5 replies to this topic

[chen]

Hi Everybody,

I am newly registered here and I am here to seek some advice.

My family own a traditional Chinese Pastry shop in Malaysia. We are moving away from the open sweaty kitchen concept with a view to seek HACCP certification in 2-3 years. Right now we are planning to mechanized our operations and I would be glad if experience form members here can give me some advice or comments.

For my steaming process (100C), my fabricator told me that food grade plastic steaming trays are acceptable but stainless steel is preferred. I would like to reuse the food grade plastic trays that I am currently using. Is it OK.

The new process is entirely enclosed except at certain areas like packing. Is it alright if I compartmentalized only these areas and leave the other areas open (but still within the factory building).

We operate in an industrial area where the buildings are designed more for manufacturing - with more than 20 feet high roof and vents for ventilation. Is it compulsory to have false ceilings as advised by some?.

I shall be grateful for any help or advice as at present its too premature to engage a consultant.

Thanks in advance.

[Charles Chew]

Hello Chen,

You mentioned that your family owns a pastry factory in Malaysia with an intention to move towards HACCP Program but also indicated that its premature to engage a Consultant. I, however, like to encourage you to reconsider your decision on this since the Malaysian Government provides a "matching grant" for companies pursuing HACCP notwithstanding the fact that getting it right the first time during pre-implementation planning stage is vital in avoiding unnecessary future renovations/corrections to "undo" errors.

Anyway, to your questions, these are my opinions:

a. I am afraid your fabricator is not a FSMS Consultant so it really does not help. You may want to validate your plastic trays to be food grade including the known maximum tolerant temperature before leaching / migration of chemicals occur.

b. Its good to know that most of the processes are enclosed. However, the final products to be packed at the "primary packaging"stage remains extremely important to ensure food safety remains as intended. Suitable and adequate protection therefore remains necessary at this stage. Because your processes involve "steam", you may want to consider ventilation and roofing height in view of potential condensation fall-back.

All the best.

[chen]

Hi Charles,

Many thanks for your reply. I noticed that you are one of the resource persons here and I gained a lot of knowledge reading your various posts.

I am aware of the government grant. However, we we founded as an enterprise and I am in the process of converting it to a private limited company to be eligible for the grant. This may take a while as I need to come out with audited accounts also.

Meanwhile I am concentrating on the planning for the new factory. And yes, our fabricator is definately not qualified in this field but they do have experience with many food processing factories.

With regards to the plastic steaming trays, we were given to understand by the supplier that its good for temperatures up to about 140 degrees C. I think normal steaming should be in the temperature range of about 100 degrees C. With regards to steam and condensation, they do suggest extractor fans at appropriate areas.

I had met with a number of Consultants on my trips to exhibitions etc in Kuala Lumpur. but I sometimes get very different advice. Cannot really blame anybody because nobody really had a look at my existing operations and/or until we gave them an official engagement.

I will take note of your advice and may engage the service of a consultant before I finalize the machinery and layout plan.

Thanks again.

Hello Chen,

You mentioned that your family owns a pastry factory in Malaysia with an intention to move towards HACCP Program but also indicated that its premature to engage a Consultant. I, however, like to encourage you to reconsider your decision on this since the Malaysian Government provides a "matching grant" for companies pursuing HACCP notwithstanding the fact that getting it right the first time during pre-implementation planning stage is vital in avoiding unnecessary future renovations/corrections to "undo" errors.

Anyway, to your questions, these are my opinions:

a. I am afraid your fabricator is not a FSMS Consultant so it really does not help. You may want to validate your plastic trays to be food grade including the known maximum tolerant temperature before leaching / migration of chemicals occur.

b. Its good to know that most of the processes are enclosed. However, the final products to be packed at the "primary packaging"stage remains extremely important to ensure food safety remains as intended. Suitable and adequate protection therefore remains necessary at this stage. Because your processes involve "steam", you may want to consider ventilation and roofing height in view of potential condensation fall-back.

All the best.

[Charles Chew]

I am not sure of the composition of your end product but if it contains meat and you are of a view to export, you may want to consider getting MOH to certify you but under the current situation when ISO 22000 is certain of being released as EN ISO 22000:2005, you may want to consider this scheme as well since it would be almost certain to involve a reivew of the mutual food safety trade agreement between EU and the rest of the world which could make HACCP only a mere composite requirement.

As a matter of fact, I do know that the Malaysian Govt. Agencies are currently into acquiring as much technical knowledge as possible in the area of ISO 22K and it would appear that a major change is inevitable.

With regards to application for grant from enterprise to private limited company status, submission may run concurrently base on past accounting records so long as conversion is legitimate and is seen as a "flip-over"

At this moment, I can only speculate that given EU Reg 178/2002 which makes HACCP compulsory, there could be a possibility of a hybrid type of HACCP program that may be acceptable during a certain grace period for conversion to full ISO 22K. Nevertheless, this is where it separates the men from the boys.

Getting a feet into the future EU market is certainly going to be a remarkable task but once you are in, the harvest is in the picking.

[chen]

Good Morning Charles,

60% of our products are exported to Singapore and I had always had queries on when we are going for our HACCP. I was told that MOH had a long queue or backlog for certification of about a year. For the Singapore market, they are OK with any reputable international CB.

With regards to ISO 22000, I am aiming for it as it is the latest. I was told that SMIDEC recomend it when you go for grants but MOH is dragging its feet over this matter for reasons best known to them. I dont know how true is this.

Anyway thanks again for the various ideas - I need to really open my mind and eyes on it.

I am not sure of the composition of your end product but if it contains meat and you are of a view to export, you may want to consider getting MOH to certify you but under the current situation when ISO 22000 is certain of being released as EN ISO 22000:2005, you may want to consider this scheme as well since it would be almost certain to involve a reivew of the mutual food safety trade agreement between EU and the rest of the world which could make HACCP only a mere composite requirement.

As a matter of fact, I do know that the Malaysian Govt. Agencies are currently into acquiring as much technical knowledge as possible in the area of ISO 22K and it would appear that a major change is inevitable.

With regards to application for grant from enterprise to private limited company status, submission may run concurrently base on past accounting records so long as conversion is legitimate and is seen as a "flip-over"

At this moment, I can only speculate that given EU Reg 178/2002 which makes HACCP compulsory, there could be a possibility of a hybrid type of HACCP program that may be acceptable during a certain grace period for conversion to full ISO 22K. Nevertheless, this is where it separates the men from the boys.

Getting a feet into the future EU market is certainly going to be a remarkable task but once you are in, the harvest is in the picking.

[Charles Chew]

Hello Chen,

Yes, MOH has always been slow due to the lack of suitably qualified food auditors and the matter would further highlight their weaknesess with ISO 22K as they have no qualified food auditor in this area at all, at least for now.

Again, a lot of FSMS Consultants claim to know how to implement an ISO 22K in Malaysia and IMO, you need to be really careful here as it is a new standard and indeed, only a handful so far that i know off are able to do so.

If your Singapore client does not require MOH HACCP then it is a straight forward issue and indeed going for ISO 22K would solve the entire problem as I do forsee HACCP as only a composite guideline rather than a specific requirement in the near future.

SMIDEC is right to encourage you to go for ISO 22K since certifcated to it would allow your company a big window to your export program. However, do remember that the effectiveness of your system lies in comprehensiveness of your implementation while the real quality is NOT in the CB (its only a name) but rather the quality of your audit and the qualification of your food auditor.