12 replies to this topic

[jeremyyap]

Hello,

I need to know do we need to re-do the Product CCP validation? If yes, how frequent? Any relevant guidelines?

Thanks & Best Regards,
Jeremy Yap

[cazyncymru]

Hello,

I need to know do we need to re-do the Product CCP validation? If yes, how frequent? Any relevant guidelines?

Thanks & Best Regards,
Jeremy Yap

I have a funny feeling i may have already posted a log for validation in the documents exchange.

I carry out a revalidation annually.

caz x

[jeremyyap]

I have a funny feeling i may have already posted a log for validation in the documents exchange.

I carry out a revalidation annually.

caz x

Hello Caz,

I need to know why you carry out the product re-validation annually? Is there any guideline you refer?

Besides, how about product process re-validation such as cooking, frying and etc? What is the frequency?

Best Regards,
Jeremy Yap

[cazyncymru]

Hello Caz,

I need to know why you carry out the product re-validation annually? Is there any guideline you refer?

Besides, how about product process re-validation such as cooking, frying and etc? What is the frequency?

Best Regards,
Jeremy Yap

BRC 1.6 "The review process shall be undertaken at appropriate planned intervals, as a minimum annually, to ensure critical evaluation of the food safety plan and the HACCP's systems suitability, adequacy and effectiveness"

BRC 1.7 "The review process shall include the evaluation of
**** Process performance and deviation from devined parameters"


Hope this helps

Caz x

[Eya]

I agree, you need to re-validate CCP every year. This is needed because validation is done per CCP per Machine/process.
Example
1.CCP is metal detector if you have 66 metal detector you need to validate each of the machine.
2. CCP is allergen if you have 5 process and 5 lines you need to validate each line and each processes.

For the other processes, you should include in your CCP validation a form to check all SOP and prerequisites (SCP,GMP,GWP,GEP etc.) are being followed.

[FSSM]

I do not know which system are you following (BRC, SQF, etc.), but you also have to consider to document any change to the process, and revalidate if the change is significant to food safety. This could be in less than one year from the last validation.

Regards,

FSSM

[Madam A. D-tor]

BRC 1.6 "The review process shall be undertaken at appropriate planned intervals, as a minimum annually, to ensure critical evaluation of the food safety plan and the HACCP's systems suitability, adequacy and effectiveness"

BRC 1.7 "The review process shall include the evaluation of
**** Process performance and deviation from devined parameters"

Dear Caz,

The review you are referring to is the management review.
The management review has IMO nothing to do with CCP validation.

CCP-validation in BRC is found in requirement 2.8.3: The HACCP food safety team shall validate each CCP. Documented evidence shall show that the control measures selected are capable of consistently controlling the hazard to the level specified by the critical limit.
and in 2.13.1: The HACCP food safety team shall ensure that procedures exist to review the HACCP plan prior to any changes which may affect product safety.****** Appropriate changes resulting from the review shall be incorporated into the HACCP plan, fully documented and validated.
and in 6.1.1: A process shall ensure that all Critical Control Points and specified limits identified through HACCP are transferred into day-to-day production controls and are fully validated.

Therefore my answer to the original question from Jeremy, would be: "with every change".
Make sure the validation is documented and motivated. This makes it easier to recall why some decisions have been made in the past. (based on what standards and which historical data)

The evaluation of the process performance in 1.7 is verification. A review of the performance but specially the deviations in the last period.

[Zeeshan]

Dear Madam A. D-tor!

Well investigated!

In line with the question asked, what's your opinion regarding the following clause:

2.13.2: Irrespective of any of the above changes, the HACCP plan will be reviewed at least annually and records shall be maintained.

Does it mean irrespective of any change, all the CCP's should be validated at least annually?

Regards:
Zeeshan

[Madam A. D-tor]

what's your opinion regarding the following clause:

2.13.2: Irrespective of any of the above changes, the HACCP plan will be reviewed at least annually and records shall be maintained.

Dear Zeeshan,

IMO this is about review of the HACCP-plan. This can be interpret as evaluation of the HACCP-plan or a review (reconsideration) of the Hazard and Risk Analyses.
The first interpretation is also included in 1.7 (- reviews of the HACCP-based system) and partly in 2.11.1 ( review of records where acceptable limits have been exceeded).

It does IMO not include CCP-validation. For CCP-validation you have to proof (by scientifically literature, practical expedience, experimental data, challenge tests, modelling programs, etc) that the monitoring method, the frequency, the limits, the corrective actions etc. are able to produce safe food.

[cazyncymru]

Dear Zeeshan,

IMO this is about review of the HACCP-plan. This can be interpret as evaluation of the HACCP-plan or a review (reconsideration) of the Hazard and Risk Analyses.
The first interpretation is also included in 1.7 (- reviews of the HACCP-based system) and partly in 2.11.1 ( review of records where acceptable limits have been exceeded).

It does IMO not include CCP-validation. For CCP-validation you have to proof (by scientifically literature, practical expedience, experimental data, challenge tests, modelling programs, etc) that the monitoring method, the frequency, the limits, the corrective actions etc. are able to produce safe food.

During our annual review of the HACCP plan, I also review and validate the CCP's.
We also do this for any changes we may have, be it processing, packaging or ingredient.

This way then, we keep the auditors happy!

[Zeeshan]

During our annual review of the HACCP plan, I also review and validate the CCP's.
We also do this for any changes we may have, be it processing, packaging or ingredient.

Dear Caz

As a standard practice, for CCP-validation we have to proof by some valid means that the monitoring method, the frequency, the limits, the corrective actions etc. are able to produce safe food. The valid means may be scientific literature, practical expedience, experimental data, challenge tests, modeling programs, etc.

I think if we have satisfactory verification results throughout the year with no internal changes, no new scientific research etc, there would be no need to re-validate the CCP, especially if it involves expensive experiments/test or modeling. Once a method, frequency, the limit or action is proved to be valid for controlling a particular hazard or a combination of hazards it will continually be valid forever until and unless :

1- Any influencing factor is changed. (such as change in raw material)

2- Or the Source or Reference of validation process is changed (such as advancement in scientific research).

Referring to the comments of Madam A. D-tor related to clause 2.13.2, I came to this conclusion that irrespective of any internal or external changes we have to review HCCP plan (not for CCP validation but) to reassure ourselves that all things are going on as planned -and- to incorporate new ideas to improve the effectiveness of the plan.

Regards:
Zeeshan

[rahul]

From my point of view,

revalidation could be performed when there is a change in process design/addition or subtraction of any particular ingredients/inclusion of new equiments or machinery/or
due to any new hazards identified by the community or added in the new legislation or as required by the legal authorities.

Review and revalidation are things which have to be discussed in different contexts.

Review has to carried out as per specified intervals as followed by the respective standard or guidelines. and i am sure you all will agree with me in the fact that with out any changes as mentioned in the first paragraph, doing the validation exercise again is a bit painful exercise which involves man power/ money and time!!!!!!

Rahul

[Tony-C]

During our annual review of the HACCP plan, I also review and validate the CCP's.
We also do this for any changes we may have, be it processing, packaging or ingredient.

This way then, we keep the auditors happy!

Sounds like good practice

Keeping auditors happy seems a good idea too!