Hazard Analysis for fraud, malicious contamination and allergens
I was wondring if anyone has an example of these hazard analysis to share. Do we need to add all of these to hazard analysis in addition to microbiologica, physical, and chemical analaysis? Allergen control is part of chemical analysis. how can we manage that. If we have a Vulnerability Assessment (5.4), isn't that cover for fraud? Thank you.
We've mentioned in in the hazard analysis largely just to spell it out for the auditor that we've considered it in accordance with the requirements of the standard, even though as you mentioned these are already covered in 5.4.
Nonetheless it's worth noting that 5.4 specifically only requires consideration of raw materials, whereas 2.7.1 is focussed on your own activities on site. Thus you may need to give some consideration to fraud hazards that could occur in your process, although as this falls into the HACCP section and there are several mentions in section 2 regarding "food safety" hazards, one has to assume that these are only adulteration activities that have potential consequences for food safety - any adulteration is potentially a regulatory/quality "hazard", but that isn't quite the same thing.
You may have already done this elsewhere - for example we have had a full analysis of our process flow separately in a security systems assessment, so other than mentioning adulterated goods being a possible hazard at the incoming raw material stage (but not a significant one due to other systems in place...), we simply refer to VACCP/TACCP systems.
I was wondring if anyone has an example of these hazard analysis to share. Do we need to add all of these to hazard analysis in addition to microbiologica, physical, and chemical analaysis? Allergen control is part of chemical analysis. how can we manage that. If we have a Vulnerability Assessment (5.4), isn't that cover for fraud? Thank you.
Hi flora,
As mostly described, I think, in Post 2 -
There are various worked examples here for RA, ie 3.5.1.1, of input "materials" (focussed on safety/quality/legality/VA[exc.packaging,focussed on supply chain/economic gain,etc,etc, as delineated in 5.4.2]), eg the following link. BRC weirdly chose to mix all the above parameters into one gross hotpot for reasons known only to themselves.
https://www.ifsqn.co...al/#entry100194
haccp as per Codex is focussed on raw materials/process/safety(inc.packaging) and tends to have its own, well-established format. Offhand, I don't recall any specific BRC examples here however the fssc22000 example in link below probably represents a reasonable equivalent if one ignores columns F, M-X.
It's true that the RA inevitably overlaps haccp but the presentations are rather different -