7 replies to this topic

[Laura8]

Hi All , I hope someone can help

I am fast approching our annual BRC audit, however I am not happy that we have Supplier Approval as a CCP. In my previous role in High risk we did not have it as a CCP. Does anyone agree with this or think it should be a CCP?


What will I need to document & demonstrate we don't think it should be a CCP?
All suppliers are approved wither its a CCP or not, and with in a year I have had no issues with suppliers that would verify approved suppliers should be a CCP.

Many thanks

[StuartMarriott]

Hi There

My initial thought it that Supplier Assurance has ended up as a CCP due to the interpretation of the decision tree question relating to 'step specifically designed to reduce hazard to an acceptable level..'. I would maybe question why 'supplier assurance' appears as step within your HACCP Flow! the process step relating to suppliers would ususally be 'Receipt & Storage of raw materials'.

This step would not be a CCP as it is 'not specifically designed to ...etc.' the purpose of this step is to physically get raw materials from the delivery vehicle into your stores.

To 'remove' this as a CCP you will need a HACCP review (so that the whole team approves any decision), during the review I would suggest you:
1) confirm the flow diagrams in which the step appears - you probably don't need a step for supplier assurance (see above)
2) once removed from your flow diagrams, make sure you account for supplier assurance within your pre-requisites - talking about supplier specifications, COA, COC etc. any testing / inspection you carry out on their deliveries.
3) see if, within your HACCP plan, you have risk assessed your raw materials? if not, you should draw up a risk assessment. (this is also a good place to capture allergens too)

You will not be devaluing any procedure by it not being a CCP any more. Without robust prerequisite programs your HACCP will become flawed.

Personally, I would try and review your plan before your audit – although it is YOUR HACCP plan and specific to YOUR operation, I would expect an auditor to challenge the HACCP Team’s thinking behind this step as a CCP.

Hope this helps

Stuart

[Laura8]

Thanks Stuart


We had had our annual HACCP review where it was discussed by the team & documented in minutes but was'nt sure if anythingelse needed to be used to justify the change.


Thanks

[Charles.C]

Dear Laura,

There are a large variety of (acceptable) ways to design and implement a HACCP system. BRC specifies to use a Codex based methodology however the latter is extremely flexible in many aspects if you hv a look at it. To more accurately answer yr query, some details of yr existing hazard analysis might hv been useful.

I agree with the previous poster that "Supplier Approval" is not usually a CCP however in many HACCP programs, it is my experience that the typical first "process" step, namely "Receiving Raw materials" is a CCP. The reasons may vary depending on the specific hazard analysis and the choice of method of HACCP implementation. I hv also occasionally seen "Purchasing" included within some textbook interpretations of the "Flow Chart", this can generate some further control comments.
The choice of CCP should fundamentally depend on yr risk assessment but this may occasionally be inconveniently subjective in the case of utilising "approved supplier" as a control measure for certain hazards. IMEX, auditors will give you the benefit of the doubt if yr implementation is logical and includes a credible validation. The Codex decision tree is a deceptively simple tool IMO, for some things it makes (decision) life easy, for others less so. Personally i try to avoid it.

It is also true that some people / procedures designate "Supplier Approval" as a Prerequisite program (along with various other manouevres such as allergen control).

Also some people (ultra-traditionalists) don't use prerequisites at all.

Rgds / Charles.C

[gelato]

Stuart's post makes perfect sense and it is logical. I would consider in the flow cart where I would suspect you have a RECEIVING step add a note on sensitive incoming ingredients.

[Jasmina Masrani]

Hi,

According to me, Approved supplier is Pre-requisite program so its a CP and not a CCP. Since you said that all your suppliers are approved then they must be having lab report of their final product. You can ask them to provide you lab report as a proof of product safety.

Hope my reply help you

Regards,
Jasmina

Hi All , I hope someone can help

I am fast approching our annual BRC audit, however I am not happy that we have Supplier Approval as a CCP. In my previous role in High risk we did not have it as a CCP. Does anyone agree with this or think it should be a CCP?


What will I need to document & demonstrate we don't think it should be a CCP?
All suppliers are approved wither its a CCP or not, and with in a year I have had no issues with suppliers that would verify approved suppliers should be a CCP.

Many thanks

[Charles.C]

Dear All,

There is an interesting collection of opinions in this thread which is a good thing.

However I fear that many of the comments lack information on a component which is typically an auditor's leading question -

Show me the validation ?

Just a suggestion.

Rgds / Charles.C

[Laura8]

Thanks for the comments.

All deliveries are still supplied with a Cof C or A, we do send samples for testing occationally to validate what the supplier is providing us on the certificates.


Some interesting comments to help me with logging the change