HACCP Audit

Is it necessary to have an audit covering the HACCP program, on top of HACCP Val/Ver, and annual review?

I was thinking questions like:

1. Is the HACCP plan reviewed by HACCP trained team members?

2. Are the documents signed? Current?

3.Does the program cover all regulated PRPs?

4. CCP records review:

...and so on. I just didnt know since HACCP is pretty much a fully well rounded program if it should be included on the internal audit program.

Thanks!! 

Yes. Absolutely yes.

Annual internal audits should include HACCP system validations.  Your record keeping review should also include accuracy and falsification checks by personnel other than those engaged in said activities along with interviews of personnel maintaining these records.

This isn't so much a double jeopardy exercise as it is a sanity check. Approach internal audit methodology as you would the highest authority you answer to. 

Yes it needs to be included in the Internal audit programme and audited just the same as the other sections of the standard. The monthly and quarterly reviews aren't enough. 

Thank you everyone - these are just the answers that I was looking for!

Something I got a non-conformance for... which I didn't agree because the Critical Limits and Critical Points were clearly defined in my HACCP Plan, in my FMI Food Safety Risk Analysis, as well as in my Hazard Analysis. But because it wasn't on my flow chart I got a point deducted. Does anyone else agree and why?

2.4.3.1

Minor

HACCP process flow does not include Critical Limits or Critical Points to clearly define the intended use of the product as defined each of CCP's from from line 1, 2 and 3.

2.4.3.1

Minor

HACCP process flow does not include Critical Limits or Critical Points to clearly define the intended use of the product as defined each of CCP's from from line 1, 2 and 3.

That seems a just a bit nit-picky IMHO. Critical limits are outlined in the HACCP Plan which is regulatory. Everything else is essentially a "narrative" in support of determining what the limits shall be. 

Really doesn't make any mention for this specific detail the auditor gave you a non-conformance for.  Always ask for a "should" or shall" clarification and to prove this decision from the code.  
 

However the auditor may be taking this guidance too far;

I agree with Slab. I've put together a ton of HACCP plans over the years and I've never put the critical limits in the flow diagram. I have indicated that a step was a CCP, but I don't even recall an auditor asking me to do that. If one had, I would have contested it promptly. 

On the other hand, I did once have an auditor ask me to highlight areas where a food security risk might occur. I looked at him, he looked at me....I grabbed a yellow highlighter and went to town with it. I asked him if he was ok with my final masterpiece (doodle) and he was. That flow diagram was then put into a special folder in my desk with that auditor's name on it. Sometimes passing an audit comes down to making them feel like they accomplished something.  :biggrin:

I had a consultant ask me the same thing. I turned to the Process Hazard Analysis and said "Yes".

Marshall

I don't have CCP's on my flow diagram. Its meant to be a FLOW diagram, so you can follow the flow! Mines pretty basic. Don't think anyone would dare ask me to change it, and if they did, they'd get the look !

Caz x

I've always put CCPs on the flow diagram.  The reason I did was so that people could see where the CCPs fit into the flow of the system.  I don't know that it's required by anyone but you could have two flow diagrams one with them and one without them...

Something I got a non-conformance for... which I didn't agree because the Critical Limits and Critical Points were clearly defined in my HACCP Plan, in my FMI Food Safety Risk Analysis, as well as in my Hazard Analysis. But because it wasn't on my flow chart I got a point deducted. Does anyone else agree and why?

 

2.4.3.1

Minor

HACCP process flow does not include Critical Limits or Critical Points to clearly define the intended use of the product as defined each of CCP's from from line 1, 2 and 3.

I fail to see it as a non-compliance, the SQF code doesn't refer to a HACCP process flow. SQF Guidance does but doesn't mention the requirement to include critical limits or critical points:

Guidance for Developing, Documenting, Implementing, Maintaining and Auditing an SQF System SQF Code, Edition 7.2 – Module 2: SQF System Elements
2.4.3 Food Safety Plan (M) Implementation Guidance
This element is mandatory. The supplier must develop and fully implement a Food Safety Plan using the Codex or NACMCF HACCP method, that at a minimum follows the twelve HACCP implementation steps:
4. Construct a process flow diagram that covers the agreed scope (see step 1 above) of the process and includes all process inputs (e.g., raw materials, packing materials, processing aids), and outputs (including second grade product, product for rework). Every step in the process must be identified.

The SQF Code requires your Food Safety Plans to be prepared in accordance with the steps identified in the Codex Alimentarius Commission or NACMCF HACCP guidelines so here are the relevant sections:

CODEX CAC/RCP 1-1969, Rev. 4-2003 - Annex HAZARD ANALYSIS AND CRITICAL CONTROL POINT (HACCP) SYSTEM AND GUIDELINES FOR ITS APPLICATION
4. Construct flow diagram
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.
Definition: Flow diagram: A systematic representation of the sequence of steps or operations used in the production or manufacture of a particular food item.

NATIONAL ADVISORY COMMITTEE ON MICROBIOLOGICAL CRITERIA FOR FOODS HACCP Principles & Application Guidelines
Develop a flow diagram which describes the process
The purpose of a flow diagram is to provide a clear, simple outline of the steps involved in the process. The scope of the flow diagram must cover all the steps in the process which are directly under the control of the establishment.

NACMCF even give you an example in Appendix 3 of a flow diagram:

NACMCF HACCP Guidelines Flow Diagram Example.png   58.02KB   1 downloads

Maybe you want to show it to your auditor next time as they seem to have their own ideas and probably an ego to match.

Regards,

Tony

I fail to see it as a non-compliance, the SQF code doesn't refer to a HACCP process flow. SQF Guidance does but doesn't mention the requirement to include critical limits or critical points:

 

Regards,

 

Tony

Thank you all for your input. To make it clear I did have my CCP's listed out and what they controlled on my flow chart and highlighted in Red. i.e. Metal Detector CCP3 detection of metal. Mr. Incognito must've had similar past auditors. His gripe was that my critical limits weren't on my flow chart so it wasn't easy for an auditor to see them. I contested that it's not an appropriate place to have it but I have it here, here, here, here, and oh yeah here. But the auditor said he wanted it there. I contested it (just as Slab and Chris D. said) asking where does it ask that and I've done many flow charts and have never had it and he said "Then you need to go back to HACCP school" I was fuming by then. I have a really hard time keeping my mouth shut and hiding facial expressions. Sorry Cazyncymru the look didn't work and I did ask he threaten to take more points off as a major. 

Marshall G., What happened after you said "Yes"?

I'm seriously considering requesting a new auditor next year.

Now my HACCP flow chart has critical limits (i.e. size of test pieces) on it as if there wasn't enough going on that page. As I mentioned in another post Tony C. My forms have taken on different forms after seeing so many different auditors. Should I have appealed it with SQF?

RG3,

I have the critical limits on my flow charts. It's just a metal detector, so does not take up too much space.

As for the consultant, after I said "Yes", he said "I'd recommend that you include areas of risk on the flow chart".

I said, "Thanks for the recommendation, but I thought that's what a hazard analysis is for. I'm not cluttering up the flow chart."

Marshall

Clearly a recommendation is not the same as a non-conformance.

I think this issue should have been addressed during a desk audit anyway and possibly shows an inconsistency from the certification body:

2.6 The Desk Audit
An independent desk audit is conducted by the certification body for initial certification. The desk audit is conducted by a registered SQF auditor appointed by the certification body, and ensures:
ii. The food safety plan (at level 2) and the associated Critical ControlPoint (CCP) determinations, validations and verifications are appropriately documented and endorsed by the SQF practitioner;

I would write to the certification body and seek clarification before unloading both barrels.

Regards,

Tony