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Hazard Analysis for Beer Distributor

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Cronkk

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Posted 02 May 2016 - 06:31 PM

Hello Everyone,

 

I am in the process of a new job with some product Im very unfamiliar with.  We are a beer distributor and do not manufacture or process of any kind.  We have cases that come to us from the MFG and we receive, store, pick, then ship.  We do have some items that come into us as a case and we do pick them by the each.  So if the case of wine has 9 sales we will open the cases and sell 1 bottle of wine. 

 

I have attached an HA for our beer product and it seems like it would be sufficient for the FDA and our NSF GMP audits.  Could I get some advice and direction on this. 

 

Thank you!

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Cronkk

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Posted 02 May 2016 - 06:35 PM

Here is the flow diagram.

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Sussy

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Posted 02 May 2016 - 06:42 PM

this looks way to complicated for a sealed product. 

 

Firstly, pest infestation is not a biological hazard. secondly, you do not have any allergen or cross contamination hazards as this is a sealed product and it is very unlikely that the product cross contaminates, besides, if one beer mixes with the other, it is not a health risk. you do not produce stuff in your place either so whatever allergen is not on the label is unlikely to get into the product at that point. the only significant hazard is breakage, so you have to have a glass policy in place. 

 

pest infestation should be taken care by SOP and prerequisite program and therefore it does not go onto your hazard analysis.

 

make it simple. it's easier for everyone



Cronkk

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Posted 02 May 2016 - 06:56 PM

this looks way to complicated for a sealed product. 

 

Firstly, pest infestation is not a biological hazard. secondly, you do not have any allergen or cross contamination hazards as this is a sealed product and it is very unlikely that the product cross contaminates, besides, if one beer mixes with the other, it is not a health risk. you do not produce stuff in your place either so whatever allergen is not on the label is unlikely to get into the product at that point. the only significant hazard is breakage, so you have to have a glass policy in place. 

 

pest infestation should be taken care by SOP and prerequisite program and therefore it does not go onto your hazard analysis.

 

make it simple. it's easier for everyone

I see what you are saying.  I updated it.  I highlighted a block because I think the working I used is incorrect.

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Sussy

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Posted 02 May 2016 - 07:03 PM

why retrieval and cross dock? arent they one and the same thing?



Cronkk

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Posted 02 May 2016 - 07:07 PM

why retrieval and cross dock? arent they one and the same thing?

Cross docking for us is spirits coming over from our liquor building that need to go on the beer truck for delivery.  Retrival is taking it from our building stock.  Also the NSF auditor said we needed it.

 

NC: The Hazard Analysis did not include the following process steps included in the flow
diagram; retrieval, cross dock and driver returned products.



Sussy

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Posted 02 May 2016 - 07:13 PM

If it is in you flow diagram then it has to be in your hazard analysis. I would suggest to make your flow diagram simpler as well. 

 

It is basically

 

receiving

storage

retrieval [you can specify "from 2 warehouses"]

maybe repacking [for smaller than case orders]

shipping and distribution



Cronkk

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Posted 02 May 2016 - 07:16 PM

If it is in you flow diagram then it has to be in your hazard analysis. I would suggest to make your flow diagram simpler as well. 

 

It is basically

 

receiving

storage

retrieval [you can specify "from 2 warehouses"]

maybe repacking [for smaller than case orders]

shipping and distribution

Hmm.  I will attempt to rework the flow diagram.  That is one thing I want to work on once im officially in the position.  Also the highlighted section on the HA, would the verbiage be acceptable to GFSI (SQF/BRC) auditor?



Sussy

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Posted 02 May 2016 - 07:33 PM

yes it will. You need the manufacturers GFSI certification on file to prove that the product you get meets your safety standards.you can add on the HA in parenthesis that supplier certificate on file



Cronkk

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Posted 02 May 2016 - 07:39 PM

thank

 

Hmm.  I will attempt to rework the flow diagram.  That is one thing I want to work on once im officially in the position.  Also the highlighted section on the HA, would the verbiage be acceptable to GFSI (SQF/BRC) auditor?

Thank you.  Im going to go through the flow diagram and update the HA accordingly.



Charles.C

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Posted 03 May 2016 - 01:01 PM

Hi Biddlecom,

 

I have no experience with storage / distribution operations.

 

If you are interested in BRC or SQF, i suggest you download their Standards and do a Gap Analysis. The Standards  contain the specific requirements as to the scope to be responded to in yr HACCP plan / hazard analysis, etc.

 

Presumably the same applies to NSF. FDA I have no idea.

 

There are many ways to present a hazard analysis / haccp plan, all valid. It may depend on the specific standard / auditor as to most appropriate.

 

It is important to remember that a hazard analysis is specific to yr own situation / flow although generic versions give some typical ideas.

 

You seem a little confused between PRPs and CCPs. This should be evident from the Standard's text.

 

Maybe have a look at this SQF post / haccp plan / thread. There are several other S&D threads on this forum.

 

http://www.ifsqn.com...age/#entry87788

 

http://www.ifsqn.com...bution-company/

 

I have never seen a flow chart with questions on it before.  Nice colours though. :smile:


Kind Regards,

 

Charles.C


Kellio

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Posted 03 May 2016 - 01:51 PM

I suggest you look into SQF, BRC or IFS Storage and Distribution standards. There will be more robust than a NSF GMP Audit. These standards will bring you closer to FDA requirements. The Documentation is free to download on their websites.



Charles.C

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Posted 03 May 2016 - 03:25 PM

Hi Kellio,

 

Are the FDA requirements in Puerto Rico  the same as USA ? (Just curious)


Kind Regards,

 

Charles.C


Cronkk

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Posted 03 May 2016 - 03:56 PM

How does this look.  I added numbers for the RBA.  Both files are attached.

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Charles.C

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Posted 03 May 2016 - 05:01 PM

Hi Biddlecom,

 

May i ask who (or what Standard) is this intended to be compliant to ? FDA ? NSF ? .

 

Or perhaps you haven't got that far yet ?

 

I would imagine a GMP audit does not require a hazard analysis ?


Kind Regards,

 

Charles.C


Cronkk

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Posted 03 May 2016 - 05:06 PM

Hi Biddlecom,

 

May i ask who (or what Standard) is this intended to be compliant to ? FDA ? NSF ? .

 

Or perhaps you haven't got that far yet ?

 

I would imagine a GMP audit does not require a hazard analysis ?

This is for the FDA who audits us and also for when we do our voluntary GMP audit.



Charles.C

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Posted 03 May 2016 - 07:02 PM

This is for the FDA who audits us and also for when we do our voluntary GMP audit.

 

Hi biddlecom,

 

Thks for response.

 

i apologize for my ignorance since I'm not in USA but is there any specific link as to the FDA's requirements ? If not, never mind. The point is that IMEX every Standard / regulatory body have some individual expectations of their own which may differ to all the others and dictate the associated HA, etc.

 

I don't use the US table format for haccp so other people are better equipped to comment on the details in this layout. Personally in my style i include items like glass breakage  directly under the heading of "potential hazard" while the BCP text is  under a "category" heading. But maybe just different style.

 

The usual order of preparing a FS system is to initially decide which PRPs are necessary (basically setting up a GMP system/SOPs/SSOPs). The PRPs  may be pre-defined by the auditing body, eg FDA.

 

Next the usual procedure is to implement a haccp plan if required, in Europe this usually follows the various steps of  Codex, in yr case presumably  NACMCF as interpreted by FDA.

 

It is crucial to generate a workable flowchart since the hazard analysis must match this. This is IMEX the first thing any auditor usually checks by "walking the production walk."

 

I notice at the moment you have 2 separate flow paths for dry/refrigerated. IMO the HA should show this if both are required to be maintained.

 

I assume the "refrigerated" path relates to quality factors only so will not be involved in haccp safety evaluations..

 

i agree with most of comments of sussykraus in Post 3. Some typical (for me) examples of flow charts are in the links/sub-attachments of my post 11.

 

Basically this should be  a very simple HA if no hazards other than those controlled by PRPs, ie no CCPs. Yr layout generally looks similar to that for equivalent hazards in the files I previously linked to and seems reasonable to me though maybe needs a little "elaboration"/expansion. It is important that it makes sense when compared to the Flowchart.

 

I anticipate that the only problem you consider of any operationally extent  relates to broken glass which will presumably be detailed in the PRP-SOP. The only comment is that if there is an excessive number of reported incidents you might find an auditor will suggest it should be a CCP since the PRP not adquately controlling. Unless it's normal for the Industry.

 

All risk matrices are subjective.  I don't quite understand  the intended separation of grey/red cells in yr template. IMEX both would be handled by CCPs. Otherwise the text looks internally feasible to me although quite different to my own usage.  Maybe this format is typical for brewing Industry.

 

Hope the above makes sense.


Kind Regards,

 

Charles.C




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