11 replies to this topic

[ladybugtag]

I need some help. I obtained my HACCP cert back before they came up with the new 12 HACCP. I wont be able to attend a HACCP class until after our SQF Audit in the spring.
I am having trouble coming up with Hazards for the hazard analysis. We manufacture chocolate confectionaries (not the actual chocolate, but candy bars and the like).

Can anyone help?

Attached Files

•  Hazard Analysis Plan.xlsx   23.26KB   210 downloads

[Charles.C]

Dear ladybugtag,

Can you also post Excel sheet as a .xls ?. I cannot open .xlsx.

Thks.

Rgds / Charles.C

[ladybugtag]

ok here is the 97-03 version of my excel document

[Charles.C]

ok here is the 97-03 version of my excel document

Dear ladybugtag,

Seems to hv got "lost in translation" ??

Rgds / Charles.C

[ladybugtag]

ah ha, I selected but forgot to attach.  Hazard Analysis Plan 97-2003 version.xls   52KB   113 downloads

[Charles.C]

Dear ladybug,

Thks for sheet.

I deduce the SQF standard you are looking at requires both Safety and Quality “CCP”s. Stupid SQF (IMHO anyway).

Few quick comments although this not my product area so no problem if you don’t agree.

A flow chart and risk matrix would help. Not possible to evaluate yr risk data.

Looks like a high risk product/process to me.

None of the bacteriological hazards are specified. Defendable but usually not welcomed by auditors since indicates (often correctly) ignorance of product / ingredients etc. I seem to recall chocolate is famous for Salmonella.?

None of the process steps are bactericidal ? eg melting?

You have admirable faith in raw material safety. Is it justifiable ?

I deduce you use a metal detector all over the place. Not a CCP ?

I notice mention of unspecified allergens. Presumably milk?. But no comment re. control measures (or lack of) ?

I presume “Hand” means use of hands to do something. But hazard is metal ??

I would hv thought there might be some (low) temperature constraints in the process ?

Flow chart would facilitate some further researching for model haccp plans to compare.

Rgds / Charles.C

PS this chocolate related hazard overview may give some further ideas -

 chocolate confectionary.png   1.33MB   49 downloads

[ladybugtag]

ok here are the associated HACCP Flow charts.  HACCP Flow Charts no company name.pdf   52.67KB   152 downloads

We are going for a level 2 SQF so we only need the food safety program, not the quality steps (thank goodness, that is level 3).

We make the chocolate confectionaries, not the actual chocolate. We get chocolate in block/or kibbled and combine it with flavors or just mold it. Chocolate is a fairly low risk product. it is considered a dry product and salmonella is the big threat. we dont have temperature controls to consider for safety because we never cook chocolate, you only melt it (about 80F degrees) so the temp is a quality issue but not a safety.

We do metal detect our product prior to packaging (in most cases, some packaging we are able to metal detect, but most is metalized flow wrap) but a metal detector is not a CCP.
What I am looking for is help filling out possible hazards, but without anything becoming a CCP. we have great prerequisites, and CP points (not listed). We have a couple of customers who will ask for metal detection to be a CCP but for all others I want to be able to present these flows/hazards as CCP free.

I appreciate any help.

[Charles.C]

Dear ladybug,

Thks for flowchart. Nice presentation.

Definitely an interestingly “twisted” logic in yr haccp plan development. RTE product with belt / manual handling in processing sequence and no bactericidal stages. And no CCPs. Hmmm.
It's not impossible but I think you can anticipate some heated arguments with yr auditor. No doubt you realise this already.

An answer to yr request for further possible hazards which do not yield CCPs is in principle easy, some typical sources of BCPA hazards are due to (a) existence in inputs, (b) unacceptable growth of (a)-derived microbiological factors during the process, © contamination from either (i) The environment, (ii) Improperly cleaned plant and equipment, (iii) Food handlers, (iv) Spoiled or waste products.

Accordingly you need to create an additional "A" line for BCPA options at each step in the process and apply above principle to develop possible hazards. From yr existing hazard analysis, (a)-factors are presumably not significant bar “A” which is accountable within labeling controls (I assume no process-to-other-process possibilities.) (b) factors therefore are also zero. So you have to add the diverse “©(i - iv)” possibilities for BCP at each step which will typically all be handled by routine prerequisites and therefore are not-significant hazards. There is an Excel example which illustrates such considerations in this post –

http://www.ifsqn.com...dpost__p__48386
(above is primarily a closed system process so c(iii) options limited, not quite clear to me how much of yr line is similar situation)
(ADDED - Apologies, hazard column not shown, the draft pre-haz.anal.column indicating basic idea is included and can be seen by "unhiding" col.G , detailed hazard analysis coming "soon")
(a list of common prerequisites to select from is in this post - http://www.ifsqn.com...dpost__p__39775 )

Hope this helps.

Rgds / Charles.C

PS it is usually beneficial to number the flowchart process points to save time/textual clarity assuming the chart layout is sufficiently stable (just located the "Hand" step, = "handling/shaping" perhaps?, good candidate for hazard .)

[ladybugtag]

Thanks,
Yeah I know having no CCP's seems very illogical but in the chocolate confectionary industry this is very common. We rely heavily on the actual chocolate producers and require COA's for all incoming ingredients. the most basic explanation is that we receive dry ingredients, combine them and package them. it just confuses people because they have a hard time thinking of chocolate as a dry ingredient.
I actually have had no issue with previous auditors.

I do plan on adding the #'s as easy reference to the flow chart/hazard analysis.

[Bawdy]

Hi Ladybugtag,

I write this in full confession/knowledge of having no experience in the confectionary/chocolate industry, so please fee free to shoot down my comments if they are way off base.

But, if as you say, you rely heavily upon the supplier and the incoming COFAs, is this then not a CCP? How critical is it to your process that the incoming goods have a COFA showing compliance to spec?

A simple question to check this is - If you found out that a finished product had used or was made from an ingredient for which you had no COFA and there was no chance of ever receiving one, would you be worried about the product/consumer? I.e would you reject the batch? If the answer is yes, then i would suggest that the provision (and checking/signing off on) of a COFA is a CCP? If you say, no it will be okay, im not worried by this, then obviously it is not.

Interested to know your thoughts on this.

Paul.

[ladybugtag]

But, if as you say, you rely heavily upon the supplier and the incoming COFAs, is this then not a CCP? How critical is it to your process that the incoming goods have a COFA showing compliance to spec?

A CCP should be the one parameter that if uncontrolled/out of spec could result in a food safety issue. Because our COA program is in place as a prerequisite and sufficeintly avoids any out of spec product/non coa'ed product from entering the plant (material is rejected) it is not a CCP but rather a CP.
I feel that too often we label things as CCP's when our prerequisite programs should lower the risk to nearly nothing.

Going back to the metal detector- specific customers ask that this be a CCP but the cleaning and maintenance SOP's and records should eliminate this a CCP point since with regular and detailed cleaning and maintence there should be no metal shavings/bits present in the machinery that could get into the product.

[Charles.C]

Dear All,

I suggest the last two posts are both feasible and reflect alternative viewpoints on implementation of PRPs. Consider -

I. Determining CCPs

In general, CCP determination involves identifying and characterizing the hazards, the control measures, and the processing steps where control is applied. Thus, it is imperative that the HACCP team revisit and re-evaluate the Hazard Analysis as well as the Flow Diagram.

If a significant hazard that is reasonably likely to occur is identified in the Hazard Analysis, it must be controlled somewhere in the food processing and handling system. Due to the rigorous HACCP requirements for setting appropriate CLs and monitoring, there are certain hazards in certain situations which are more appropriately controlled by prerequisite programs. This has been the subject of some debate and has led to two approaches in dealing with such hazards. While they differ philosophically, the end result of these two approaches is similar.

*

Approach A: This approach is used by some HACCP auditors in the regulatory and private sector. It dictates that a hazard deemed significant in the Hazard Analysis must be controlled at a CCP. It then follows that a hazard which is, in fact, managed by a prerequisite program is considered not "reasonably likely to occur" because of the prerequisite program.
*

Approach B: In this approach, prevention and control of identified significant hazards can either be at a CCP or through rigorously applied prerequisite programs.

No set number of CCPs is required in HACCP. Rather, CCPs must be determined for each specific food processing and handling system and be appropriate to that specific system. Having too many CCPs could unnecessarily encumber and burden the implementation of the HACCP plan. Conversely, having too few CCPs could jeopardize food safety.

(  FSHN07-04_FS140_ Hazard Analysis.pdf   57.03KB   76 downloads)

Going back to the metal detector- specific customers ask that this be a CCP but the cleaning and maintenance SOP's and records should eliminate this a CCP point since with regular and detailed cleaning and maintence there should be no metal shavings/bits present in the machinery that could get into the product

See section D in above attachment.

Additionally, in some industries, eg seafood, the USFDA's prescriptive approach virtually defines that a step where possible metal contamination is appropriately controlled is a CCP for specified process operations/equipment.

I think the reality is that there are a lot of possible permutations in the presentation of hazard analyses / selection of CCPs. The parallel use/definition of SOPs, SSOPs, GMP, GHP etc can further overlap/blur the issue.

Rgds / Charles.C