8 replies to this topic

[npk]

Hi All,
Need some clarifications regarding implementation of HACCP. If we want to implement in a concern which does not actually produces the food but imports and trades to local consumers (e.g. Super markets, Hotels etc.) Does the requirements like Personnel requierements, Approved Food & Beverage suppliers etc. need to be addressed?
If no, then is there any article which will help me in preparing manual of HACCP for trading firm.
Please help me providing an example if any.

Thanks,

[Penard]

Hi npk,

where are you located, Europ, Asia...Requirements based on legislation depends on your location,

regards,

Emmanuel

[Jean]

Need some clarifications regarding implementation of HACCP. If we want to implement in a concern which does not actually produces the food but imports and trades to local consumers (e.g. Super markets, Hotels etc.) Does the requirements like Personnel requierements, Approved Food & Beverage suppliers etc. need to be addressed?

Dear npk,

IMO, yes you need to consider about the supplier approval program and performance monitoring as long as you are dealing with food. This is required to ensure the food being imported or exported does not contain any pathogens, toxic compounds, veterinary drugs etc. If you were my supplier; I would require you to provide me all the details about your food safety system procedures. I would ask for details and information of the product being imported and supplied to us as it the very important to ensure the food being received in any food facility is safe and is from an approved source. Incase of a re-call this information will help. (Refer Section 5.3 of CAC / RCP 1 -1969)

Personal requirements
Any person who comes in direct or indirect contact with food should not contaminate the food and transmit illness to the consumers. (Refer Section VII of CAC / RCP 1 -1969)

[Charles.C]

Dear npk,

As mentioned, the regulatory aspect depends where you are and the business involved.
One classic (and rare) detailed example is the import of seafood into USA. A national scheme was implemented several years ago in which importers were mandated to maintain HACCP documentation from their suppliers so as to be available for FDA scrutiny.
The specific expectations / justifications for the prerequisite programs and CCPs of HACCP plans are laid out in a series of specially commissioned documents, eg, for the HACCP part, see the "purple" book here -
http://seafoodhaccp....anuals_pdf.html

Rgds / Charles.C

[Jean]

Hi Charles,

Good and useful link.

Thanks

[GMO]

I know of a food distribution site which has had different answers from two environmental health officers about whether they need HACCP; one said yes, the other said no. I would have said yes.

As it happens, they are moving chilled food so you can automatically identify a micro hazard. Also there is a pest control prerequisite in place.

It might be short but if you can identify any hazards in your system, you need HACCP.

I don't know your process but here are some things you could consider:

Intake - hazard; presence of allegens due to product not being to supplier specification. Control measure; supplier quality assurance, suppliers have systems in place which are regularly audited to control allergens etc. You might require certificates of analysis for some ingredient hazards too. For some ingredients, the product might not be released until that CofA is checked and in spec in which case it might be a CCP or an oPRP.

Storage - hazard; growth of pathogenic bacteria, e.g. Listeria monocytogenes, due to storage at elevated temperatures. Control measures would be around temperature (might be a CCP), control of contamination at supplier sites etc.

HACCP is a worthwhile exercise and makes you consider your process and your controls. You shouldn't perhaps think about it this way but is worth the cost due to your ability to state a defence. I don't know if you recall the mouse found in a topic bar case in the UK? It was found to have come from a supplier site to Mars and because Mars had a supplier assurance scheme and their supplier hadn't told them about the pest control issues which had arisen; Mars were successful in their due diligence defence. If they'd not had a supplier assurance programme, they would have been liable. Supplier assurance is a prerequisite of HACCP.

[Jean]

I agree with GMO. 2 years ago when I went to audit a supplier for dry foods and found their premises had sightings of rodent infestation and birds nesting and cockroaches. The workers were even feeding the birds. My first action was to inform their MD and purchasing to stop the dealings with immediate effect .

[Charles.C]

Dear npk,

You might like to also hv a look at the comments in this similar 2005 thread -

http://www.ifsqn.com...?showtopic=1173

Rgds / Charles.C

[npk]

Dear Gurus,
Tons of thanks for providing the guidance. Sorry I was away from Office so could not join the forum.
Thanks.