7 replies to this topic

[rosie]

Hi Everybody

We have almost finalised our HACCP plan - validated process flows, identified hazards and assessed risk - I have used Simon's 3 x 3 (Tried 5 x 5 but things got too complicated). However in Simon's example HACCP for direct packaging CCP is identified by risk level as opposed to going through the decision tree and I find using the risk level approach better. What do others think?

Rosie

[Charles.C]

Dear Rosie,

Zero CCPs ??

Rgds / Charles.C

[rosie]

Well you see I'm not sure.

Bearing in mind that we have to evaluate contamination risk, legality, consumer safety and functional integrity we certainly have a series of control points and some would be a higher risk rating from the SxL and therefore subject to more inspection etc - but where do I draw the line and say it is a CCP instead of just having control points of varying risk rating - where does the decision tree come in?

[Charles.C]

Dear Rosie,

Sorry but I don’t remember if this is for BRC or what ?

Regardless, although it’s very risky to generalise about an unknown set-up, you will probably hv realised that most of the packaging people here claim to only require zero or perhaps 1 CCP in their HACCP plans. Nonetheless, it’s still yr Plan.

Strictly, a proper hazard / risk analysis requires an in-depth study of the process. If you want a food example, try some of the NZFA examples on their website where they use FSOs. I think most people initially do something approximating this (bar the FSO) and then start looking for ways to simplify the presentation (the subjective element).

The matrix philosophy is highly subjective (perhaps totally in the central area). And so is the Codex tree since this implicitly relies on an analogous risk assessment basis. The 3x3 is ultra-minimalist but if it works as per the Simon test, clearly minimises labour. Unfortunately, on some occasions, it prevents making fine differences where you want to do so in order to differentiate between options (although most auditors will probably never notice these distinctions). Ultimately, IMO, people often choose matrix size for strictly pragmatic reasons – it enables a decision which agrees with validatable sources and (hopefully) one’s own opinion plus the auditor has no significant quibbles (which is rare anyway). The majority of clear-cut CCPs are probably well stated somewhere, and similarly the pre-requisites. So the remainder are probably somewhere in the middle and need a proper examination of the realistic situation but the subjective aspect is still omni-present within the guiding principle of minimising total number of CCPs.

Never used the tree because I didn’t like all the ambiguous (to me) questions but it has the advantage that the final format for CCPs seems well recognised and the rest just fall by the wayside. I got a bit worried when I heard a guy coming out of a (food) HACCP lecture saying “I didn’t realise it was so easy, you just have to get XXXX and it’s a CCP”. But in reality, the matrix approach is not that different in many cases.
Maybe it doesn't work at all for packaging due to the food oriented question structure (not a packing person myself). I seem to remember seeing this comment previously.

If you need specific risk opinions, will probably hv to give more detail.

Rgds / Charles.C

[Simon]

I agree Charles 3x3 is somewhat limiting, but also for packaging the risk to the consumer is much less than food and CCP’s in their true sense are probably not even applicable to packaging, although you might want to (and some do) use CCP’s to elevate a particular hazard that is more significant than the rest.

The important thing is that the packaging company sits down and conducts a methodical hazard analysis and risk assessment of the product and process with all relevant, competent people and they put suitable (adequate) control measures in place. For me the process of doing this is much more important than the precise detail or format to which it is done…as long as it complies with the requirements of the BRC packaging Standard of course.

Regards,
Simon

[rosie]

Thank you. I agree that CCP as in the food industry doesnt apply to packaging - I wish BRC had left the term out of the standard and just said control point.

To us, a high severity score will mean a defect on the packaging which renders it unusable as opposed to something that will cause major illness / injury to a consumer. For us, it is crucial to control these type of points.

[Charles.C]

Dear Rosie,

Well, maybe. It could also depend on what contamination may then result, what are the contents, how great the exposure, and to whom it occurs. And that's just for short-term defects !

Rgds / Charles.C

[rosie]

Hi Charles

More likely to be a domed base on a yogurt pot or pots not separating properly which won't even go down the customer's line let alone get filled with anything or reach a final consumer. Thanks for all you helpful feedback on this question - as long as I am not the only one who does not intend to use the CODEX decision tree.

Rosie.