9 replies to this topic

[QM-OS]

Hello all,

 

I'm hoping for some help and potential inspiration.

We've recently recieved a minor complaint from our internal auditor that we don't have a document which lists all the potential hazards in our HACCP plan, according to 2.7.1.

 

We have previously referred to our hazard analysis where we have done everything according to regulations;

• All process steps (same on the flowcharts), product groups (incl water and packaging) are covered.
• Biological, physical, chemical and allergens risks are considered on each steps and for each product groups, that also describe in detail which potential risk we mean.
• We have risk assesed all steps and lists preventative and following actions which can reduce risk.

 

So now I'm confused as to what this required "list" of potential hazards should cover, that the analysis doesn't? 

 

 

Could someone please help me with this?

[jcieslowski]

The standard says:  

 

The HACCP food safety team shall identify and record all the potential hazards that are reasonably expected to occur at each step in relation to product, process and facilities. This shall include hazards present in raw materials, those introduced during the process or surviving the process steps, and allergen risks (refer to clause 5.3). It shall also take account of the preceding and following steps in the process chain.

 

It does NOT say you need a separate document with hazards.  This is under the HACCP section - it is reasonable to assume that the standard is expecting you to list your potential hazards IN your hazard analysis, which you do.

 

In the comparison of the BRC standard to the Preventative Controls Rule, the BRC has said that their requirement is comparable to this  PREVENTIVE CONTROLS RULE: requires that a Hazard Analysis be performed to identify reasonably foreseeable hazards (biological, chemical, physical) to determine where preventive controls are require.

 

I believe your internal auditor does not fully understand the requirement and is confused on the hazard identification.

 

https://www.brcgloba...ce-document.pdf

[Charles.C]

Hello all,

 

I'm hoping for some help and potential inspiration.

We've recently recieved a minor complaint from our internal auditor that we don't have a document which lists all the potential hazards in our HACCP plan, according to 2.7.1.

 

We have previously referred to our hazard analysis where we have done everything according to regulations;

• All process steps (same on the flowcharts), product groups (incl water and packaging) are covered.
• Biological, physical, chemical and allergens risks are considered on each steps and for each product groups, that also describe in detail which potential risk we mean.
• We have risk assesed all steps and lists preventative and following actions which can reduce risk.

 

So now I'm confused as to what this required "list" of potential hazards should cover, that the analysis doesn't? 

 

 

Could someone please help me with this?

 

Hi QM-OS,

 

It's difficult to give a meaningful answer without some context.

 

2.7.1 is a standard initial requirement , eg as per Codex, to a hazard analysis.

 

The relevant potential hazards will depend on the product/process/flow stage.

 

Can you be more specific as to why yr IA thinks that yr list of potential hazards is incomplete ?

[QM-OS]

The standard says:  

 

The HACCP food safety team shall identify and record all the potential hazards that are reasonably expected to occur at each step in relation to product, process and facilities. This shall include hazards present in raw materials, those introduced during the process or surviving the process steps, and allergen risks (refer to clause 5.3). It shall also take account of the preceding and following steps in the process chain.

 

It does NOT say you need a separate document with hazards.  This is under the HACCP section - it is reasonable to assume that the standard is expecting you to list your potential hazards IN your hazard analysis, which you do.

 

In the comparison of the BRC standard to the Preventative Controls Rule, the BRC has said that their requirement is comparable to this  PREVENTIVE CONTROLS RULE: requires that a Hazard Analysis be performed to identify reasonably foreseeable hazards (biological, chemical, physical) to determine where preventive controls are require.

 

I believe your internal auditor does not fully understand the requirement and is confused on the hazard identification.

 

https://www.brcgloba...ce-document.pdf

 

 

Hi QM-OS,

 

It's difficult to give a meaningful answer without some context.

 

2.7.1 is a standard initial requirement , eg as per Codex, to a hazard analysis.

 

The relevant potential hazards will depend on the product/process/flow stage.

 

Can you be more specific as to why yr IA thinks that yr list of potential hazards is incomplete ?

 

As this was a new auditor we might have had some difficulties in understanding each other.

But as I understand it, she wanted us to have a list of all potential risk at our facility, in order to "be of assistance if someone new where to write a new hazard analysis". 

I explained that the current four hazard analysis, which have been the same for the past 10 years will be used as guidance. As I previously mentioned they all have the required information.

 

It feels like unneccessary work to make one more document with the same information which can already found in the hazard analysis ?!  

[Charles.C]

As this was a new auditor we might have had some difficulties in understanding each other.

But as I understand it, she wanted us to have a list of all potential risk at our facility, in order to "be of assistance if someone new where to write a new hazard analysis". 

I explained that the current four hazard analysis, which have been the same for the past 10 years will be used as guidance. As I previously mentioned they all have the required information.

 

It feels like unneccessary work to make one more document with the same information which can already found in the hazard analysis ?!  

 

Hi QM-OS,

 

I deduce the current risk assessment / hazard analysis(es) has satisfied BRC's expectations.

 

Again, some actual context would be useful.

 

What kind of process is involved ?

[QM-OS]

Hi QM-OS,

 

Again, some actual context would be useful.

 

What kind of process is involved ?

 

It's all our production lines, we clean and pack food stuffs in different packaging. For industries and consumers.

[Charles.C]

It's all our production lines, we clean and pack food stuffs in different packaging. For industries and consumers.

 

Thks but what kind of process, fish, eggs, meat RTE, NRTE etc

[QM-OS]

Thks but what kind of process, fish, eggs, meat RTE, NRTE etc

 

Fruit and vegetables

[Charles.C]

Fruit and vegetables

 

Hi QM-OS,

Thks.

 

Well, assuming you mean a production line for RTE fresh produce, the potential hazards relate to the inputs / the process-its complexity.

 

Just as an example of a not-so-simple flowchart -

 

 HACCP Generic Model for Ready-To-Eat Fresh-Cut Vegetables - Food - Canadian Food Inspection Agency.pdf   427.04KB   182 downloads

[QM-OS]

Hi QM-OS,

Thks.

 

Well, assuming you mean a production line for RTE fresh produce, the potential hazards relate to the inputs / the process-its complexity.

 

Just as an example of a not-so-simple flowchart -

 

HACCP Generic Model for Ready-To-Eat Fresh-Cut Vegetables - Food - Canadian Food Inspection Agency.pdf

 

This is what we have.