20 replies to this topic

[garryrana72]

Hi everyone,
Back to basics again. I am working with a company making dry blends/ seasonings for meat, bakery, soups etc. We are in process of getting SQF certification. While reassesseing our HACCP plan, I am stuck with a very small question. Shall we consider hair & dirt as Hazards? In my previous jobs, though not in Canada, we never considered dirt & hair as hazards. Now, the CFIA (Govt.) food inspectors recommend that dirt & hair be included in my hazard analysis, even the generic HACCP plans made by CFIA has both of them included as hazards.
Further, there is no known risk associated with hair & dust nor could any one guide me to any literature indicating hair & dust as the cause of food safety failure hence, I personally am not convinced about the "likelihood" of the risk. Can any one comment?
Regards.

[AS NUR]

IMO.. you have to calculate the severity and probability of Dirt and Hair.. i am sure that Probability is high but the severity is low ( i never heard people die cause of hair and dirt)... so.. they can't be hazard to controled by CCP.. but you have to control the hair and dirt with GMP ( PRP in ISO 22000)...

rgds

AS Nur

[Fparedesh]

Hello,

I think you are confuse about the hazard, Hair and dust are not phisical hazard; it could be the way (vehicle) to introduce a microbiological hazard.

If you put hair and dust in petri plate, you would scare.

I hope it served you.

pd. sorry for my english.

[GMO]

I agree with Fparedesh that hair and dirt are probably more likely to be a source of microbiological contamination (hair particularly S. aureus I would think) but normally both of them could be easily controlled by prerequisites. For the "dirt" though, I'd be very specific about what kind of dirt and where it could be from. For example, if the "dirt" includes wood splinters for example, that could be a physical hazard and also by identifying where it's from, you are more likely to be able to identify what kind of pathogens it contains. I've also taken swabs of items covered in dust before to see what the loading is like (surprisingly low actually). If you decide that "dirt" is not a significant food safety hazard, you could have a separate quality plan where you consider it as a quality but not safety risk.

[Simao Monteiro]

Hi all,

I you are thinking of hazards that should be in the Hazard analysis, IMO you don't need to consider those hazards. The aim of hazard analysis is identify and record all the potential hazards that are reasonably expected to occur at each step in relation to product, process and facilities which may not be controlled by existing pre-requisites. So, air & dirt should be controled bey PRP.

I hope this was helpfull.

K

[Simon]

As a consumer I certainly wouldn't want to find a hair in my food product. Sure it wouldn’t cause me physical harm, but maybe a little psychological damage (disgust). I would not purchase the product again and would tell my friends and family. Does HACCP consider psychological damage as “harm”.? Whether categorized as foreign body or microbial hair should and can be controlled with a reasonable amount of time, effort and money. So it should be.
I’ll leave dirt to the experts.

[garryrana72]

Hi group,
Forgive me, but don't we all base our HACCP knowledge on CODEX? which states hazard as "A biological, chemical or physical agent in, or condition, of food with the potential to cause an adverse health effect". Now my personal thinking is, to set the priorities right, HACCP should never be mixed with quality issues. Further, for me dirt is sand, mud etc. Let us keep it simple. I am not talking about the severity or probability or CCP, rather I am not able to get hold of some convincing argument stating hair and dirt are hazard or not.
Let me further add that I did my food safety training in europe, practiced for 12 years in a leading multinational making highly sensitive baby food in India but never we considered hair & dirt as hazard while doing the hazard analysis but here in Canada, surprisingly auditor after auditor insist for that. I am yet to get across a food safety issue reported due to hair & dirt as a physical of microbial hazard.
Hope you guys will further help me.
warmth,
garry

[Hillsie]

I found a synopsis for some research at http://www3.intersci...TRY=1&SRETRY=0.

OFF TOPIC:
I have been busy because of Passover and Shavot and expect to take some time off soon.

I will then get more involved in the topics.

Cheers.

Edited by Hillsie, 16 April 2010 - 01:57 AM.

[GMO]

I agree Garry. Unless it's actually a food safety hazard or source of one, it's not something you should include in HACCP even though it could cause disgust Simon. Disgust is a quality issue; therefore if you don't identify any hazards in it, the best place to consider it is a quality plan (doesn't mean you shouldn't consider it at all.)

[rosie]

Gosh - i would consider disgust as more serious than a quality issue - we have to trust our instincts and the presence of hair in a food does repel us - i've heard it said that there is a reason our noses are just above our mouths - millions of years of evolution - don't eat it if it smells bad.

Rosie

[Tony-C]

Hi everyone,
Back to basics again. I am working with a company making dry blends/ seasonings for meat, bakery, soups etc. We are in process of getting SQF certification. While reassesseing our HACCP plan, I am stuck with a very small question. Shall we consider hair & dirt as Hazards? In my previous jobs, though not in Canada, we never considered dirt & hair as hazards. Now, the CFIA (Govt.) food inspectors recommend that dirt & hair be included in my hazard analysis, even the generic HACCP plans made by CFIA has both of them included as hazards.
Further, there is no known risk associated with hair & dust nor could any one guide me to any literature indicating hair & dust as the cause of food safety failure hence, I personally am not convinced about the "likelihood" of the risk. Can any one comment?
Regards.

Hi Garry

Can you point me to where dirt and hair are referenced in the CFIA HACCP please.

As some people have already stated the hazard with dirt and hair is microbiological as they are synonymous with bacteria.

Regards,

Tony

[GMO]

Yep Rosie, I didn't mean it wasn't serious and as I said before, it can be a source of micro contamination, the thing is that many complaints (and many recalls) are associated with quality not food safety complaints so quality issues do need to be taken seriously, they just strictly should not be part of HACCP.

[Madam A. D-tor]

Let me further add that I did my food safety training in europe, practiced for 12 years in a leading multinational making highly sensitive baby food in India but never we considered hair & dirt as hazard while doing the hazard analysis but here in Canada, surprisingly auditor after auditor insist for that.

Dear Garry,

IMO hair and dirt should be considered. You must mention them in your hazard identification, cause it is a physical agent and it has potential to health effect. In your risk analyse you will find out, that the probability is high and the effect is low (too small for choking and no microbiological hazards known)
You have done some kind of risk analyse (maybe a small one, just in the head), cause you are convinced this is no risk. What is the problem of document this analyse/decision. Probably you have control measures in place (wearing headgear, prerequisites/GMPs).
On the other hand, IMO the effect of hair should be the same as contact with other parts of the human body. So have you considered personal hygiene, hand washing, etc.? Why is hair different?

I find it very strange that no-one has ever noticed that these basics are missing in your HACCP-study, but perhaps you were at one of these multinationals that are not certified but only conduct audits internally (these are very harsh, I know).
It would be on top of my list. On the other hand, if you do name personal hygiene or something as a hazard, I would assume this also includes hair.

Disgust is a quality issue; therefore if you don't identify any hazards in it, the best place to consider it is a quality plan (doesn't mean you shouldn't consider it at all.)

Hi GMO,

I do not understand this quality plan. Are you saying that you have a separate hazard identification and risk analyse for quality issues? What is the use of that? Does it not make things more complicated? How about the hazards that are considered food safety hazards and quality hazards? Do you name them in each plan with different effects? And how about the hazards that first are mentioned food safety hazards and then seems to be quality hazards? E.g. Moulds.
I have never seen separate plans for quality and for food safety. Only integrated ones.

[FSSM]

Now, the CFIA (Govt.) food inspectors recommend that dirt & hair be included in my hazard analysis, even the generic HACCP plans made by CFIA has both of them included as hazards.

Garry,

They recommend them to be include in hazard analysis, then, include it, what is the result of your analysis? I suppose no CCP because you have control measures, like GMP´s.

Further, there is no known risk associated with hair & dust nor could any one guide me to any literature indicating hair & dust as the cause of food safety failure hence, I personally am not convinced about the "likelihood" of the risk. Can any one comment?
Regards.

Would you produce baby food in an equipment with hair and dust? what would be the result (besides the quality issue)?

If there is no litterature available, then we should conduct our assesment to find evidence.

Regards,

FSSM

[Charles.C]

Dear All,

I wonder if any of the previous tolerances wud change if it was a rat hair ??

Nonetheless, I predict that most of us hv never encountered gary's specific difficulty ?

Surely this is usually classified within hygiene related controls, eg SSOP, SOP, PRP whatever. Must say I hv used the HACCP plans at cfia website many times but never noticed these items discussed within any HACCP plan itself (although the PRP documents are technically part of the HACCP System of course). I am interested to see the answer to Tony's query ?

In respect to Madam A.D-tor's comments, some companies now require HACCP to specifically analyse-categorise health / quality issues, eg Woolworths, Australia.

Rgds / Charles.C

[Rizwan Ahmed]

IMO the hair and dirt should be considered in the hazard analysis simply for the physical hazard category at each step of your processing line, but it would be considered as PRP and can be controlled by SOP's as risk associated with these hazards would be very low as well as the severity. probability of accurrence could be a bit high in some instanecs but is not very critical.


RIZ

[GMO]

Hi GMO,

I do not understand this quality plan. Are you saying that you have a separate hazard identification and risk analyse for quality issues? What is the use of that? Does it not make things more complicated? How about the hazards that are considered food safety hazards and quality hazards? Do you name them in each plan with different effects? And how about the hazards that first are mentioned food safety hazards and then seems to be quality hazards? E.g. Moulds.
I have never seen separate plans for quality and for food safety. Only integrated ones.

Yes. To a large extent the food safety and quality plans are separate. This is the approach recommended by Campden BRI in the UK to avoid people getting too hung up on quality issues rather than food safety ones when considering HACCP.

[garryrana72]

Surely this is usually classified within hygiene related controls, eg SSOP, SOP, PRP whatever. Must say I hv used the HACCP plans at cfia website many times but never noticed these items discussed within any HACCP plan itself (although the PRP documents are technically part of the HACCP System of course). I am interested to see the answer to Tony's query ?

For last couple of days, I have been reading all the CFIA generic plans from cover to cover, I myself could'nt find any such reference. The auditor, who mentioned me about this, also could not come out with any thing. Believe me, I have learnt a lot working with this topic and reading the posts of all the knowledgable members. To close the loop, just wanted to mention that now we are not at all considering hair & dirt as hazards in our plan, we want to keep it compact & simple & don'nt want to add any thing for just the sake of adding.
Cheers,
Garry

[mat_CL]

Hair & dirt: no
You have to manage it through GMP (written in a SOPs...control, frecuency, programs..checklist)

sorry 4 my english

[Dale P]

I do not understand this quality plan. Are you saying that you have a separate hazard identification and risk analyse for quality issues? What is the use of that? Does it not make things more complicated? How about the hazards that are considered food safety hazards and quality hazards? Do you name them in each plan with different effects? And how about the hazards that first are mentioned food safety hazards and then seems to be quality hazards? E.g. Moulds.
I have never seen separate plans for quality and for food safety. Only integrated ones.

To further expand on this, a HACCP based quality plan is also required for SQF 2000 level 3 certification. As far as making things more complicated and having repetition, there is the chance of that occurring. But items mentioned as food safety and quality hazards could have different severity dependant on the analysis.

[Charles.C]

Dear DaleP,

It would appear that for some reason best known to themselves, SQF hv decided to ignore all the archived discussions regarding the inclusion of quality factors (along with economic fraud) in HACCP which many years ago achieved a consensus to focus on safety only. Woolworths in Australia seem to be in league with the principle of SQF level3 also.

Now I've given them an opportunity for SQF level 4.

Rgds / Charles.C