Evaluate my hazard analysis, Please!

So I think I have married my Food Safety Plan and my HACCP together. trouble is I always have issues with the hazard analysis section.

 

anyone willing to look over what I have here and give me feedback (good and bad).

 

and if you like it you are welcome to the file as a template.

 

Thank you!

Please provide your template then i can comment  on that  because i couldn’t see any attachment here.

Hi Quality elf,

 

We would be happy to help. Per prasanth please upload your hazard analysis.

Sorry, I thought I had attached it but I think I choose the file and didn't click the second step of actually attaching.

 

here it is.(hopefully)

First thing so far is that you can remove Quality from the Hazard analysis; quality issues are not included/necessary in the approach as they don't affect the safety of the food. I will continue to add thoughts.

On undeclared allergens you wrote 'no' under (4). This might be a typo?

Intentional and economically motivated adulteration are considered the same thing so you can just group them as one

 

Also I advise you list every packaging material and ingredient as well as all processes listed in your flow diagram and do a hazard analysis on each (B, C, P, E) biological, chemical, physical, economical.

 

I would refer to biological as microbiological as I assume some of these ingredients could contain both spore forming and vegetative microorganisms?

 

You assessed the screen but in your justification you wrote it as controlling foreign material; however you need to realize that you are looking at this from a standpoint of what hazards would be posed if the screen degraded and broke apart, e.g, metal fragments and pieces from the mesh screen, etc. You look at its composition and the degradation of the screen to know your B,C,P,E hazards. The same is true for the bulk sifter process.

This is a bakery haccp? What is this for rolls?

Why don't you do a 1-5 ranking for likelihood and severity? Your ranking will be confusing for auditors.

 

Here is an example format you can use. The likelihood and severity is represented by x/x respectively.

 

 

http://active.inspec.../introe.aspx?i=

 

Here is a link to the CFIA referance hazard database. It is a bit cumbersome to use, but includes just about every hazard for a multitude of process' and products

 

I'm also partial to this form for hazard anaylsis

http://www.inspectio...82?chap=4#s10c4

 

Scroll down until you see a "combined form 8"

 

Upon first glance at your H.A., I include the actual PRP program in the H.A., then an auditor can quickly see where that hazard falls in your specific program.  Iv'e given an example below as a snapshot

 

 

Step Incoming materials/ process steps / hazards on schematic diagram Category and identified hazard

Determine if fully controlled by prerequisite program.

* If yes = indicate "Prerequisite Program" and proceed to next identified hazard.
* If no = proceed to question 1 (Q1). B C P Q1. Could a control measure(s) be used by the operator at any process step?  Q2. Is it likely that contamination with the identified hazard could occur in excess of the acceptable level or could increase to an unacceptable level?
If no = not CCP. Proceed to the next identified hazard.

* If yes = proceed to Q3. Q3. Is this process specifically designed to eliminate or reduce the likely occurrence of the identified hazard to an acceptable level?
If no = proceed to Q4.

* If yes = CCP. Enter its number in the last column. Q4. Will a subsequent step eliminate the identified hazard or reduce its likely occurrence to an acceptable level?
If no = CCP. Enter its number in the last column.

* If yes = not a CCP. Identify subsequent (controlling) step and proceed to the next identified hazard. 2 Dry  Storage Contamination from damaged containers   √ √ Yes       Storage and Transport       11.6.1.1.       Contamination from chemicals   √   Yes       Storage and Transport       11.6.1.1.       Contamination due to  improper handling by employees √     Yes       Personnel Processing Practices       11.4.1.1       Contamination of packaging materials or ingredients due to inadequate pest control √     Yes   Pest Prevention 11.2.12.1               Bacterial contamination of packaging due to a lack of sanitation  √     Yes       Cleaning and Sanitizing       11.2.13.1      

combined 8 for sharing.xlsx   10.21KB   463 downloads

 

 

Sorry, try this one

 

Thank you JdPaul 

You're right that should be yes and not a no.

 

the last tab in the excel file is for ingredient/packaging eval

 

the 1-5 likelihood severity is the same thing as consequence (severity) and frequency (likelihood) (first tab has the score card). I like using a letter/# bc it is easier for me to not mix the two columns up which could lead to a different score.

 

and yes it is for a bakery. lots of different items run on the same line.

For raw material hazard analysis, the FDA inspectors are using this document from their Draft Guidance. (They expect you to use it as well).

 

Also, they are not likely to accept a Supplier Control at the Receive Ingredients step where you identify pathogens as a hazard. You have a baking step. They want to see a Process Control there that will "scientifically" reduce or eliminate the pathogen.

Our flour supplier specifically says in their documents that they do NOT have any Process Controls in place to eliminate things like Salmonella or e. Coli in their raw materials.
So having an Approved Supplier Program and 3rd party audits are great, but it's not going to satisfy FDA.

 

Marshall

On your process control tab, where you've listed the critical limits.........those should be the MAXIMUM size of metal that your system would allow through. So you should list the MAXIMUM size for each type of metal in this field. I would also list the actual process for any product placed on hold instead of just referring to the SOP, you've said product must be examined for metal, but it doesn't say how.

Critical Limits 1) Metal Detector present and operating.  2) No metal fragments that would cause injury or choking are in the product passing through the metal detector

 

 

I might include a reference to the master batch for packaging allergen control. If you're just looking at the label, how do you know it's correct unless you are referring to the master 

 

You've made no reference to monitoring cold storage temperatures

 

 

Generally, in column J of your hazard analysis, I would list the actual Pre Req SOP, SSOP, policy statement etc that specifically controls each of your hazards. Column J should not be empty.

As a corollary to post 12, I presume the FSMA expect the actual hazard analysis to follow a layout similar to that  exampled in a parallel thread here (which it basically does). The details are likely to depend on the process of course.

 

http://www.ifsqn.com...ample-of-harpc/

 

It's nice to see the risk assessment  (though i subjectively disagree with some of the matrix) but, IIRC, FSMA do not actually demand a quantitative calculation (despite IIRC the example in the frequently uploaded training text).

 

PS - Personally, at the metal detector step, i quite liked the dual  "hazard" as designated in a CFIA haccp example -

 

Physical

 

Presence of hazardous extraneous material (metallic) in the [RTE vegetables] due to the failure of the metal detector to detect metal.

 

Presence of hazardous extraneous material (metallic) in [RTE vegetables] due to failure of the metal detector to function as intended (e.g. line stops, alarm sounds, product is kicked off the line when metal is detected).

 

Why don't you do a 1-5 ranking for likelihood and severity? Your ranking will be confusing for auditors.

 

Here is an example format you can use. The likelihood and severity is represented by x/x respectively.

 Thank you for this. Do you perhaps have this is an excel spreadsheet format?

 

I like the way Economical Gain is indicated, as it aids for assessing food fraud at the same time as B,C, P.

 Thank you for this. Do you perhaps have this is an excel spreadsheet format?

 

I like the way Economical Gain is indicated, as it aids for assessing food fraud at the same time as B,C, P.

 

Twinkle. Yes I have added the template. I went ahead and segregated all hazards and rankings in their own column as some auditors might have a hiss about not having them segregated; however, I did not separate the justification column (you can do this if you wish).

correct me if I'm wrong but your only CCP is the metal detector and not the baking processing step? I am a little confused unless there are typos. I would also like to see  your HACCP flow diagram or HACCP decision tree if possible just to analyze   

If you are willing to share, I would like to see your template please.

xxxxx