Hello Charles C.
Again, the Codex is very clear under the 5 preliminary steps which includes the "Process Flow". The purpose of the 7 principles is to establish the HACCP Plan and one of the requirements is to analyse potential hazards arising from "Ingredients / Materials" and the "Resultants from the Processes" respectively.
Requirements to determine control measures under the two different categories differ. Control on ingredient / materials are not part of the HACCP Plan but rather through other means. Hence, IMO Allergen (from Ingredients) cannot be classified as a CCP nor GMO.
IMO, current industrial practices through cleaning programmes and verifications are sufficient to manage potential cross contamination of Allergen during changeover of production, etc.
I think we are talking about decisions as to (width of) scope. (And presumably the “risks” related thereof.).
II. Scope of Hazard Analysis
Unlike HACCP principles 2 through 6, which are usually limited to operations within the facility's control, hazard analysis has a much broader scope and must include factors both within and outside of the facility.
The following is a listing of what should be included (at a minimum) in the hazard analysis:
Ingredients and raw materials: source, composition, handling, transportation, and storage.
Activities conducted in the process and handling system: steps identified on the flow diagram.
Equipment used in manufacture and processing: specific parameters important to controlling, reducing, or preventing hazards.
Equipment and facility sanitation.
Food product distribution: transportation, delivery, wholesale/retail practices, and intended use.
EDIS - FS13900.pdf 1.45MB
Q2. What range of hazards should be considered for the hazard identification and subsequent analysis?
A2. The scope of the HACCP application and the prerequisite programmes will influence this choice.
Normally the hazards identified are those that are reasonably expected to occur in association with:
• raw material;
• inputs (as defined in A Guide to HACCP Systems in the Meat Industry);
• process steps.
Hazards normally dealt with by a prerequisite programme, e.g. personal hygiene, may have to be considered in the development of a HACCP plan for a product and process involving special conditions, e.g. those involving a cook step. Alternatively, these hazards could already be effectively addressed by an appropriate prerequisite programme, e.g. clearly indicating the specific personnel hygiene requirements when working with raw or cooked product. The processor must be able to demonstrate appropriate control of the hazard, either through the HACCP plan or by the prerequisite programme.
Q3. What inputs have to be considered in the HACCP plan?
A3. Inputs, as defined in the Guide, are incoming materials such as consumable or non-consumable items added to the product during the process (e.g. ingredients, food additives, packaging). Recyclable or other items that come in contact with the product (e.g. hooks/gambrels) are not considered as inputs. Some premises may want to include food contact processing aides (e.g. legging paper) to ensure that all food contact materials are considered, and that hazards associated with them are adequately addressed. This decision is up to the processor.
MAFF, haccp_v1.pdf 253.09KB
I would imagine you are not too enthusiastic about this type of approach –
ILSI HACCP Concept.pdf 189.09KB
I guess the PAS220, etc output team (or its ISO adopters) wouldn’t be either.
But it is also IMO incontestable that PAS220, et al reduce the workload / head scratching.
So ultimately we probably agree with respect to CCPs although i have noted that allergen cleaning operations in some process analyses are becoming popular as a proposal for a model OPRP. Worrying line of thought for me.
Rgds / Charles
PS (added) - Almost forgot, Codex -
The scope of the HACCP plan should be identified. The scope should describe which segment
of the food chain is involved and the general classes of hazards to be addressed (e.g. does it cover all
classes of hazards or only selected classes).