Including Scrap on a HACCP flow diagram?
Good Afternoon!
During a recent food safety (AIB) audit, our auditor suggested we add (to our HACCP process flow diagrams) points in the process where scrap is generated. We include rework as part of our diagram, but not scrap. Theoretically, scrap can occur at virtually ANY step in the process, for a variety of reasons, and because it is scrap, it does not affect the final outcome of the product.
(Background -- we are a low-risk processing facility, not technically required by US Law to have a HACCP plan, per se)
So I put this to you, oh experts of all things food safety: Is it a good idea to include scrap on process flow diagrams?
Many thanks!
We include it as an out put. Every step has inputs and outputs listed. It can be hard to organize everything and make it clear to read. Sometimes you may need a separate cut out diagram for process steps (like water treatment) If your layout is vertical, inputs (raw materials, compressed air, ice and water, packaging, etc) go the left, steps in the middle, and outputs on the right.
Good Afternoon!
During a recent food safety (AIB) audit, our auditor suggested we add (to our HACCP process flow diagrams) points in the process where scrap is generated. We include rework as part of our diagram, but not scrap. Theoretically, scrap can occur at virtually ANY step in the process, for a variety of reasons, and because it is scrap, it does not affect the final outcome of the product.
(Background -- we are a low-risk processing facility, not technically required by US Law to have a HACCP plan, per se)
So I put this to you, oh experts of all things food safety: Is it a good idea to include scrap on process flow diagrams?
Many thanks!
Dear ksullivan,
Sounds like nit picking to me if aimed at every step. Most people accumulate / segregate for later disposal IMEX.
Of course it may depend on what you mean by scrap and how you hygienically dispose of it. Perhaps yr (continuous?) waste (offal?) exit ran through the middle of the packing section. Has been known.
If hygiene is maintained, maybe put a footnote in somewhere and say all scrap is accumulated for last step, then add one step to the flow, = artistic license.
For an example see the process flow chart in the model yoghurt haccp plan.
PS - the "background" is interesting, how do you prove it's low risk without a hazard analysis ? Is there an approved FDA list ?
Rgds / Charles.C
I've had the same asked by an auditor ksullivan. Honestly what I did was make a big { across my whole flow chart and state "waste". Auditor was happy. Waste of time...YES.
We have all inputs and outputs listed. We don't have waste however. In my previous position when I made the flow charts for yogurt I did have waste on there in a few locations such as the fermentation room where some milk water mix would be wasted until the water was out of the line.
Dear ksullivan,
Sounds like nit picking to me if aimed at every step. Most people accumulate / segregate for later disposal IMEX.
Of course it may depend on what you mean by scrap and how you hygienically dispose of it. Perhaps yr (continuous?) waste (offal?) exit ran through the middle of the packing section. Has been known.
If hygiene is maintained, maybe put a footnote in somewhere and say all scrap is accumulated for last step, then add one step to the flow, = artistic license.
For an example see the process flow chart in the model yoghurt haccp plan.
PS - the "background" is interesting, how do you prove it's low risk without a hazard analysis ? Is there an approved FDA list ?
Rgds / Charles.C
Thanks to everyone for their comments.
We do have a hazard analysis in place and our product is classified as low-risk (as defined in the following link: http://www.fda.gov/F...s/ucm094143.htm). Our processes are all de-coupled, so scrap can be generated (and removed) at pretty much any point. And if you get quite literal, scrap can start at raw material storage, should, for example, a fork truck skewer a pallet of ingredients. The possibilities are endless!
BRC ask for waste to be included on the flow diagram.
I circumnavigated it by having a waste risk assessment, which seems to suffice!
Caz x
ksullivan -
Not sure if you will be required to have HARPC as the FSMA regulation is rolled out, but one consideration for your Flow Chart is your regulatory environment. USDA FSIS requires HACCP for all meat/poultry plants that is available to inspectors. I prefer not to have extraneous data/information on documentation I will be showing to regulators. My plants maintain 2 Flow Charts - one in the HACCP binder for regulators and another in HACCP support for audit compliance. We are very open about it and make no effort to hide this fact to auditors. Upkeep takes a little more time, but its worth it to avoid the hassle of discussing all the extra 'stuff' on the Flow Chart that is not required by regulation.
KTD
Dear ksullivan,
Re- Low Risk Products.
I guess it may depend on what you are actually doing / jurisdiction.
Thks for the nice link but, AFAI could see, the only mention of “low risk” relates to Australia ?
(slightly OT)
In truth, as detailed in the link’s review, this terminology area is a minefield. Much of the confusion is due to variable criteria for low/medium/high risk foods of course. BRC daringly use the same terminology for both foods and production areas in their standard.
Just as examples of (maybe) geographic preferences, note the “anomalous” use of RTE, chemicals, and haccp risk in these examples –
rk1 - risk UK.pdf 362.64KB 127 downloads
rk2 - risk Canada.pdf 546.56KB 84 downloads
rk3 - risk ASEAN.pdf 472KB 66 downloads
(annexes 1,2)
Rgds / Charles.C
BRC ask for waste to be included on the flow diagram.
I circumnavigated it by having a waste risk assessment, which seems to suffice!
Caz x
Thanks Caz! Can you pls share waste risk assessment?