7 replies to this topic

[Jon5]

All:

My company is working with European customers to convince them to accept FSSC 22000 in place of BRC and/or IFS. I've seen a good number of press releases indicating that the FSSC 22000 is the first GFSI standard to receive EA acceptance, which in my mind is a very good argument.

All the information I find on the web seems to point back to a newsletter posted on www.fssc22000.com. I don't see any "original" information that actually points back to an EA declaration or anything of the sort. Can someone direct me to some sort of "source document" from the EA that I can refer to? It would be very much appreciated. Thanks!!



Jon

[Tony-C]

All:
My company is working with European customers to convince them to accept FSSC 22000 in place of BRC and/or IFS. I've seen a good number of press releases indicating that the FSSC 22000 is the first GFSI standard to receive EA acceptance, which in my mind is a very good argument.

All the information I find on the web seems to point back to a newsletter posted on www.fssc22000.com. I don't see any "original" information that actually points back to an EA declaration or anything of the sort. Can someone direct me to some sort of "source document" from the EA that I can refer to? It would be very much appreciated. Thanks!!


Jon

Hi Jon

I have also only seen publicity from FSSC. The formal evaluation of conformity assessment schemes is a new process for the European co-operation for Accreditation and they have nothing indicating their approval as far as I can see from their website.

The FSSC scheme is still in its infancy and so I suspect won't be widely accepted for a while. At the moment it appears on unaccredited certificates are being issued. "Unaccredited certification is in principle not allowed from 1 July 2011. New certification bodies have nine months from the date of the letter of intent to become accredited."

I have made enquiries with UKAS (UK accreditation) and will let you know if I get anything useful from them.

I think you will have to be patient with your customers whilst the scheme develops and establishes itself.

Regards,

Tony

Edited by Tony-C, 17 December 2010 - 07:31 AM.

[Jon5]

Thanks Tony, I appreciate the help. You're right, we'll have to be patient. There are accredited bodies here in the US already, and after Jan. 1 they will be able to issue cetificates to companies audited. We'll see how things proceed.

Due to the nature of this standard, being based on an ISO standard, I have high hopes for it. I very much like some of the differences in this standard as compared to the other standards out there, specifically the food safety team and the introduction of oPRPs, both of which make your HACCP system more robust. Some companies will have already met these requirements, but many do not currently, so I'm glad they're specifically called out.

Jon

Hi Jon

I have also only seen publicity from FSSC. The formal evaluation of conformity assessment schemes is a new process for the European co-operation for Accreditation and they have nothing indicating their approval as far as I can see from their website.

The FSSC scheme is still in its infancy and so I suspect won't be widely accepted for a while. At the moment it appears on unaccredited certificates are being issued. "Unaccredited certification is in principle not allowed from 1 July 2011. New certification bodies have nine months from the date of the letter of intent to become accredited."

I have made enquiries with UKAS (UK accreditation) and will let you know if I get anything useful from them.

I think you will have to be patient with your customers whilst the scheme develops and establishes itself.

Regards,

Tony

[Charles.C]

Dear Jon,

Slightly OT ,

and the introduction of oPRPs, both of which make your HACCP system more robust.

Not sure exactly what you mean by robust. No offence intended but redundant is more the word that comes to my mind.

Personally, I have yet to see any claim, let alone objective evidence, that the introduction of OPRP has achieved any specific benefit with regards to food safety compared to traditional HACCP ? (Other than to boost paper usage perhaps).

Admittedly this lack may partly be due to the fact that the relevant text was concocted with such ambiguity that food safety forums are still arguing/ wasting their time (?) over the intended basic meaning 5 years later. I suppose one can at least give credit to ISO for internationally breaking the KISS concept.

If ISO had to proceed in the present 22000 direction, it would probably have been so much easier to simply present, with examples, a suitably modified version of Dutch HACCP as their chosen form in place of Codex. And rewrite/delete much of the gobbledygook of the notorious paragraphs (a-g).

Rgds / Charles.C

[Tony-C]

Thanks Tony, I appreciate the help. You're right, we'll have to be patient. There are accredited bodies here in the US already, and after Jan. 1 they will be able to issue cetificates to companies audited. We'll see how things proceed.

Due to the nature of this standard, being based on an ISO standard, I have high hopes for it. I very much like some of the differences in this standard as compared to the other standards out there, specifically the food safety team and the introduction of oPRPs, both of which make your HACCP system more robust. Some companies will have already met these requirements, but many do not currently, so I'm glad they're specifically called out.

Jon

Hi Jon

This might be of interest to you:

http://www.foodprodu...ter+Daily<br />
Regards,

Tony

[Jon5]

Thanks Tony.

Hi Jon

This might be of interest to you:

http://www.foodprodu...ter+Daily<br />
Regards,

Tony

[Jon5]

Charles:

Thank you for your thoughts. These are good discussions to have. You do make a good point; a company may simply implement some oPRPs in order to meet the standard, and not produce product that is any safer for it as a result.

Can I ask what OT means? My only knowledge of the term is "overtime."

The reason I believe that the concept may improve companies' HACCP systems is because it formally recognizes what is already being done by many companies in practice, and has been for many years. It recongnizes that in addition to fundamental environmental controls like pest control, and CCPs, there are process steps in the "middle" of this continuum that must also be controlled with a level of rigor. They're often called "quality control points" or just "control points." Well-concieved HACCP plans will, I believe, include these control points as something that is monitored, making the product safer. Companies that do not monitor these points in the process (I believe there are many) increase the likelihood of producing an unsafe product.

To clarify, as an example, if you have a 5-log reduction "kill step"in your process and you are refrigerating raw product for a brief period prior to the kill step, this refrigeration may not be recognized in your HACCP plan as a CCP. However if the refrigeration is not monitored and goes out of compliance long enough to produce a material with a 6-log count of microorganisms, you may be putting consumers at risk. This is just a made-up example off the top of my head, and may not be the best example.

Some food safety standards may directly require what they consider to be universal oPRPs, such as the glass & hard plastic policy requriements of the BRC and IFS. But they don't necessarily require that you implement control points specific to your particular process.

The way I see it, this concept more specifically calls out an industry best practice that is not clearly required anywhere else. It may require more paper (or more bytes of spreadsheet), but I believe it's the right thing to do. Just my two cents.

Jon

Dear Jon,

Slightly OT ,


Not sure exactly what you mean by robust. No offence intended but redundant is more the word that comes to my mind.

Personally, I have yet to see any claim, let alone objective evidence, that the introduction of OPRP has achieved any specific benefit with regards to food safety compared to traditional HACCP ? (Other than to boost paper usage perhaps).

Admittedly this lack may partly be due to the fact that the relevant text was concocted with such ambiguity that food safety forums are still arguing/ wasting their time (?) over the intended basic meaning 5 years later. I suppose one can at least give credit to ISO for internationally breaking the KISS concept.

If ISO had to proceed in the present 22000 direction, it would probably have been so much easier to simply present, with examples, a suitably modified version of Dutch HACCP as their chosen form in place of Codex. And rewrite/delete much of the gobbledygook of the notorious paragraphs (a-g).

Rgds / Charles.C

[Charles.C]

Dear Jon,

I appreciate yr response. I think I get the “drift” if perhaps not the total (my limitations solely ).

From a purely safety aspect, I think the stages within the continuum you refer are preferably interpreted in a risk / prerequisite context. Terms like Quality Control Points may or may not be safety related, often specifically not IMEX. Personally I think it is safer to simply exclude these terms from a HACCP-based discussion particularly due to their myriad of interpretations. (1/2 credit to 22000 ) An example of a more risk-based concept is (partially) contained within Dutch HACCP which has (curiously) many similarities to 22000, including a Dutch “OPRP”. One dis-similarity IMO is that it is fairly intelligible.

The practical/theoretical limitations of yr 5D, 6D, (and 12D!) examples are usually well-spelled out in the original texts but I agree that they tend to vanish in the subsequent user-manuals. i hv nothing against "control points" but I don't think they represent an excuse for misusing HACCP / risk assessment. I blame the propagation of this kind of "slip" on the auditors, it should be fully covered within validation. Eg You must risk assess / accommodate your baseline.

In the current context “best-practice” is maybe equatable to the achievance of a “satisfactorily safe” health result within practical / economic / educational constraints .?? The original haccp system tried to include slightly “lesser” ccps in the main scheme (ccp1/ccp2 procedure) but it faded away, maybe people didn’t like all the extra paperwork for little perceived benefit (can see it discussed in textbooks). Including the auditors maybe.

IMHO, a serious flaw in OPRP as presented in the standard (ignoring the crazy text) is that there is not a single suggestion as to what level of objectivity is targetted. We all know that even traditional HACCP is highly subjective but at least the range of risk uncertainty is discussed. For OPRP, AFAIK. Nada !!

Nonetheless, I respect yr opinion. I hope you don’t hv too many oprps to validate.

Rgds / Charles.C

PS sorry for slang, OT= Off-topic; IMEX = In My experience, CM = control measure, IMHO = in my humble (?) opinion, AFAIK = as far as I know
If you look in very first forum on main page there is a list of popular slang.