Question over Repeating Hazards

Hello all,

So I'm discovering some hazards like employee contamination, allergen contamination, chemical residues, etc. can be found at every processing step. Does this mean those need to be identified in my HACCP plan repeatedly or only at the step when the hazard is first introduced?

For example- "employee contamination" would first occur right after storage when the open product is exposed, but technically it would continue throughout every step when an employee is involved. Is it correct to include these repeat hazards at every processing step?

Thanks!

From what I know, and my initial training was 5 years ago and sadly my Advanced HACCP training isn't until August, you should at least list any reasonable hazard at every step so that you can show that it was considered at that step. 

There are people on here that have vastly more knowledge of HACCP though so they may chime in as well.

 We look at each step individually if a hazard exists at this  step then it is listed. A lot of our hazards are repeats but are present at almost every step. Our product is open for all of production (open cheese vats). 

Yes you may find the same spesific hazards at several steps when you do Hazards Identification. List all of them and identify their significance  by estimate the likely occurence of hazards and severity of adverse effect

These items are "global" or "generic" to the factory  rather than "local" "specific" to each step. Usually associated with the 3 categories of PEOPLE , PREMISES, PRODUCT. For us they are listed in a separate list of Pre -Requisites. They are in a hasard table for analysis and  review like our process steps but are considered once rather than at every step. Examples are , cleaning, maintenance, training, work work, personal hygiene regs.Pest control, They are part of haccp but analysed separately to the specifics at each process step. Taking them out of the study (but not ignoring them) allows you to concentrate on the PROCESS rather than the FACTORY.

Hope this helps

Regards

Sharon

Dear Sharon,

I agree with you but IMEX some auditors won't. It also maybe depends on the standard. And the lunch ? :smile:

I once tried a similar approach such as " all process steps X - Y are potentially associated with intrinsic contamination from some/all factors such as equipment, environment, personnel, etc, etc as detailed in Table ABC. These are controlled to a satisfactory (safety) level by the prerequisite programs as cross-listed in Column W via related  procedures given in the Prerequisite text sections D-E."

First auditor immediately shot it down saying that all "relevant" hazards must be shown in the same hazard analysis within a continuous logical order. I guess auditors may differ over what is "logical". :smile:

Rgds / Charles.C

Dear Sharon,

 

I agree with you but IMEX some auditors won't. 

 

...

 

I guess auditors may differ over what is "logical". :smile:

 

Rgds / Charles.C

HA!

I have my global hazards listed in the front along with a list of steps they are relevant to (its all of them!).  Only time will tell if this is okay or not

My previous Quality Manager had listed a global hazard of Radiological and stated that at no step was there a radiological hazard because there were no power plants nearby... blah blah blah.

I tried to explain to her that in my SQF class you also had to mitigate possible radiological hazards in your ingredients if they are sourced in an area where that is a possibility (for example like the Fukushima reactor issue) but she ignored me.  At least that's what they told us in the SQF practitioner class.

That's the only time I've seen a global hazard listed... beyond that hazards were repeated to show that they were considered at every relevant step.  That's what the auditors want to see... that you thought about the hazard every time it was appropriate... at least that's how I understand it.

Good luck.

Dear Mr Inc.

From memory the (soon-to-be-notorious) FSMA initially required radiological hazards to be included. Now, maybe not ?

But as you, and SQF, say, there will surely be some cases for it. Processing food next to a Pitchblende mine maybe. :smile:

Rgds / Charles.C

Well a few years ago, before FSMA was adopted I believe, SQF required the consideration of radiological hazards.  Now it's possible they were aware that was going to be a requirement of FSMA and adopted it early.  I don't know the details because I was new to implementation of SQF and GFSI standards in general... but back then it was an SQF only thing.

And what I was eluding to was if your sourcing sugar from Japan, for instance, and there is a reactor explosion then you would have to assess if it impacts your ingredient and source from another location if found to be a risk.  \

That being said I don't know if Japan exports sugar and I'm just using a real world example for explanation purposes and I don't really have another one to use (3 mile island and Chernobyl I guess) so please don't think I'm hammering on one country and one incident.
 

• The way I have been advised is that if it may occur at a step it must be listed.  If it may occur at more steps then more listings.  The CFIA (Canadian Food Inspection Agency) is who stated that to me and we follow what they say.

Dear Mr Inc.

 

From memory the (soon-to-be-notorious) FSMA initially required radiological hazards to be included. Now, maybe not ?

 

But as you, and SQF, say, there will surely be some cases for it. Processing food next to a Pitchblende mine maybe. :smile:

 

Rgds / Charles.C

FYI, and thanks to the previous poster that brought this thread back up, at my HACCP training last month the auditor said there was like 6 classes of hazards in FSMA and while I don't remember them off the top of my head I'll have to listen to the recording I made of the training but radiological was one of them.  There was another two but they've escaped me.