7 replies to this topic

[SPL]

Just inherited a HACCP program from the previous coordinator. I was tasked to make sure it was update and standard. The current  plan uses a hazard analysis worksheet. An auditor stated he wanted a decision tree. My question  are then not the same in principle? 

[henriquefonseca]

In priciple they are if in the end you answer the same questions.

People got used to the "raw" Codex way of doing things, it has a decision tree so many still think you must have one too.

[Dharmadi Sadeli Putra]

Dear SPL

I hope the following reference maybe useful

http://www.fda.gov/F.../ucm2006801.htm

Rgds,

Avila

[SPL]

In priciple they are if in the end you answer the same questions.

People got used to the "raw" Codex way of doing things, it has a decision tree so many still think you mus have one too.

 

I believe you're right, this auditor has a particular way of doing things. As part of the ongoing validation, I will create a decision tree to support our system .

[Charles.C]

Dear SPL,

 

If Codex is the relevant arbitrator and you are referring to the determination of CCPs, yr auditor has no haccp  justification for a demand of a decision tree.

I suggest you read up a little on Codex HACCP and then you can cheerfully rebut the request which is, btw, scientifically nonsense.

(3 exceptions might be (a) if the requirement is specifically stated in the standard, (b) legislatory documented, © yr current hazard analysis was unacceptable and the auditor thought a decision tree would be more convenient/easier for you. Neither [a.b] is customarily the case).

 

Rgds / Charles.C

[Ekivlen]

If Codex is the relevant arbitrator and you are referring to the determination of CCPs, yr auditor has no haccp  justification for a demand of a decision tree.

I suggest you read up a little on Codex HACCP and then you can cheerfully rebut the request which is, btw, scientifically nonsense.

(3 exceptions might be (a) if the requirement is specifically stated in the standard, (b) legislatory documented, © yr current hazard analysis was unacceptable and the auditor thought a decision tree would be more convenient/easier for you. Neither [a.b] is customarily the case).

 

Well said. Sounds to me like an auditor that doesn't fully grasp the intention of a decision tree; we were trained that a CCP decision tree was a tool used to determine whether a CCP was merited. 

Do your homework. Ask the right questions and provide documentation/verification from Codex Alimentarius. Your HACCP plan should be YOUR HACCP plan. 

[Slab]

Is this a regulatory audit?  If so there is no need to provide an investigator (auditor) with anything other than the HACCP plan. What an auditor would "like" is entirely negotiable as regulatory requirements trump desire. Should you have documented preliminary steps, narratives, process flow charts, hazard analysis? Yes, this is a great practice for continuity as you have just discovered and it certainly makes a review procedure so much more simpler. 

[SPL]

Is this a regulatory audit?  If so there is no need to provide an investigator (auditor) with anything other than the HACCP plan. What an auditor would "like" is entirely negotiable as regulatory requirements trump desire. Should you have documented preliminary steps, narratives, process flow charts, hazard analysis? Yes, this is a great practice for continuity as you have just discovered and it certainly makes a review procedure so much more simpler

 

This was a customer audit, a major part of our business. From the audit, I did sense that he was not grasping our HACCP plan and our scientific evidence for our decisions. Flow charts and hazard analysis work sheets details it out, but I understand our plan will need a minor revision. Another member of customer was along during the audit and stated the auditor was rough on all their vendors.

 

Auditor was from the UK before moving stateside, is this criticism a result of BRC or other UK standard?