11 replies to this topic

[Mr. Incognito]

I had someone from Corporate ask me if we had sent out our HACCP plan to an external verification for confirmation or something like that.  I've never heard about doing that.  Anyone have any thoughts or experience sending out their HACCP plan to a 3rd party to have it verified?

 

Personally I think it sounds stupid but I'm not as experienced in HACCP as some other members on here.

 

Thanks,

 

Merle

[fgjuadi]

Maybe he meant a third party audit like AIB or BRC?

[Mr. Incognito]

No.  We are AIB certified (last score was around 965 or so) and we just completed our FSSC 22000 certification. 

 

Honestly I have no idea what she was talking about which is why I threw it out here to get ideas on if that is something people do... if it's actually a thing lol.

[Marshenko]

That was something we used to have to do when going through Silliker GMP audits - we'd send it to an outside consultant just to have it reviewed, he'd write up a little one-page thing saying all steps were followed, risks addressed, yada yada yada.

 

So yeah, it happens.

[Mr. Incognito]

Ok then.  I guess I'll check with my food safety team today and see if it's something they were going to follow through on and find a consultant that will do it if they want to.

 

Simon is this something IFSQN does or has done?  Not saying I can get it over to you of course but if I can push some work your way I'd do what I could to suggest it.

[cazyncymru]

I work on a food park, and I have an agreement with the technical manager at one of the other manufacturers on the park

 

I "externally" verify their HACCP, and they "Externally" verify mine

 

Win / win situation

 

Caz x

[Mr. Incognito]

Nice Caz... not a bad way to do it as long as the auditor goes for it.  That's a good way to do it because saves you money and builds teamwork between different companies.

[Charles.C]

Ok then.  I guess I'll check with my food safety team today and see if it's something they were going to follow through on and find a consultant that will do it if they want to.

 

Simon is this something IFSQN does or has done?  Not saying I can get it over to you of course but if I can push some work your way I'd do what I could to suggest it.

Dear Merle,

 

I would make sure no-one's trying to stab you in the back first.

 

In many Companies such a query/proposal would be more of an accusation than a recommendation.

 

Rgds / Charles.C

[Mr. Incognito]

Oh no Charles here we are all actually pulling the oars in the right direction.

 

The lady who asked me just mentioned they had thought to do it before but with everything going on, our technical manager in charge of Quality quit, it fell by the wayside.

 

My plant manager isn't too keen on the idea he has the "If it ain't broke don't fix it" mentality and I can agree with that.  It passed AIB and FSSC inspection I don't want to change something that's working.

[Jessika]

_Merle,

_{It would be my guess that the process of external HACCP reviews is aimed at smaller companies that might not have a HACCP trained member of staff who is able to create a plan that satisfies auditors. Only about 6 months ago I was called into a meeting with the Head Honcho and our QA Manager to review some HACCP plans that an auditor had looked at and wasn't happy with. The Head Honcho was able to assist our QA Manager in adjusting and expanding the plan and explained to him why some things were critical control points rather than quality control points and vice versa. I mostly nodded along and confirmed that our process hadn't changed much since the plan was originally written.}

_{It's possible that your Corporate heard someone mention the idea or read about it and thought that it just sounded like something good to do to show auditors that always interesting 'continuous development' without understanding that with a good quality team it isn't a necessity.}

 

_Charles,

_{Have you ever heard of Hanlon's razor? "Never attribute to malice that which is adequately explained by stupidity."
I remind myself of this often when dealing with questions from higher up.}

[Charles.C]

_Charles,

_{Have you ever heard of Hanlon's razor? "Never attribute to malice that which is adequately explained by stupidity."
I remind myself of this often when dealing with questions from higher up.}

Dear Jessika,

 

Nice one. Very comforting.

 

But i also noticed this "corollary" -

Critic #1: Grey’s Law

Hanlon’s Razor is helpful in most contexts, but maybe not in all. Grey’s law states:

 

“Any sufficiently advanced incompetence is indistinguishable from malice.”

 

In other words: If you find someone acting so stupid that you can’t believe she’s doing it without the slightest chance of knowing that it’s stupid, then she might act out of malice.

 

My advice here is to apply Weinberg’s Rule of Three Interpretations:

 

“If I can’t think of at least three different interpretations of what I received, I haven’t thought enough about what it might mean.” — Jerry Weinberg

 

If you can’t find any sign of stupidity in a received message, it might be malice what you have found.

 

Rgds / Charles.C

[shea quay]

I was just about to thank Jessika for the greatest post on this forum ever and then I read Charles' reply! 

 

IMEX, HACCP plans tend to get stale after a few years, so there is no harm having someone new coming in to have a look. When I started out in the food world EVERYTHING was a CCP. Then the world changed, and as my hair slowly thinned and my favourite bands started to die, nothing was a CCP (including metal detection). Now, as the hair starts to concentrate on my back and on the palms of my hands and my favourite dead bands start reunion tours, a steady return to having CCPs has been introduced. It is worth having a new set of eyes coming in and scanning your plan every now and again. HACCP team members may not change much over a 5-10 year period, so there is a tendency for a "it ain't broke, why fix it" attitude. Unfortunately, what once passed as not broke can often become an embarrassment in a relatively short space of time, especially with the more modern risk based assessments. Also, such more recent food scares can have an impact on your plan, such as the Ukranian Sunflower Oil issue of '09. Once the old reliable of "no historical evidence of an issue" has been smashed, you may find yourself requiring a new risk assessment.