Jump to content

  • Quick Navigation
Photo
- - - - -

BRC 3.5.4. Outsourced Processing (CCP)

Outsourced Processing CCP HACCP 3.5.4 BRC

  • You cannot start a new topic
  • Please log in to reply
2 replies to this topic

#1 Adam.F

Adam.F

    Grade - Active

  • IFSQN Active
  • 2 posts
  • 0 thanks
0
Neutral

  • Earth
    Earth

Posted 30 January 2019 - 01:26 PM

Hi all,

 

Thank you for all your help thus far, however I'm stuck on a 3.5.4 of the BRC standard. This is also my first time posting, so please excuse any re-posting of answered questions (although i've searched high and low!)

 

We're looking at producing freshly squeezed juice, which will then be HPP'd by an external company. The product will then receive 40 days, pending shelf-life confirmation. 

 

My struggle is trying to incorporate this into our HACCP plan. As there is a chance that the product will come back to our site for boxing, it will need to be considered as an outsourced process. Therefore my question is, would this outsourced process be considered a CCP in my HACCP plan, and if so how can these be treated the same way as a CCP carried out in-house i.e. is the BRC certificate from the HPP company enough to satisfy an auditor that the CCP is managed correctly?

 

Thanks,
Adam

 

 

 

 



#2 Scampi

Scampi

    Fellow

  • IFSQN Fellow
  • 2,830 posts
  • 773 thanks
334
Excellent

  • Canada
    Canada
  • Gender:Not Telling

Posted 30 January 2019 - 01:34 PM

Adam, BRC is not my area, however, I would assume that the contracted operator would be responsible for the CCP at their end and you would be receiving the units back as finished goods/repacking/warehousing only so the processing that occurs off site does NOT belong in your plan.

 

You would then need documentation from said 3rd party company as part of your approved supplier program. But again, BRC is not my thing. Generally speaking from a HACCP point of view this would be a "hazard not controlled by the facility" In Canada, we would use a form 9. example below

 

Example of Completed Form 9: Hazards not controlled by the Operator
Product name: Spices
List here any biological, chemical and physical hazards that are not controlled by the operator Hazards Indicate how the hazard could be addressed (cooking instructions, public education, use before date, etc.) Untreated Spices / Treated Spices – Presence of agricultural chemicals (pesticides and herbicides) in spices above the maximum residue limits. Farm level – Educate farmers about good agricultural practices.
Supplier level – Obtain documentation (e.g., Letter of Guarantee, Certificates of Analysis, specifications) from suppliers to demonstrate that spices were grown, harvested and handled according to good agricultural practices. Untreated Spices / Treated Spices – Presence of heavy metals and other chemicals in spices due to water used for irrigation and fumigation on the farm and/or steam sterilization at supplier/treatment facility. Farm level – Educate farmers about good agricultural practices.
Supplier level – Obtain documentation (e.g., Letter of Guarantee, Certificates of Analysis, specifications) from suppliers to demonstrate that spices were grown harvested and handled according to good agricultural practices. Untreated Spices / Treated Spices – Contamination with agricultural chemicals, non-food chemicals in spices due to improper use of reusable containers at the farm level and/or supplier/treatment facility. Farm level – Educate farmers about good agricultural practices.
Supplier level – Obtain documentation (e.g., Letter of Guarantee, Certificates of Analysis, specifications) from suppliers to demonstrate that spices were grown, harvested and handled according to good agricultural practices.

Because we always have is never an appropriate response!


Thanked by 1 Member:

#3 pHruit

pHruit

    Grade - PIFSQN

  • IFSQN Principal
  • 602 posts
  • 236 thanks
118
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Interests:Composing/listening to classical music, electronics, mountain biking, science, sarcasm

Posted 30 January 2019 - 02:38 PM

For any outsourced processing we use, our HACCP plan ends with the last of our own processes being the output of semi-finished product to the third party processor.
I'd call this a prerequisite that is managed through the supplier approval program, so you'll just need to make sure your scope of approval for the processor/packer includes this service - effectively what you're trying to show is that they are suitably in control of the process, as it's theirs to manage.

You could gather further evidence in the form of copies of process records per batch for your own verification if you wanted to - I know several brands that do this with the pasteurisation time/temp and various other QC records for their subcontracted production, and there will be equivalents for the HPP process. Depending on how they've done their HACCP the pressure stage could be a CCP, but you'll probably want to go through this with them so you've got a good understanding of what they're trying to do (and whether they're actually achieving it).

 

N.B. I have come across contract processors who take the alternative position that it's not their material/product, and thus it is not up to them to determine things like critical limits etc. This ends up in a confusing stand-off, as the party commissioning the process doesn't know the kit and it's not their HACCP plan so they're not really in an informed position to be able to advise on such things. If you're asked this type of question then the default response to the subcontracted processor should probably be "as per your validated parameters for your process, in accordance with your HACCP plan"...



Thanked by 1 Member:




0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users

EV SSL Certificate