Dear Friends,
I want to ask you one general question which is not acceptable to me - please give your views:
If the process flow of the product is different - for example 4 different process - Is it ok to have same common flow chart for all the 4 different process categoy, common hazard analysis and common HACCP Plan - The CCP's are not the same for all the flow chart - in some CCP 1, 3,4 is there in some all CCP is there - but the CCP limits are same...
If I want to tell - this is not justifiable to have common hazard analysis - I have to tell which clause of ISO 22K is asking to keep the different flow chart for the product... I hope you got my point.
Pls. clarify.
Rgds,
Anish
Dear Anish,
IMO, ISO22000 does not explicitly set a definite limitation. But a limitation may still exist.
The iso22000 standard states “this internationl standard integrates the principles of the Hazard Analysis and Critical Control Point (HACCP) system and application steps developed by the Codex Alimentarius Commission”.
The Codex HACCP guidelines state –
The flow diagram should be constructed by the HACCP team (see also paragraph 1 above). The flow diagram should cover all steps in the operation for a specific product. The same flow diagram may be used for a number of products that are manufactured using similar processing steps. When applying HACCP to a given operation, consideration should be given to steps preceding and following the specified operation.
AFAIK, the ISO22000 standard only explicitly requires compliance with para..7.3.5.1.
Accordingly it should depend on the interpretation of the Codex “similar”.
IMEX (not iso22000) auditors have no problem where the alternative overall routes within a composite flow diagram have the same CCPs. Otherwise it becomes more problematic.
I have seen (haccp) textbook examples where different processes have the same mainline but with varying loops within the mainline so that overall process routes have different CCPs. This was pictorially handled by showing additional, labelled, flow “diagrams” for the loops within the same page and indicating the location of the loops on the mainline flow line. Individual hazard analyses for the separate loops were then presented within their respective contexts of the main plan.
However, depending on the actual process(es), the overall analysis could eventually get so complicated that it may ultimately be more logical to use separate flowcharts. This scenario IMO could cause an audit problem, ie it may depend on the specific case.
Rgds / Charles.C
