Validation of CCPs
As an independent technical consultant, I recently attended a BRC GSFS audit on a bakery and a minor non-conformance was raised by the auditor that the critical control point required validating. By this he meant that I needed to validate why the process step, metal detection, was identified as a CCP and document the validation. However, my interpretation of this clause in the standard is that the control measures in place for the CCP require validation to ensure they are effective in controlling the hazard and preventing critical limits being exceeded. I would be interested in members opinions on this.
Hi, maybe he mean't that he wanted to see your decision making process that this is a CPP documented and how this was decided i.e using a decision tree??
I rather agree with previous poster. Sounds like a question of semantics.
In fact, "Validation of CCP" (VoC) as such does not occur (I think) in the Codex presentation of HACCP to which BRC is referenced although "validation of critical limits" does (plus "validation" being used in a more general way.) However yr interpretation of VoC is the typical one IMEX and usually focuses on finding (or developing) a scientific justification for the effectiveness of the chosen control measure and associated critical limits. For example as per this well-known Codex document -
cxg_069e.pdf 206.71KB 226 downloads
As per previous poster, the other bit sounds seems more like a "validation" of the risk assessment procedure which is also a common auditor requirement, eg "how do you justify the necessity for the CCP".
I suppose both viewpoints could be correct in some respect although assuming you are specifically referring to clause 2.8.3 (BRC5) yr interpretation seems more "valid"
Rgds / Charles.C
Kind Regards
Skye.
Hi, maybe he mean't that he wanted to see your decision making process that this is a CPP documented and how this was decided i.e using a decision tree??
As an independent technical consultant, I recently attended a BRC GSFS audit on a bakery and a minor non-conformance was raised by the auditor that the critical control point required validating. By this he meant that I needed to validate why the process step, metal detection, was identified as a CCP and document the validation. However, my interpretation of this clause in the standard is that the control measures in place for the CCP require validation to ensure they are effective in controlling the hazard and preventing critical limits being exceeded. I would be interested in members opinions on this.
you are absolutely right. validation is required to prove the control measure applied is adequate enough to control the hazard identified. no validation for hazard identification is required. decision tree is just one of the options. You can straigt way say this could be the possibility hence thios control measures and that critical one.
Correct me if Iam wrong.
Thanks
Gourav
As an independent technical consultant, I recently attended a BRC GSFS audit on a bakery and a minor non-conformance was raised by the auditor that the critical control point required validating. By this he meant that I needed to validate why the process step, metal detection, was identified as a CCP and document the validation. However, my interpretation of this clause in the standard is that the control measures in place for the CCP require validation to ensure they are effective in controlling the hazard and preventing critical limits being exceeded. I would be interested in members opinions on this.
Skye,
1. The nonconformity raised on the HACCP Plan is a MAJOR not a minor if indeed "validation" had not been conducted. I believe the auditor had erred in his judgment
2. CCP identification only needs to be justified however the sensitivity of the MD requires validation. Perhaps, in this case, he wants you to validate the correctness of the selected MD sensitivity by testing the test pieces BEFORE each production (if you do not have one). Otherwise, there may be a fundamental error in judgment by the auditor.