8 replies to this topic

[cristaleo]

Hello to you all, my first contribution (actually, first question )!

We're in the process to implement ISO 22000 - in the hazard analysis step. "Fortunately", two consultants are working with us: an "holistic" quality consultant that has been involved with our Quality System since the beginning, whose aim is to develop some integrated food safety system that works within our in place broader quality system, and then a newer "food safety" consultant, that has ministered the HACCP training and has been helping us in solving more detailed/specific questions related to it.

Ok, so they disagree in one important point: hazardf specificity. While the "holistic" says that you should mention "pathogen presence" as a hazard and then on the control measures you could stablish which one(s) you're set to control, the "food safety" says you should specifically determine which pathogen you're up to (such as L. monocytogenes, E. coli, Salmonella spp.,... so one) in the hazard and evolve your analysis from that.

I was looking around these forums and found some examples of both. So, what do you think? Go the for simplistic or the rigorous?

BTW, I understand that in the control measures, although you might mention some pathogen, they couldn't be used as a measure themselves, since it's not a rapid process measure. Is that correct?

[GMO]

I completely agree with your HACCP expert. In answer to your question "how specific should your hazard be?" I would say "as specific as you can make it".

The reason is because without fully identifying your hazard you cannot identify your control measure. It's back to front IMO to say you will specify at the control measure. Imagine this situation. You are setting up your HACCP plan and go through the entire hazard analysis first, I will use a physical example first. Imagine at one stage you identify "physical contaminants" but actually you mean "wood fragments from uncontrolled damaged pallets" (I know that's probably a PRP but bear with me). Later on in the process there is a subsequent step and you realise you have a metal detector and assume the "physical contaminants" will be picked up by that, but of course they're not.

Likewise you might have a dish which contains a chicken curry sauce and rice. Without thinking through your microbiological hazards fully you risk not considering that cooling time could be a really serious issue with b. cereus or that Salmonellae, Listeria and E. coli might be an issue with the chicken, it might also be an issue with C. botulinum depending on product life and packing method. I think waiting to look at control measures limits your thinking. As I indicated, you might need to not just think of the cooking temperature (and holding time) but also the cooling time and temperature. You might not think about the packaging format etc.

When I audit HACCP plans, one of the things I always check for is "does the control measure control the hazard which has been identified?" In your plan if you go with consultant 1, you can't tell so for me that's a problem.

Hmm, just started a glass of wine and I'm not sure if I'm making sense. What I mean is when you start any project it's useful to write down all your ideas, concerns etc. For me that's the hazard analysis stage. You then think about all the things on your project you will do to mitigate risks; that's your control measure stage.

I'd also (personally) be wary of getting side-tracked into quality issues at this stage. I would try and keep HACCP as separate from the rest of the quality system as you can for the time being. I've recently been through a new build project starting a HACCP plan from scratch and remember being side-tracked repeatedly by hour long arguments about whether dust was significant. Trust me when I say "keep it simple" for now.

[cristaleo]

The reason is because without fully identifying your hazard you cannot identify your control measure.

Hi, GMO, thanks taking time out of your wine (the one thing I miss the most being 8 months pregnant ) and answering my question.

The above is exactly what I answered the "holistic" consultant.

And also thanks for the advice in keeping things separately - every time people try to insert a "hazard" into the plan, I ask: does that pose a health hazard? So, they have been tamed so far .

It's nice to hear that your line of thought is correct.

[George @ Safefood 360°]

Excellent Post GMO. The HACCP expert is of course correct. Your hazard analysis has to based on specific hazards for the following reasons:

1. If you don't know the specific hazards you're dealing with you can't know if your control measures are appropriate or adequate.
2. Risk assessment can be difficult when dealing with general hazards e.g. hazard characterization and exposure.
2. You cannot apply effective CCP determination since the standard Codex questionnaire relates to a specific hazard.
3. Validation of your HACCP plan (CCP's) has to be based on specific hazards e.g. target pathogens.

Your PRP program will address the general hazards associated with your product/process. HACCP is then used as a powerful tool to separate the specific critical hazards that are essential for safe food production.

Having said all that, there are certain practical issues relating to identifying specific hazards including the available data, expertise required for robust hazard analysis, time and resources. In some cases you will be forced to identify hazards generally but this should not deter you from making your HACCP study specific and robust as possible. The following website can be a useful resource...

http://www.foodrisk.org/

George Howlett.

[Ken]

Agree with your Haccp consultant - you need to be specific. I've seen too many haccp plans with hazards such as 'physical contamination'. That is a category of hazard and not a description of a food safety hazard. My question is what sort of physical contamination were you thinking of and where from / how could it contaminate?.......and then see blank faces!

[Tony-C]

Hello to you all, my first contribution (actually, first question )!

We're in the process to implement ISO 22000 - in the hazard analysis step. "Fortunately", two consultants are working with us: an "holistic" quality consultant that has been involved with our Quality System

Ok, so they disagree in one important point: hazardf specificity. While the "holistic" says that you should mention "pathogen presence" as a hazard and then on the control measures you could stablish which one(s) you're set to control, the "food safety" says you should specifically determine which pathogen you're up to (such as L. monocytogenes, E. coli, Salmonella spp.,... so one) in the hazard and evolve your analysis from that.

Get rid of your consultants would be my first tip.

When you are conducting your analysis you can use general or specific hazards. As long as you understand the risk and how to eliminate the risk there shouldn't be a problem.

Regards,

Tony

[Charles.C]

Dear Tony,

When you are conducting your analysis you can use general or specific hazards. As long as you understand the risk and how to eliminate the risk there shouldn't be a problem.

Quoting the usual Codex HACCP presentation (2003)-

In conducting the hazard analysis, wherever possible the following should be included:
• the likely occurrence of hazards and severity of their adverse health effects;
• the qualitative and/or quantitative evaluation of the presence of hazards;
• survival or multiplication of micro-organisms of concern;
• production or persistence in foods of toxins, chemicals or physical agents; and,
• conditions leading to the above.
Consideration should be given to what control measures, if any exist, can be applied to each hazard.
More than one control measure may be required to control a specific hazard(s) and more than one hazard may be controlled by a specified control measure.

If one follows the above logic, I think specific input is required.

With respect to the original post, a pragmatic reason is that auditors may have certain guidelines as to which HACCP features must be documented, not only to self-validate the existence of the auditee's knowledge but to act as a prerequisite for the proposal of an appropriate control measure. It's true that some implemented control measures are relatively generic in nature but others are oriented/designed for specific hazards, eg bacterial species.

Rgds / Charles.C

[GMO]

Get rid of your consultants would be my first tip.

When you are conducting your analysis you can use general or specific hazards. As long as you understand the risk and how to eliminate the risk there shouldn't be a problem.

Regards,

Tony

Hi Tony,

I don't understand that. Without knowing the specific hazard, how can you understand the risk? What general hazards would be ok? I have to admit where there are general hazards which are controlled by general PRPs because they've not been specific to the process step, I've stated this in a general hazard section but this is the only time I'd do it as otherwise I can't see the benefit?

[SriramB]

If one follows the above logic, I think specific input is required.

" It's true that some implemented control measures are relatively generic in nature but others are oriented/designed for specific hazards, eg bacterial species."

Rgds / Charles.C

Agree with Charles, as you are using a systematic tool (HACCP) to evaluate true risk to your product and plan control methods to mitigate same, it becomes value adding,only if you try to get as specific as you can (even though the task is difficult at times )

Generic risks can end up being disputed as they appear to be derived from common sense/ experience of individuals - consequently , others may not follow your thought process.

Also, with Generic - you may spend money (your shareholder's) on a control which is not really needed, when your product's inherent robustness is considered.

If getting to specifics proves to be a challenge, you might consider getting subject experts (from your company) to augment the Food safety team.

While documenting, I have seen specific hazards listed on their own or clubbed under a more generic heading, but the science is still available to be audited.

Cheers,