7 replies to this topic

[smittyjr]

I might have posted this in the wrong area but just tell me....>>>>>> Hi guys I want, no I need help..     okay so it is all related to the HARPC and FSMA.  I have researched for days and I have a million and 1 websites and articles but i still have no idea what is the logical next move. Okay so I have HACCP and I have 1 CCP, what I am unsure of is.. Do I just add radiological to my hazard analysis? Do I need to do a different flow chart and what would it include? Since the Radiological is potentially by water or disaster do i now have to add that to my water testing? Do i need to do air smaples?  Do I just start over and go with each and every prerequisite and make it into a preventative control and in what format do I do that? I am overthinking it   I know but this is what was handed to me as my project and i want it to be right. I know the rules have not yet been put into place but everything i have read says start now... HEEELLPPPPPP ME!! Thank you in advance for your help and patience.   

Brandi

 

[sail1234]

Hi Brandi:

 

I am  in the same boat as you, but here is what our 3rd party auditor told us in February 2015 on HARPC....and I am quoting here, "Your HACCP meets HARPC requirements.  HARPC is for those who did not have HACCP.  You do need to look at and add radiation and affafloxins.  Make sure you have SDS versus MSDS registrations for chemicals."  We produce Salad Dressing and have 2 CCP's...we are a smaller company as well.  Keeping an eye on all this too...

 

Good Luck and hope this helps a little,

Sharon

[smittyjr]

Hi Brandi:

 

I am  in the same boat as you, but here is what our 3rd party auditor told us in February 2015 on HARPC....and I am quoting here, "Your HACCP meets HARPC requirements.  HARPC is for those who did not have HACCP.  You do need to look at and add radiation and affafloxins.  Make sure you have SDS versus MSDS registrations for chemicals."  We produce Salad Dressing and have 2 CCP's...we are a smaller company as well.  Keeping an eye on all this too...

 

Good Luck and hope this helps a little,

Sharon

Thank you Sharon,  I am glad i'm not alone ...lets keep eachother posted.. ;-)

[clbernard]

I would suggest that you rethink your HACCP plan to potentially include radiological.  You mention that the source would be water, so it appears that you might have a hazard, but determine if the hazard is significant and likely to occur then include or exclude according to your findings.  If the source is a disaster then the issue could be included in your Crisis or Business continuity plan.  The trigger for testing could be driven by the level of potential hazard and its likelihood of occurrence.  You do not mention your product so other hazards could also need to be considered, including intentional contamination.  

 

Preventative controls are really just a continuation of the verification, validation cycle that we tend to short-circuit.  If you have a hazard do you have a control, is that control effective?  Do the documents show the hazard is being controlled consistently and if not are their documented corrective actions that indicate the gap was addressed from an immediate product safety aspect in addition to prevention of re-occurrence?

 

I mention my logic behind each identified hazard within my plan as to it's significance and it's likelihood of occurrence then I go on to mention what programs control that hazard.  This list is then my official PRP.

[smittyjr]

Thank you clbernard, I forgot to mention we package Rice, we reveive a 2000,00 lb tote of dry rice and we bag it in 10lb bags. I am very confused about all of it, i understand what you are saying but i always have had trouble with a hazard analysis so this makes it even harder.   I have watched a few webinars and i have been on many websites and that is where there was mention of the radiological being in either the water or a disaster, i can just add that box next to chem,phy,bio. I can do that i guess but the rest has me lost too, it says about making new flow charts? to include what?  and that its not really ccp but prevenative controls.I just need a list..uuggghhh I have no clue what is happening. if you say yes just add radio to your haccp plan and call it a day that is fine, but what i have been reading is that it is way more than that and i have no clue. Did you do it clbernard? why am i struggling with this..

thank you for reading my rant... save me

[FSQNNow]

I highly recommend looking over this presentation and webinar: Among all the

http://www.nwfpa.org...FPAORG_2014.pdf

https://www.youtube....h?v=uhfyYKsL6Dw

This was done around Feb 2014.

 

AIB has also published a bit later: (sept 2014)

https://www.aibonlin...entiveHuman.pdf

https://www.aibonlin...ntiveAnimal.pdf

https://www.aibonlin...pdates/FSVP.pdf

http://www.aibonline...oodContact5.pdf

 

 We are now (eagerly?!) awaiting publication of final versions and then can assess any changes to above.

 

NB. I am not linked to AIB!

[smittyjr]

Thank you!

[boohblake]

Thank you for all who gave information about HARPC