11 replies to this topic

[ehamilton]

     Hi All,

I have a quick question about what constitutes a critical raw ingredient. I'm looking back over my notes and can find nothing specifically about this.

     And I'm looking at this from a quality viewpoint right now, so the definition may differ somewhat, but any words of advice or reference is greatly appreciated. In our HACCP Plan, currently the only critical raws we have are allergens.

     Which raises another question as well. In HACCP, allergen severity is always high. Does this apply to a Quality plan as well? Undoubtedly, a quality product can't be produced if there is cross contamination, yet I'm not sure if this is the correct application of terminology.

     In the risk assessment matrix, there are 3 levels of grading. Does anyone know if the requirement of a critical raw must be claimed at a low severity/ medium likelihood?

    

[esquef]

As I've stated on this forum previously, IMO allergen control is not part of your HACCP plan per se, it's a pre-requisite program. I agree that if you use a risk analysis matrix to do ingredient and process risk assessments for your HACCP plan(s) Severity would be high. If, however you have a solid allergen control program documented and in place (and deemed working and effective by auditors) you can consider the Likelihood to be low.

[Mr. Incognito]

I'll have to differ with esquef here.

 

Allergens are definitely something that goes into your HACCP plan especially if there is a risk of allergen cross contamination due to multiple allergens in your facility.  Allergens are typically considered a chemical hazard.

 

http://www.foodsafet...enerhazards.pdf

http://www.ifsqn.com...-fourth-hazard/

 

Though you can see places where people believe it should be under other categories.

 

Prerequisite Programs are a part of HACCP, insomuch, that they influence your hazard analysis, as was stated above even though it's not directly a part of the 12 steps / 7 principals of HACCP.  And yes if you have an excellent allergen control program the likelihood should be low.

 

For instance you can say that a car can be operated without tires.  Surely you can start the engine, turn the steering wheel, and listen to the radio but you can't drive down the road.

 

To say that a quality product can't be produced due to cross contamination may be a stretch.  If you are talking about minimal incidental cross contamination of allergens I don't think it would severely affect the quality of the product and certainly not as much as the safety of the product.  That is to say that if there was allergen protein on the line and not dumping in an extra ingredient like peanuts.

 

I'm not sure that I would list allergen ingredients as a critical food quality raw ingredient for those reasons though I haven't used SQF level 3 in a long time.  My guess is you are looking at this section of the code:

 

2.4.4.1 (M) A food quality plan shall be developed, effectively implemented, and maintained in accordance with the HACCP method to outline the means by which the organization controls and assures food quality and legality. The food quality plan shall:

 

i. Outline the results of a food quality risk analysis conducted to identify threats to achieving and maintaining product and process quality.

ii. Prescribe those measures taken to apply the controls implemented that are critical to assuring, monitoring and maintaining food quality.

iii. Include process controls at quality points in production to monitor product quality, identify when a process is deviating from set parameters and make corrections to keep a process under control;

iv. Cover a food or food group and the associated processes; and

v. Include documented Standard Operating Procedures (SOPs) and Work Instructions (WI) applicable to the organizations scope of certification.

 

I believe this is more talking about what processes that are critical to achieving the proper product like if you make flour and a customer wants a certain granulation (rollstands / sifters / etc) or you are making bread and the customer wants it enriched (enrichment feeders feeding into the flour stream), or a yogurt that is supposed to have a certain pH.  Food quality, from what I remember, deals more with product specifications than what you are looking at.

 

I could be wrong.

[esquef]

I read the OP too quickly and missed the "Quality" aspect of the question. I guess part of the question is "if product is unsafe is it off-quality?". I'd agree that it is.

[Charles.C]

Hi ehamilton,

 

I'm not a SQF user so  disagreements welcome. Here's my take (below) based on these quotes from SQF Standard/Guidance -

 

(1) HACCP  The Hazard Analysis Critical Control Point and refers to the following two universally

accepted guidelines and definitions contained therein:

(a)    HACCP guidelines developed and managed by the Food and Agriculture

Organization’s CODEX Alimentarius Commission. Hazard Analysis and Critical

Control Point (HACCP) System and

 

Guidelines for its Application – Annex to CAC/RCP 1 – 1969, Rev. 4-2003), – “A

system, which identifies, evaluates and controls hazards which are significant for

food safety.”

 

(b) HACCP guidelines developed and managed by the National Advisory Committee on

Microbiological Criteria for Foods (NACMCF). Hazard Analysis and Critical Control

Point Principles and application Guidelines, Adopted August 14, 1997. “A systematic

approach to the identification, evaluation, and control of food safety hazards”

together referred to as the HACCP Guidelines.

(2) HACCP Method  The implementation of pre-requisite programs and the application of HACCP principles in

the logical sequence of the twelve steps as described in the current edition of the CODEX

Alimentarius Commission Guidelines, or the current edition of the HACCP guidelines

developed and managed by the NACMCF.  The SQF Code utilizes the HACCP method to

control food safety hazards and other quality threats in the segment of the food chain

under consideration.

(3) HACCP Plan  A document prepared in accordance with the HACCP method to ensure control of hazards

which are significant for food safety in the segment of the food chain under consideration.

 

 

(4)(a)  SQF Level 2 – Food Safety Plan

Level 2 incorporates all Level 1 requirements, but also requires the supplier to first, identify hazards

that can impact product safety; second, conduct a food safety hazard analysis of the product (s) and

its process (es); and third, identify actions to eliminate, prevent or reduce identified hazards to an

acceptable level.  These steps must be achieved using an approved HACCP methodology (refer to

section 2, below).  Level 2 requirements are found in the center column in module 2 of the SQF Code,

edition 7.

(4)(b) SQF Level 3 – Food Quality Plan

Level 3 incorporates all Level 1 and Level 2 System requirements. At this level, the supplier is also

required to use and approved HACCP methodology to identify and assess food quality hazards and

document the action (s) taken to eliminate, reduce or prevent their occurrence.  Quality hazards and

their controls can be included in the same HACCP study as performed for food safety hazards, or can

be documented separately.  However, if incorporated food safety hazards and their controls must be

clearly distinguished from food quality hazards.

 

 

As I understand, Food Safety Plan is an SQF synonym for HACCP  Plan

 

AFAI can see yr phrase “critical raw material” is nowhere mentioned in the SQF Code.

 

From above quotes I suggest allergenic hazards are positioned within (4a)

From (2,3) this would also apply to  allergenic control programs if categorized as Prerequisites.

 

Any relevant factors which are not safety-related should then be positioned in (3b), ie within the SQF Food Quality Plan. The scope of the “relevant factors” is illustrated in the Guidance. It will (specifically) obviously depend on yr product/process.

 

PS - Just as a side-note, "Quality" has a wide and varied range of interpretations. For example ISO 9001 = (ISO) Quality, ISO 22000 = (ISO) Safety. Many haccp food texts refer (loosely) to "safety and wholesomeness" as = Haccp/Quality respectively. Predictably, "Quality" is not defined in the SQF Glossary.

[Mr. Incognito]

Charles,

 

In SQF level 3 you have to have a food safety plan (which everyone who works in GFSI is aware of) and a food quality plan.

 

What things are key to having a quality product?

 

Normally those are things that your lab tests for as I outlined above.  Those are not two interchangeable things.  Having a food quality component is what set SQF level 3 to an, arguably, higher benchmark than other GFSI standards.  If something isn't required for your product why would you test it anyhow?

 

For instance baking bread will normally have a food safety CCP of cooking - Time and Temperature however if you cook the bread at a lower temperature (or higher temperature) or for a longer or shorter time will you achieve a quality product.  Probably not.  Therefore a quality control point may also be time and temperature though the ranges may be different for the QCP than the CCP.

 

So my question for EHamilton is where did you get the idea that you need to list critical ingredients?

 

I could postulate that maybe, in the instance of yogurt, milk could be a critical raw ingredient.  It has to be received at a proper temperature, it can't have pathogenic organisms in it, etc.

[Charles.C]

Hi Mr Inc.

 

Maybe this post expands yr comments in a SQF way -

 

http://www.ifsqn.com...l-3/#entry88890

[ehamilton]

Charles,

 

In SQF level 3 you have to have a food safety plan (which everyone who works in GFSI is aware of) and a food quality plan.

 

What things are key to having a quality product?

 

Normally those are things that your lab tests for as I outlined above.  Those are not two interchangeable things.  Having a food quality component is what set SQF level 3 to an, arguably, higher benchmark than other GFSI standards.  If something isn't required for your product why would you test it anyhow?

 

For instance baking bread will normally have a food safety CCP of cooking - Time and Temperature however if you cook the bread at a lower temperature (or higher temperature) or for a longer or shorter time will you achieve a quality product.  Probably not.  Therefore a quality control point may also be time and temperature though the ranges may be different for the QCP than the CCP.

 

So my question for EHamilton is where did you get the idea that you need to list critical ingredients?

 

I could postulate that maybe, in the instance of yogurt, milk could be a critical raw ingredient.  It has to be received at a proper temperature, it can't have pathogenic organisms in it, etc.

Mr Inc.,

Thanks for your input. In our particular instance, there are several factors to ensuring a quality product. The usual visual, flavor, and aromatic, etc.

My question arises more about verbiage and certification body expectations I think.

In presenting a Food Quality Plan modeled after our HACCP, I, of course, am basically migrating tables from one to the other.

So, in the raw material Quality Threat Analysis, it becomes a question as to the scope and extent of the information required to be a complete Quality Plan in the eyes of our certification body.

On the one hand, all ingredients are critical to ensuring a quality product, as we can't very well produce without them, on the other hand, well there is no other hand actually in that respect. So, it becomes a matter of what exactly, if anything needs to be listed as such.

At this point, I believe I'm overthinking everything, and probably need to step back, take a breath, and reevaluate the steps needed to make a smooth transition from level 2 to level 3. 

Perhaps eliminating this section of our analysis?

[Charles.C]

Hi ehamilton,

 

Just out of curiosity, how do you control yr raw material inputs in  yr HACCP Plan ? Designated as Prerequisites?

[ehamilton]

Hi ehamilton,

 

Just out of curiosity, how do you control yr raw material inputs in  yr HACCP Plan ? Designated as Prerequisites?

Yes Charles C,

     Prerequisite plans cover the incoming raws and storage thereof. I'm guessing this is your line of query?

Allergen Control, Supplier Verification, Pest Control, etc.

[Charles.C]

Hi ehamilton,

 

Thks yr response.

 

I was speculating since (a) I don’t use SQF myself, (b) I cannot find a single "representative" example of a SQF Food Quality Plan on this Forum.

 

As I understand SQF expect you to present a  food QUALITY plan (fqp) by following an analogous path to that used in the Food SAFETY plan (fsp).

 

I deduce yr fsp has no such entity as “critical raw materials” from a CCP POV since this risk aspect is controlled within the Prerequisite program. Such an approach appears to be in line with SQF para 2.4.5 which also includes Quality.

 

It seems to me that this SQF Code format implies that their terminologies  “Process” and “Production” refer to the activities subsequent to reception of incoming material inputs. This seems consistent with the SQF glossary def. of “Processing” - The processing of food through one or more steps in which the nature of the food is changed……

 

As per the above I suggest the term “critical raw material” has no meaning  for fsp or fqp in the context  of the terminologies CCP and CQP.

 

I repeat the above is purely speculative since SQF auditors are well-known to occasionally adopt what may seem quite illogical interpretations to some observers regarding  the text of SQF Code, Guidance and Glossary.  

Nonetheless I expect that routine SQF users will well know the veracity or otherwise of above, ie YES, NO or something in-between.

 

PS - i don't quite understand the popularity of "quality threat"  since cud be confusing with "vulnerability" although i equally dislike the SQF term "quality hazard". New word ?

 

PPS - this thread has an intriguing completed layout but with an invisible reasoning, generating some quite useful advice -

 

http://www.ifsqn.com...hod/#entry61955

 

P3S - Maybe you will get lucky and match this thread -

 

http://www.ifsqn.com...qps/#entry62293

 

P4S - This example has some relevant material to qfp -

 

 Development SQF Safety-Quality Food Plans.ppt   2.68MB   577 downloads

[Charles.C]

corrigendum
 

 

It seems to me that this SQF Code format implies that their terminologies  “Process” and “Production” refer to the activities subsequent to reception of incoming material inputs. This seems consistent with the SQF glossary def. of “Processing” - The processing of food through one or more steps in which the nature of the food is changed

 

After some rethinking, the above is probably incorrect - "process" is not correlated to  "processing". The former should include all the stages between reception and (typically) exit from the manufacturing facility as defined in the scope of the fsp/fqp.

 

This does not alter the (conventional) interpretation/usage of Prerequisite Programs within the fsp so i tentatively maintain the logic for the fqp also (if required).