7 replies to this topic

[stephie]

Dear All:

Auditor comment:
No documented procedures established to ensure the HACCP Team was informed or involved on a regular basic in the evaluation of significant changes which have impact on the HACCP system.

For this statement, what I can reply to the auditor?
I need crate a new PRP?Any reference?

Thanks and I appreciated your assist.

Cheer,
Stephie

[Charles.C]

Dear Stephie,

IMEX, this topic is often part of yr HACCP system verification procedure. Do you have one ?

What standard is being audited ? Was the comment referred to any specific element / paragraph ?

Rgds / Charles.C

[stephie]

Dear Charles:

In the Only have PRP verification procedure.
Auditor based on MS 1480:2007 clause 8.1
If Charles have any reference for HACCP system verification, can i get a sample?
Thanks a lots!!

Cheer,
Stephie

[GMO]

You could put together a "pro forma" ie a sheet of questions and answers for new products (prior to trial) and another one for significant engineering works and another just for "changes" which don't get captured by either that has a question on it along the lines of "does the HACCP team need to be informed of this change?" and "if not, why?"

Also on every HACCP meeting, I have a question of "have there been any significant changes since the last meeting?" and "are there any changes planned before the next meeting"

You can then stick all that into a procedure to keep the auditors happy

I then find that the team are normally kept informed and very few things slip through the net although we have a small team which helps. It's also a good idea to have a reasonably senior member of staff as the HACCP team leader as then they are likely to be on the project and planning meetings about new works so they can have that in the back of their minds.

Edited by GMO, 01 November 2010 - 08:55 AM.

[Charles.C]

Dear Stephie,

I deduce that MS = Malaysian Standard. I noticed that Section 8 of the Standard you quoted = Verification. I have never seen this standard (detail) but it may list the range of items you are expected to include.

In practice, different standards usually hv some similar core requirements but may add different “extras”, ie variable scope.

The attachment below, see section 23.8 contains some typical basic requirements –

 USFDA seafood final rule.pdf   371.54KB   44 downloads

Maybe the auditor expected to see some record for maintaining yr awareness of internal safety events such as a review of yr corrective actions file or external current safety events such as input from a journal scan / government information source / seminar attendance.
Some people prepare a table, eg item / responsible for activity / frequency / further actions if required / signature.

Sometimes a little imaginative reporting is necessary.

Rgds / Charles.C

PS - GMO's idea is good as well, provided you have enough people for a meeting

PPS - this one is similar but not quite the same -

http://edis.ifas.ufl.edu/fs143

[GMO]

What you don't have HACCP meetings because people don't turn up? That never happens!!!

Yep, Charles is right. I also keep a file which includes all alerts from our head office, FSA and FDA which are in similar food groups or which could impact on the factory. I then sign and date them and write on what other action needs to be taken if necessary. In my area there hasn't been any alerts which have been referred to the HACCP team, however, if I worked in ready meals as I did some years ago, I'm sure this would be a topic which came up in every HACCP meeting.

[D-D]

I have put together a Change Control procedure that hopefully addresses this sort of thing (together with a product development system) and flags HACCP issues, amongst others.
Nothing specificallty in the BRC standard (our goal) that calls for a Change Control system - surprisingly.

[stephie]

Thanks!!this may help me lots..