CCP monitoring frequency leniency
Hi all-
We recently had a BRC audit & our auditor suggested that we change our CCP monitoring frequency from "once per hour" to "once per hour +/- XX minutes". He said you should never "talk" in absolutes (if you say once per hour it better be on the hour, every hour) or you could open yourself up to possible NR.
My question is how many minutes is acceptable? He suggested 15 minutes, but I'd like to go 30 minutes just to give us a little bit more leniency so that we don't open ourselves up to NRs anyway.
Any help would be appreciated. Thanks in advance!!
Only my opinion/experience with BRC is actually the opposite. We had checks to be completed within 4 hours of previous check, plus before start up and after shut down. We installed a light that came on at 3hr 50 min and bell at 3hr 55min. Any deviation after 4 hours was a CCP violation and handled accordingly. If its worthy of a CCP then it should be treated as such.
A grace period of 30 min on an hour check in my opinion is not acceptable, you may as well say "whenever we feel like it". If your expectation is that it is preformed every hour it shall be done as such. Want it done on time train operators to do it every 45 mins with your HACCP plan stating it will be conducted at a minimum of once an hour.
If your set on a grace period for an hour check it should be again only in m opinion no more than 5 min.
G
Only my opinion/experience with BRC is actually the opposite. We had checks to be completed within 4 hours of previous check, plus before start up and after shut down. We installed a light that came on at 3hr 50 min and bell at 3hr 55min. Any deviation after 4 hours was a CCP violation and handled accordingly. If its worthy of a CCP then it should be treated as such.
A grace period of 30 min on an hour check in my opinion is not acceptable, you may as well say "whenever we feel like it". If your expectation is that it is preformed every hour it shall be done as such. Want it done on time train operators to do it every 45 mins with your HACCP plan stating it will be conducted at a minimum of once an hour.
If your set on a grace period for an hour check it should be again only in m opinion no more than 5 min.
G
Our auditor actually suggested +/- 15 minutes. The reason I'm wondering about +/- 30 minutes is because of the way our line breaks work & end of shit, For example we run from 7:00 AM to 3:30 PM, if the check was done at 2:45 PM then we aren't able to get a check for the 3:00 PM hour. We start clean up around 3:15 PM and there is no product on the floor at 3:45 PM. Also, things happen and if you say you're going to do a check every hour ON THE HOUR and say the QA is busy dealing with an issue of some sort then you've already deviated. I see the logic of the "grace period" since we are a very small company & only have one QA.
We have one QA as well on each shift, but it may be nesscary to train others to do the task becasue who does them if the 1 QA is on vacation or out sick? I struggled here at the start as we kind of whishy washed everything. And your right sh&t happens and we mutlitask hourly, but having a broader base for duties assists in that.
I would do the 3:00 check at the end of production to ensure everything made from the 2;45 check to the end was still in spec. If you run 8-8.5 hr and test on the hr your woud need a min of 8 checks but if your team gets 10 checks in that's just bonus and less product to put on hold/recheck if the current verification fails.
All this is my 2 cent for you to process how you wish!
G
I have always used 'approximately hourly' without specifying a minutes range. You can also train your people to conduct monitoring at a higher frequency than in the HACCP plan itself. You should have a discussion regarding actions to be taken/not required based on production interruptions.
Keith
hi B.Nicks,
My guess is that yr auditor nitpicks "approx." one victim in 10 just to keep his hand in.
Condolences.
Not knowing your process, or the exact CCP, it's hard to comment.
In the baking business, metal detectors are the usual CCP.
Everywhere I have worked it's always been hourly +/- 15 minutes for the frequency of checks.
Marshall
We've always had exact defined times because if you say "approximately" then there is no standard to know when an operator is supposed to perform it. I've seen 1 hour and 4 hours on MD checks and I've seen start of run / end of run (or shift depending on which MD).
The important thing is the ability to hold the product if it fails on a future check back to the last good check. As long as you can do that then you should be ok. But I can't see how an auditor is suggesting slop time on something as important as a CCP check. I've always trained my people that if they can't do something as important as a CCP check on time and properly then how can any auditor expect them to do the less important things on time/properly.
For me it depends on the wording. There is a HUGE difference between once per hour and once on the hour. My CCP's are monitored once per hour, HOWEVER, because they are once per hour, they can be almost 2 hours apart and I am not in a position of non conformance....as previously mentioned, it would depend on the actual CCP. In my previous post, a metal detector was a CCP and checked every 15 mins WITHIN the 15 minutes which did mean eventually there would be more than 4 checks in any given hour......
I am under FSIS, and I don't think 'approximately hourly' fulfills frequency requirements. Likewise, you couldn't use an approximation for your critical limits.
I have always used 'approximately hourly' without specifying a minutes range. You can also train your people to conduct monitoring at a higher frequency than in the HACCP plan itself. You should have a discussion regarding actions to be taken/not required based on production interruptions.
Keith
Appendix G -
I agree that 'approximately hourly' may not have the exactitude that auditors like; however, I have used it successfully for years in multiple USDA FSIS inspected plants. It can be helpful to define the term on your definitions page. Obviously, monitoring at 90 minute intervals is not 'approximately'. There has to be sufficient flexibility in the process (where appropriate, allowed, and reasonable) to accommodate human error and production changes.
We use non-exact/boundary condition statements all the time without necessarily recognizing it.
For lethality: '...internal temperature must reach 165F'. A temperature of 167F is acceptable
For freezing: '...internal temperature must reach 0F in 72 hours.' Hitting -2F in 70 hours is not a failure
KTD
Hi,
Whats odd to me is a BRC auditor "Suggesting" you change your CCP monitoring frequency. You are not allowed to "Consult" on a BRC audit. The auditor asks a question and you provide the answers, thats it. He is not allowed to make suggestions on "YOUR" CCP monitoring. Its against his code as a BRC auditor. Its cut and dry with BRC and GFSI audits in general, they ask questions and you have to answer it, If you were to ask " what do you mean exactly?" or "What is that?" all they would do is repeat the question. Answering the question is considered consulting. And if you want that then you would request for a consulting audit from your selected auditing body prior to having the official BRC audit.