relates to the health of the end user eg., microbiological pathogens will always be categorized as high whereas physical hazards will usually be categorized as low or medium.
The Likelihood of Occurrence is the vertical axis which relates strictly to the hazard likelihood that it will appear in the product (i.e. likelihood that the end user will be exposed to the hazard identified). This will be influenced by items such as in-plant process controls, type and use of product, target group, regulatory requirements, complaint file, plant history and other relevant information eg., a metal hazard due to defective equipment prior to a metal detector will be categorized as low, whereas without a metal detector it will be categorized as high.”

I would guess that this second approach where pathogens tend to be lumped together as “high” with respect to severity is more common due to simplicity (and possibly more pragmatic with respect to the auditor – no need to confuse him with microbiological subtleties, after all it’s all subjective, right ?).

Personally I tend to follow the second style so probably higher than you, 2-C/D perhaps (though I wouldn't use the "product recall" as a classifier myself).

Regarding comments in an earlier post about high severity and low likelihood I found this viewpoint –

 risk_matrix_use.jpg   19.19KB   157 downloads

Rgds / Charles.C

[Jean]

Severity -Severity is the magnitude of a hazard or the degree of consequences that can result when a hazard exists. Disease-causing hazards can be categorized according to their severity. One system uses the categories of: • High (life-threatening) - examples include illnesses caused by Clostridium botulinum, Salmonella typhi, Listeria monocytogenes, Escherichia coli 0157:H7, Vibrio cholerae, Vibrio vulnificus, paralytic shellfish poisoning, amnesic shellfish poisoning • Moderate (severe or chronic) - examples include illnesses caused by Brucella spp., Campylobacter spp.. Salmonella spp., Shigella spp.. Streptococcus type A, Yersinia entercolitica, hepatitis A virus, mycotoxins, ciquatera toxin • Low (moderate or mild) - examples include illnesses caused by Bacillus spp., Clostridium perfringens, Staphylococcus aureus, Norwalk virus, most parasites, histamine-like substances and most heavy metals that cause mild acute illnesses"

Dear Charles,





Thank you so much the very valuable information. I think this ranking from ICMSF(1986) would be apt when considering risk assessment matrix for microbiological hazards. Do you have the link for this? <

(module 6 in <A href="http://www.fao.org/d...0.htm#Contents" target=_blank>http://www.fao.org/d...htm#Contents.On the other hand, this is an extract from some material I found on the CFIA website some while ago – used for a 3x4, Sv-Lkh matrix –

The link above refers to the principles and methods of training and module 6- 'Types of training aids and how to use them'. This was indeed a useful one for me too as I prepare a lot of training slides for the company. I would like to see 3x4, Sv-Lkh matrix as you mentioned though I didnt see it in the link.

The Severity of Consequences for an identified hazard is set based on the health outcome. (Subclinical = low, temporary disability = medium, permanent disability/death = high). As well, severity of consequences is based on the worst case scenario as it relates to the health of the end user e.g., microbiological pathogens will always be categorized as high whereas physical hazards will usually be categorized as low or medium.

Can you suggest some examples which are rated as "temporary disability"? How about Chemical hazards like excess chlorine in potable water or during; improper sanitization (above 100ppm -200ppm

Last of all, do you recommend considering viruses (Hepa-A or Norwalk virus) while doing the hazard analysis



I agree with you when considering the high severity for all pathogens 2-D (in my case) and also product recall does not really suit catering industry as the foods are consumed faster compared to manufacturing.

Regarding comments in an earlier post about high severity and low likelihood I found this viewpoint

Thanks for your comments regarding Severity- High; Likelihood- Low, so in my previous case I can say the hazard is not significant.



BR



J

[Charles.C]

Dear Jean,

(1) The ICMSF ref is a book -
International Commission of Microbiological Specifications for Foods (ICMSF) 1986. Microorganisms in Foods 2. Second Edition. Sampling for Microbiological Analysis: Principles and Specific Applications. University of Toronto Press. Toronto, Canada.
The part I quoted derives from their own risk modeling procedure using Severity / Likelihood of occurrence categories particularly aimed at proposing appropriate sampling schemes. A representative part of this section is reproduced here (see pgs 34-37)

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 fh03_08e.pdf   270.03KB   531 downloads

(Eg, quoting pg 34 - “3. Sampling plans
In ALINORM 97/13 Appendix III, in developing sampling plans, the severity of the hazard and
assessment of the likelihood of its occurrence must be considered. A scientific rationale for the
development of sampling plans has been developed and published by the ICMSF (1986).
The ICMSF approach distinguishes three categories of hazards based upon the relative degree of
severity :
_ severe hazards,
_ moderate hazards, potentially extensive spread,
_ moderate hazards, limited spread.)”

(2) The risk matrix link (+ my quoted cfia text) is at –

http://www.inspectio...nue/app3e.shtml

(a similar (I think) matrix is also embedded somewhere within the text of the fao link )

(3) “temporary disability” – it all depends on yr own methodology of course but yr chlorine comment probably comes more within the pre-requisite area ( nowadays anyway). Perhaps a stone incident might cause short term incapacitation (dental )?. I’m rather unclear myself as to the exact use of “subclinical”.
As usual, after their (CFIA) detailed introductory presentation, there are no illustrations of it’s exact use for risk analysis in the (otherwise) excellent HACCP plans then presented. This is IMO one of the disadvantages of the D- tree method, it’s a bit too convenient.

(4) Viruses- Yes, but depends on the case as usual , eg –
http://www.fao.org/d...743e06.htm#bm06

(they appear in the category of “moderate hazards – potentially extensive spread” in one version I have seen of the above ICMSF ref )

Rgds / Charles.C

[Jean]

Dear Charles,

Viruses- Yes, but depends on the case as usual , eg –
http://www.fao.org/d...743e06.htm#bm06

(they appear in the category of “moderate hazards – potentially extensive spread” in one version I have seen of the above ICMSF ref )

I have found the list of pathogens that have been categorized as severe hazards and moderate hazards (limited and potentially extensive spread) which was adapted from the ICMSF (1986).



Severe Hazards



Clostridium botulinum types A, B, E, and F

Shigella dysenteriae

Salmonella Typhi; paratyphi A, B

Hepatitis A and E

Brucella abortus; B. suis

Vibrio cholerae 01

Vibrio vulnificus

Taenia solium

Trichinella spiralis



Moderate Hazards: Potentially Extensive Spread



Listeria monocytogenes

Salmonella spp.

Shigella spp.

Enterovirulent Escherichia coli (EEC)

Streptococcus pyogenes

Rotavirus

Norwalk virus group

Entamoeba histolytica

Diphyllobothrium latum

Ascaris lumbricoides

Cryptosporidium parvum



Moderate Hazards: Limited Spread



Bacillus cereus

Campylobacter jejuni

Clostridium perfringens

Staphylococcus aureus

Vibrio cholerae, non-01

Vibrio parahaemolyticus

Yersinia enterocolitica

Giardia lamblia

Taenia saginata

I’m rather unclear myself as to the exact use of “subclinical”.

Sub-clinical disease: An illness that stays below the surface of clinical detection. A sub-clinical disease has no recognizable clinical findings. It is distinct from a clinical disease, which has signs and symptoms that can be recognized.

yr chlorine comment probably comes more within the pre-requisite area ( nowadays anyway)

Yes, I agree with you that Cl₂ in potable water is covered in the pre-requisites but the Cl₂ disinfectant used for vegetable sanitization is to be considered as a chemical hazard as this is a process step( I think this can be of medium severity). How about pesticides in fruits and vegetables (in excess)?



How about Aflatoxins? What do you suggest for this - severe or moderate (extensive spread) hazard? I wonder why this was left out ….. is it because the likelihood of occurrence was low? Just a thought!



BR,



J

[Charles.C]

Dear Jean,

Good searching. One practical problem is when an auditor asks how about severity if one also includes the legal aspect , all varieties of Salmonella then become serious pathogens (except perhaps in raw chicken / eggs [but not in all countries!]). It is not always easy to ignore the pragmatic variable .

Re - yr comment about application of chlorine to vegetables, pesticides etc. The interpretation probably comes back to choice of methodology again. There is a quite detailed thread on vegetable processing here - http://www.ifsqn.com...amp;#entry11687
which has some discussion on this and another thread on GAP/HACCP somewhere which discusses the handling of aflatoxins in a HACCP plan. I think the usual (pragmatic) approach is to invoke GMP, GAP, GHP basic requirements. Nonetheless, this is not compulsory since it's your HACCP, if one has strong enough opinions and you can validate yr viewpoint, it's up to you. A common result is that the chosen severity is perhaps "medium" or "high" however as long as you follow proper GMP etc then the likelihood parameter will probably be "low" and the conclusion "not significant" with respect to potential CCPs.

Rgds / Charles.C

[hitesh_1973]

would you please guide me to download the file risk assessment matrix file.

It may be very useful to me.

kinds rgds
Hitesh

Dear Charles / Madam D-tor ,

I am really thankful and glad for all your valuable inputs.

I agree with Charles that microbiological hazards should be specified, but in my case (catering industry) where HACCP is process based and have more than 2000 different menu and many with different methods of preparation and it would be too cumbersome to conduct a detailed HA for each menu in retail operations. I feel this can be better done in small restaurants.....

But we have categorized different products like Meat, seafood’s, poultry, diary products etc..and have specified the microbiological hazards like Salmonella in poultry instead of chicken sandwich, chicken curry etc....

Charles, anybody would be surprised / worried when they see risk assessment done with "M" and not "L" as long as the person does not work or know the operations of the particular facility.
My decisions were based on my observations during inspections, checking staff competency, operations (during different business seasons), kinds of consumers etc. which is again subjective.
Currently I am not using any risk matrix and have decided to work out in detail.

As Madam A.D-tor has mentioned risk assessment is theoretical. From my point I consider the severity "H" for vulnerable people who may consume foods likely to make them sick due to lack of awareness and finally blame the food processors / caterers. Moreover all the steps in the food flow are considered and have appropriate controls in place irrespective of whether it is a CCP or not.

I strongly agree that an auditor should assess hazard analysis and the responsible person should be able to give valid reasons and documents to support the decision.

I am already working on the review of HA to ensure no hazards have been missed and this thread has been very valuable.

Madam: Last of all, please I am not concerned about the English being used for communication all the comments from Steve, Bobby, Charles and yourself have been very much appreciated and benefited.

BR,

J

[Charles.C]

Dear Hitesh,

Welcome to the forum.

My apologies but I don't quite understand yr question. Could you give some more details?

Are you asking for additional suggested IT links related to risk analysis matrices ? Or a specific file already referred in this forum thread ? Or a recommended link from the previous posts - this may depend on yr particular application area ?

Please revert.

Best Regards / Charles.C

[Charles Chew]

I have found the list of pathogens that have been categorized as severe hazards and moderate hazards (limited and potentially extensive spread) which was adapted from the ICMSF (1986)

While it is imperative to fully understand the pathogenic impact of each species of micro-organism, it is also equally important to understand the level of infective dose of each species that could cause harm to adverse health impact. A moderate pathogenic hazard that has limited spread such as "bacillus cereus" is just as potent as a severely hazardous species.

FSMS is not just about severity, likelihood or risk - its about risk management as well which means "zero tolerance". Comments appreciated.

How about Aflatoxins? What do you suggest for this - severe or moderate (extensive spread) hazard? I wonder why this was left out ….. is it because the likelihood of occurrence was low? Just a thought!

There is a new quideline under Codex Alimentarius on this issue which is becoming a big issue now. Mycotoxins such as Fusarium, T-2, Ochratoxins etc are being looked into with seriously and it would become a bigger in tme to come.

Regards
Charles Chew