ISO 22000 poll - HACCP options - 7.4.3 ?

Dear All,

I’m hoping that you lucky people who have succeeded in already acquiring certification to ISO 22000 will share a fragment of yr audit experience to (hopefully) benefit other potential applicants.

Not a user myself but based on questions to this forum, I think that the most difficult interpretational area is centred around the HACCP and HACCP extended areas, ie paragraph 7.4. Most of the queries have been for 7.4.3 / 7.4.4 and I hv initially picked the less contentious xx.3 to develop a small poll.

The objective is simply to get an idea as to the range/ relative frequency of possibilities which auditors hv found acceptable as a response to 7.4.3. Similarly the geography section is deliberately set very general for shy folks. For any new poll users, you can make one entry into each main section. The items listed are, IMO, all acceptable based on the text of the standard and include the main categories which I could think of. Expansion is possible but I have tried for maximum simplicity to avoid putting people off.

“a” = standard Codex decision tree + documented Q1,Q2 etc Yes/No data
“b” = documented data (letters or numbers) of [probable occurrence (likelihood)(L) / severity (S)] of hazard
“c” = decision rule for product of L x S (usually numbers)
“d” = Risk matrix (letters or numbers)
“e” = Risk matrix action rules (letters or numbers)

It will be observed that I hv left the question as to the precise continuation from the above undefined (eg, can compare to Bennii’s approach). This was deliberate, am only trying to get an overview here.

Hope this is not too complicated and thanks for any input. Any queries welcome (or spotted errors / impossibilities ).

Rgds / Charles.C

Charles has spent some time here attempting to clarify what is expected in this area.

Come on ISO 22000 users please help him out by answering the survey.

regards,
Simon

“a” = standard Codex decision tree + documented Q1,Q2 etc Yes/No data
“b” = documented data (letters or numbers) of [probable occurrence (likelihood)(L) / severity (S)] of hazard
“c” = decision rule for product of L x S (usually numbers)
“d” = Risk matrix (letters or numbers)
“e” = Risk matrix action rules (letters or numbers)


Rgds / Charles.C

Hi Charles,
All of these options are guidance only (including "a"), all CCP and opPRP could be selected by any method but after that all control measures has to comply with:

7.5 (or 7.6), 7.10.1, 7.10.2 and 8.2

Saludos.

Dear Erasmo,

Apprciate yr comment but perhaps my post was not sufficiently clear. The poll was not intended to extend to the selection of oprps, only 7.4.3 (ie approx. half way down the 22004 decision tree). I’m sure you are not suggesting that the oprp decision can be made without considering the requirements of 7.4.4. Nonetheless, many thanks for the feedback.

Rgds / Charles.C

Dear Erasmo,

Apprciate yr comment but perhaps my post was not sufficiently clear. The poll was not intended to extend to the selection of oprps, only 7.4.3 (ie approx. half way down the 22004 decision tree). I’m sure you are not suggesting that the oprp decision can be made without considering the requirements of 7.4.4. Nonetheless, many thanks for the feedback.

Rgds / Charles.C

Hi Charles,
I'm going to share with all what happened recently with an auditee:
They use one of the Risk Matrix perfectly detailed, with that tool only they make the selections. The result: they selected some control measures that not comply with validation (8.2) and Corrective Actions (7.10.2). (2 Major NC)
Let me try to explain requirement 7.4.3 and the 22004 desicion tree. If you see the requirements, there are 2 paragraphs, the second one is reflected in the second box of the tree. The first paragraph (that has to be performed after the second one) are "reflected" on the following 2 desicions. and for that 2 questions the FS team has to check the requirements.

In fact, Validation has to be performed BEFORE clasification (CCP or opPRP).

Saludos

“a” = standard Codex decision tree + documented Q1,Q2 etc Yes/No data
“b” = documented data (letters or numbers) of [probable occurrence (likelihood)(L) / severity (S)] of hazard
“c” = decision rule for product of L x S (usually numbers)
“d” = Risk matrix (letters or numbers)
“e” = Risk matrix action rules (letters or numbers)

Dear Charles..

IMEX.. we use "b" and "C" to state that potential hazard is Significan or not. if the hazard is significant we continue to "a".. if the hazard is not significant we control it with PRP... at the procees "a" we decide the hazard is CCP or OPRP... and we use "d" and "e" as supporting doc. for "b" and "c"...

so we use a + b+ c + d + e..

Thks for the above responses and to the pollsters contribution.

@Erasmo - I guessed when I put the poll together that its usage was not going to be that easy due to the various side-issues related to the standard’s textual presentation. Particularly the consequences of the “dotted line and linkages” in the 22004 decision tree as you discuss. I noticed the dotted line has been removed in Didier Blanc’s later publication (and the word "prior" prefixed to "validation" as in the standard).
I agree that even for the traditional HACCP methodology, although it may not appear as such in the “smoothed” Codex flow scheme, the validation function always becomes circular (reflected) in reality, together, I suppose, now with 7.4.4.

AS NUR’s post suggests that alternative interpretations are also perhaps in use.

Was not my intention (yet) in this thread to dive in to any detailed discussions on the recurring oprp topic however I would say that Bennii’s type of presentation seems to avoid some of the standard’s subtleties which Erasmo has (correctly IMO) noted in the sense of offering a smooth flow path however, by omission, it dodges the implications of 8.2 et seq. I found Bennii’s initial procedure for selecting PRPs a bit debatable also since it seemed contrary to the ISO 22000 definitions to me. Nonetheless I get the impression that some people hv been (successfuly?) using its ideas.

Rgds / Charles.C

Thks for the above responses and to the pollsters contribution.

... I noticed the dotted line has been removed in Didier Blanc’s later publication (and the word "prior" prefixed to "validation" as in the standard).

Rgds / Charles.C

Charles,
What is that publication? - can you share it with us or is a CR document?

Dear Erasmo,

I think you hv probably seen this document many times before (under different name maybe ) –

http://www.iso.org/i...n_ims_06_03.pdf

And my partial memory error, “prior” only in the table, not the figure, sorry.

Can see the position of the validation box has changed relative to 22004 but the content of table attached still agrees with yr comment and the standard. Curious.

Rgds / Charles.C