12 replies to this topic

[May Thu Zaw Myint]

Dear All food safety experts,

 

I am currently working in baking industry and I am newly just a month here. I am struggling to get HACCP cert here. I have some doubt and I hope someone reply my question as below:

 

1. my raw materials are not having COA. Is it ok for the audit?

 

2. Finished product are not having physical and chemical testing except in process water testing. Is it ok for the audit?

 

Sincerely,

May

 

[Charles.C]

Dear All food safety experts,

 

I am currently working in baking industry and I am newly just a month here. I am struggling to get HACCP cert here. I have some doubt and I hope someone reply my question as below:

 

1. my raw materials are not having COA. Is it ok for the audit?

 

2. Finished product are not having physical and chemical testing except in process water testing. Is it ok for the audit?

 

Sincerely,

May

 

Hi May,

 

Welcome to the Forum !

 

Pls inform which FS Standard is involved (if any).

[May Thu Zaw Myint]

Hi Charles,

 

I am going under EU standard.

[Charles.C]

Hi Charles,

 

I am going under EU standard.

 

Hi May,

 

Do you mean the Codex haccp Guidelines ?

 

I deduce no GFSI-recognised Private Standards are involved, eg BTC, SQF ?

[Charles.C]

addendum

 

Hi May,

 

I can offer a general answer to yr queries. Specific answers may depend on the actual inputs involved and the text of the Standard used for audit.

 

(1) IMEX COAs are not generally mandatory for raw material lots but may be expected depending on the type of raw material. If COAs not available, monitoring of incoming lots is probably unavoidable. IIRC, some private Standards do specify COAs  be available.

 

(2) Finished Product testing is typically part of the haccp Verification Stage.The scope of the testing will depend on the actual material(s) involved and the haccp plan.

[May Thu Zaw Myint]

Hi Charles,

 

Thanks for your answer.

 

But for ans no. 2, some of my product are freshly baked and last for 2 or 3 days. When micro testing is taking 48 hr to know the result, I can make it business. Please suggest me.

 

Sincerely,

May

[Charles.C]

Hi Charles,

 

Thanks for your answer.

 

But for ans no. 2, some of my product are freshly baked and last for 2 or 3 days. When micro testing is taking 48 hr to know the result, I can make it business. Please suggest me.

 

Sincerely,

May

Hi May,

 

i think you are referring to microbiological "positive release" of the finished product ?

 

This is not automatically mandated in haccp.  It's usage depends on the length of shelf life, risk level, etc.

(In fact one of the objectives of haccp was/is to reduce the level of microbiological testing as performed in traditional Food Quality Assurance).

 

But micro. testing is a typical requirement for on-going haccp Verification.

 

Maybe have a look at this document -

 

 EC Micro.Criteria Guidance Ed.1.2.pdf   1.54MB   178 downloads

[May Thu Zaw Myint]

Hi Charles,

 

Thanks for your guidance. It help me a lots.

 

 

 

Cheers,

May

[anytal]

Dear All food safety experts,

 

I am currently working in baking industry and I am newly just a month here. I am struggling to get HACCP cert here. I have some doubt and I hope someone reply my question as below:

 

1. my raw materials are not having COA. Is it ok for the audit?

 

2. Finished product are not having physical and chemical testing except in process water testing. Is it ok for the audit?

 

Sincerely,

May

Hi May,

Here is my first post in here :)

 

We do not test our raw materials either. We get COA for high risk raw materials only - like gluten free flour etc (used in finished products with Gluten free claim). For some raw material we get COA annually to verify compliance with spec. But annual certificate of conformance from suppliers for the rest of raw materials is sufficient.  Of course the intake inspection must be carried out to ensure raw materials are per agreed product specifications and the intake operators have all the inspection points written down for each raw material (what to look for at the delivery ). This is sufficient for all auditors we had including BRC. I didn't mention - all our suppliers are BRC approved. The need of raw material testing would depend on your raw material risk assessment. You would have to categorized them e.g. high, medium, low to see if you need COA with each delivery,  COA annually (e.g. for medium risk raw materials) or annual COC is ok. This is only example.

 

Our products don't go through any physical/chemical testing but we have product release procedure in place  --> supervisors/managers sign off that there was no deviation to the process during batch production, all packs were metal detected, visual inspection of product for foreign bodies, packaging condition, correct labeling (allergens, use by date etc) in in place. Process water is the only testing is done as well. Microbiological release isn't possible as our products have shelf life 7-10 days. But weekly micro testing is in place to validate product micro criteria and end of shelf life testing is carried out annually.

 

Hope that helps.

 

Regards,

Ela

[May Thu Zaw Myint]

Dear Ela,

 

Greatly thanks for your perfect answer.

 

 

Cheers,

May

[Charles.C]

Hi May,

Here is my first post in here :)

 

We do not test our raw materials either. We get COA for high risk raw materials only - like gluten free flour etc (used in finished products with Gluten free claim). For some raw material we get COA annually to verify compliance with spec. But annual certificate of conformance from suppliers for the rest of raw materials is sufficient.  Of course the intake inspection must be carried out to ensure raw materials are per agreed product specifications and the intake operators have all the inspection points written down for each raw material (what to look for at the delivery ). This is sufficient for all auditors we had including BRC. I didn't mention - all our suppliers are BRC approved. The need of raw material testing would depend on your raw material risk assessment. You would have to categorized them e.g. high, medium, low to see if you need COA with each delivery,  COA annually (e.g. for medium risk raw materials) or annual COC is ok. This is only example.

 

Our products don't go through any physical/chemical testing but we have product release procedure in place  --> supervisors/managers sign off that there was no deviation to the process during batch production, all packs were metal detected, visual inspection of product for foreign bodies, packaging condition, correct labeling (allergens, use by date etc) in in place. Process water is the only testing is done as well. Microbiological release isn't possible as our products have shelf life 7-10 days. But weekly micro testing is in place to validate product micro criteria and end of shelf life testing is carried out annually.

 

Hope that helps.

 

Regards,

Ela

 

hi Ela,

 

Thks for yr post and Welcome to the Forum !

 

I deduce yr info. is basically aligned to BRC7 Standard.

 

I daresay it's debatable but IMO yr "validate" = haccp Verification.

 

I'm curious how you validate a 7day shelf life ?

 

Yr finished product is not mentioned but i am also curious as to why the flour ingredient is classified as a high safety risk ? i would have expected the exact opposite. High because no labelled allergen warning ?  Or is this risk assessment result based on non-safety related factors (ie peculiar to BRC), (if either of the previous reasons I deduce the high rating will likely be mis-matched to the OP's current, traditional haccp situation). Just interested.

 

JFI I believe some facilities producing ca.1 week shelf-life products do a "restricted' microbiological release (Enterobacteriaceae) while product in transit to a distribution centre so that recall still feasible. (Not that I'm disputing the haccp logic of release based on specific process implemented control measures including the product specification as appropriate.)

[anytal]

hi Ela,

 

Thks for yr post and Welcome to the Forum !

 

I deduce yr info. is basically aligned to BRC7 Standard.

 

I daresay it's debatable but IMO yr "validate" = haccp Verification.

 

I'm curious how you validate a 7day shelf life ?

 

Yr finished product is not mentioned but i am also curious as to why the flour ingredient is classified as a high safety risk ? i would have expected the exact opposite. High because no labelled allergen warning ?  Or is this risk assessment result based on non-safety related factors (ie peculiar to BRC), (if either of the previous reasons I deduce the high rating will likely be mis-matched to the OP's current, traditional haccp situation). Just interested.

 

JFI I believe some facilities producing ca.1 week shelf-life products do a "restricted' microbiological release (Enterobacteriaceae) while product in transit to a distribution centre so that recall still feasible. (Not that I'm disputing the haccp logic of release based on specific process implemented control measures including the product specification as appropriate.)

 

Hi Charles,

Thank you for your comment!

My assessment is based on allergen / micro/ chemical/ physical / legality/ quality etc factors but including raw material characteristics as well as risk during production/processes through to final product and intended use of finished product.

As our gluten free product is intended to be consumed by coeliac – the risk of getting gluten in the flour (manufacturer handles and process gluten as well) is relatively low to medium but consequences of it are pretty high – coeliac suffer allergy reactions and of course  instant recall if gluten found. So I could not operate without certificate of analysis for each batch received/or testing each batch at intake. This makes the raw material high risk to me.

Maybe it is a wrong approach for risk assessment of raw materials but it works for me…for now of course  :)

 

Regards,

Ela

[Charles.C]

Hi Charles,

Thank you for your comment!

My assessment is based on allergen / micro/ chemical/ physical / legality/ quality etc factors but including raw material characteristics as well as risk during production/processes through to final product and intended use of finished product.

As our gluten free product is intended to be consumed by coeliac – the risk of getting gluten in the flour (manufacturer handles and process gluten as well) is relatively low to medium but consequences of it are pretty high – coeliac suffer allergy reactions and of course  instant recall if gluten found. So I could not operate without certificate of analysis for each batch received/or testing each batch at intake. This makes the raw material high risk to me.

Maybe it is a wrong approach for risk assessment of raw materials but it works for me…for now of course  :)

 

Regards,

Ela

 

Hi Ela,

 

Thks yr reply.

 

One thing for sure is that BRC certainly dodged a few bullets by avoiding any Glossary definitions/Interpretations of "Raw Material Risk Status".

 

It may depend on yr location but I deduce that if similar to the UK, the situation you describe is highly "subjective" from a "risk status" POV, eg as per the extract below - 
 

Caterers can only use the phrase ‘gluten-free’ if they can demonstrate that, when tested, their product is 20 parts or less of gluten per million. They will also be required to demonstrate that any products claiming to be 'very low gluten' also comply to the legislation.

 

Caterers producing foods with no deliberate gluten containing ingredients, but due to the high risk of gluten cross-contamination, will be unable to label foods as ‘gluten-free’ or ‘very low gluten’. Instead, if steps have been taken to control gluten cross-contamination, caterers will be able to indicate which foods do not contain gluten containing ingredients. This allows people with coeliac disease to make choices about the food they eat based on their individual levels of sensitivity

 

http://allergytraini...onsumer-advice/

 

I agree that a conservative viewpoint of the above could take a "high risk" option although as i understand the above extract would also specifically exclude product labelling statements such as "gluten-free". The above extract seems to me a rather Russian Roulette scenario for people suffering from coeliac disease, ie Thanks but No Thanks. 

 

I can certainly understand yr requirement of COAs in this situation. I  presume this facilitates the use of a PRP at the raw material reception stage.

 

However, unless the OP is also faced with a situation of above complexity, I anticipate they will need a labelling CCP with a "contains gluten" statement  and a Risk status of Low. Unless further local legalities dictate of course.