End of run / batch CCP checks

I would be very grateful if someone could advise me: At the end of a product run we currently check the filter (our only CCP) but do not complete the rest of the check. We have been told that if the last check was at 14.00 and the run finishes at 14.10 we would have to complete another full check. I believed that if at 14.10 we check the filter and document it then this would be adequate. Help!

I would be very grateful if someone could advise me: At the end of a product run we currently check the filter (our only CCP) but do not complete the rest of the check. We have been told that if the last check was at 14.00 and the run finishes at 14.10 we would have to complete another full check. I believed that if at 14.10 we check the filter and document it then this would be adequate. Help!

Dear robbed76,

A little more info. might be useful, eg

Product
Process, eg hazard controlled by filter

What do you mean by a "full check" ?

Rgds / Charles.C

Ok, we pack edible oils and the hourly check consists of recording oil and packaging batch details (these don't change during the run), best before date and Julian code, some manual weight checks and an organoleptic test. The CCP is the filter check which is done at the start and end of the run. I am of the opinion that if the check is completed at 14.00 and the run ends at 14.10 then another check would be unneccesary, as long as the filter is checked at 14.10. The filter check consists of removing it from it's housing and visually inspecting it. The oil is stored in a holding tank and passes through the stainless steel filter before entering the packing machine. I hope this makes more sense!

Regards and thanks for taking the time to respond.



Robin

Dear robbed76,

A little more info. might be useful, eg

Product
Process, eg hazard controlled by filter

What do you mean by a "full check" ?

Rgds / Charles.C

Dear robbed,

Thks for details.

I forgot to request the specific reason for the auditor (?) desiring a full check.
I presume you hv a procedure for "full check" which refers to a different documentation frequency than the filter.
Was the objection raised related to HACCP, perhaps traceability ?

Rgds / Charles.C

Hi Charles

Yes, the "full check" is completed at the start and then hourly and the filter check is completed at the start and end of the run.

This was raised by an auditor but didn't relate it to HACCP or traceability specifically, just said that it was industry standard and it would be raised as a non conformance during a BRC audit.

At another factory I have worked at we used to complete a metal check at the end of the run regardless of when the last full check was completed as it was a CCP and it needed to cover off the full run but this was the only part of the check we were required to complete (at the end of the run).

Thanks once again,


Rob

.

Dear robbed,

Thks for details.

I forgot to request the specific reason for the auditor (?) desiring a full check.
I presume you hv a procedure for "full check" which refers to a different documentation frequency than the filter.
Was the objection raised related to HACCP, perhaps traceability ?

Rgds / Charles.C

While common sense certainly would say a full check isn't necessary, you really have to leave your common sense at the door when auditing-especially yourself. In theory, however highly unlikely in practice, something could be altered, change, or go wrong in those 10 minutes, and it would not be found. Ensuring your entire process meets your standards also means checking at the absolute last possible second just in case.

Dear robbed,

just said that it was industry standard and it would be raised as a non conformance during a BRC audit.

The latter opinion demands that yr auditor was aware of a specific section in BRC standard which was compromised. He/she should hv informed you accordingly so you could judge for yourself. Similarly, the comment "industry standard" demands validation, not just hearsay. After all, you paid for the audit.

Rgds / Charles.C

The filter is your CCP control measure and checking it is the monitoring procedure. The key things to record are the filter checks (1) before use i.e. to show it is not cracked or has holes in it other than those supposed to be there as a filter, (2) during use - if possible, not always with in-line systems, and crucially, (3) after use to document it has not broken or overflowed during use (in which case your corrective action would be to replace the filter and re-filter since the last "good" check into new containers).
So you absolutely need a check at the end - at 14.10 or whenever - as you say you do.

If your "full check" is "packaging batch details (these don't change during the run), best before date and Julian code, some manual weight checks and an organoleptic test", I don't really see what you would be checking those for every hour unless maybe it is some sort of continuous rather than batch process, and these have nothing to do with the CCP.

I agree with D-D...a filter check only should be ok if it is less than a half hour after the last "full check" when the batch/run completes.