2 replies to this topic

[Beautykees]

Hi all,

This question concerns a importer who imports nuts -vacuumpacked and gas flushed- into the EU. The nuts are not treated or unpacked, only shipped, stored at a (subcontracted, HACCP certified) warehouse, and sold. EU regulation 852/2004 requires every food operator (from import onwards) to implement an HACCP plan.

How does the HACCP plan allocate responsibilities with respect to subcontracted work? Is it sufficient to have a plan only at the warehouse, or is it necessary to draft a plan also for transport?

[FSSM]

Hi all,

This question concerns a importer who imports nuts -vacuumpacked and gas flushed- into the EU. The nuts are not treated or unpacked, only shipped, stored at a (subcontracted, HACCP certified) warehouse, and sold. EU regulation 852/2004 requires every food operator (from import onwards) to implement an HACCP plan.

How does the HACCP plan allocate responsibilities with respect to subcontracted work? Is it sufficient to have a plan only at the warehouse, or is it necessary to draft a plan also for transport?

As far as I know, HACCP from codex is not specific about subcontrated work, but talks in general about taking care of product during transportation and warehousing, so you should extend its recommendations to any external service if possible, if not, you should implement control measures to be sure product is handel correctly by that subcontractors.

ISO 22000 does mention some things about subcontrated work.

If transport is managed by you, then it is part of your responsibility, if not, make sure it has good conditions to keep product safe until it gets to the next part of the food chain.

Regards,

FSSM

[GMO]

If it is part of your responsibility the transport is part of the plan (or should develop their own plan perhaps if that works better with the organisational structure of your company.) If it's not, then the transport is like any other supplier and so should be assessed with self assessment questionnaires, possibly audited etc. You wouldn't expect to have your bread supplier as part of your HACCP plan in a sandwich factory, I think this is the same thing, however, possibly complicated by the distance / knowledge / competence of the supplier?