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Allergen Hazard Risk

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Jvalentin

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Posted 12 February 2018 - 07:34 PM

HI All, 

So we are a Tea Company that only repackages raw material and tea is a very low risk product.  We basically receive the tea in bulk and repack to resell.  We have well over 100 sku's along with tea bags as well as gift sets.

We have a strong supplier approval in which all my vendors have either SQF certifications or a really strong HACCP plan and GMP's in place.  

My question is that I wrote out our HACCP plan and have no CCP's and did a hazard analysis on all my processes.  One of the only risks we have preventative control measures on are allergens.  As far as doing a Allergen Hazard Risk Assessment do I have to do that on ALL of our sku's? Or can I break the tea down to variations ex: green, black, oolong and write it out that way?      

We do not have any allergens based on what we receive from our suppliers and their specs on the product.  I still have a SOP on how to receive, segregate and handle allergens if that day comes that we decide to carry them. 

Thank you in advance

John



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Posted 12 February 2018 - 08:09 PM

Break it down by segment.


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Charles.C

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Posted 13 February 2018 - 04:06 AM

HI All, 

So we are a Tea Company that only repackages raw material and tea is a very low risk product.  We basically receive the tea in bulk and repack to resell.  We have well over 100 sku's along with tea bags as well as gift sets.

We have a strong supplier approval in which all my vendors have either SQF certifications or a really strong HACCP plan and GMP's in place.  

My question is that I wrote out our HACCP plan and have no CCP's and did a hazard analysis on all my processes.  One of the only risks we have preventative control measures on are allergens.  As far as doing a Allergen Hazard Risk Assessment do I have to do that on ALL of our sku's? Or can I break the tea down to variations ex: green, black, oolong and write it out that way?      

We do not have any allergens based on what we receive from our suppliers and their specs on the product.  I still have a SOP on how to receive, segregate and handle allergens if that day comes that we decide to carry them. 

Thank you in advance

John

 

Hi John,

 

JFI I enclose an example of a haccp plan for tea.

 

The plan has 3 CCPs. As presented, the hazard analyses for all 3 CCPs are IMO flawed however the 2nd/3rd ones might be validatable if appropriately "hazard analysed".

 

Attached File  haccp plan tea.pdf   119.6KB   192 downloads


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Charles.C


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Posted 16 February 2018 - 05:28 PM

As suggested, break it down by groupings, don't have to do individually.

 

I would say, get more information from your suppliers on allergens such as if they have any shared equipment with allergens and the materials you purchase from them.  Or other allergens in their facility.  You need this information to determine actual risk and may consider doing spot testing of raw materials you bring in from various suppliers based on allergen risk with different allergens.  This is actually going to be more important as the PC rule of FSMA comes into enforcement.







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