9 replies to this topic

[Highland Girl]

Hi,

 

As an agreement at a customer audit and now that traded products are included in BRC Issue 8 i am creating a HACCP plan for traded products. We trade a number of products (everything is low risk) that come in packed and leave the same way. Some of these products are also repacked however this is covered under a different HACCP plan. My question is around CCPs. My plan is Purchase - receipt of COC/COA - Intake - storage - dispatch (with a side step for direct deliveries). I am classing my receipt of COC/COA as a CCP, apart from visual inspection and some products which are tested for moisture on intake nothing happens to these products before they go back out so the COC/COA is evidence from the supplier that the product conforms to the specification and some products COAs. Does anyone have any thoughts on this as otherwise there would be no CCP in this HACCP plan? I do not have this as a CCP step in any of my other HACCP plans. Any help would be appreciated.

[Charles.C]

Hi,

 

As an agreement at a customer audit and now that traded products are included in BRC Issue 8 i am creating a HACCP plan for traded products. We trade a number of products (everything is low risk) that come in packed and leave the same way. Some of these products are also repacked however this is covered under a different HACCP plan. My question is around CCPs. My plan is Purchase - receipt of COC/COA - Intake - storage - dispatch (with a side step for direct deliveries). I am classing my receipt of COC/COA as a CCP, apart from visual inspection and some products which are tested for moisture on intake nothing happens to these products before they go back out so the COC/COA is evidence from the supplier that the product conforms to the specification and some products COAs. Does anyone have any thoughts on this as otherwise there would be no CCP in this HACCP plan? I do not have this as a CCP step in any of my other HACCP plans. Any help would be appreciated.

 

Hi Highland Girl,

 

Should state that I have limited  familiarity with typical trading haccp plans.

 

You omitted to mention what kind of "Goods" ? Including chilled/frozen (C/F) ?

 

I wouldn't say that it is exactly incorrect but the scope of most published haccp plans does not include the Purchasing step. A question of definition.

 

Usually the reception stage is handled by PRPs these days  to avoid interpretive complications. .Although, IIRC, there are examples of (SQF) haccp plans for receipt/storage/distribution of  fully packed C/F goods on this Forum where first 2 stages are CCPs involving temperature control.

 

A haccp plan is not obliged to contain a CCP unless Regulatory mandated..

Edited by Charles.C, 24 August 2019 - 06:12 PM.
expanded

[Highland Girl]

Hi Charles

 

Good point on the purchasing step, I will remove this.

 

All our products are ambient, pulses, cereals, dried fruits etc. Temperatures are not an issue for me.

 

I think maybe its because I have never produced a HACCP plan without a CCP which I think is what's throwing me off.

 

thank you for your help

[pHruit]

If you're already BRC certified then log in to Participate and download the Agents & Brokers standard / guidelines - this has a whole section of the standard on the expectations for "HACCP" for non-manufactured products.

You may need to "forget" some elements of HACCP to make it work though, as it's obviously not what it was originally intended for

FWIW we have no CCPs in our plan for Agents & Brokers, but obviously your requirements will depend on products, hazard analysis, potentially what decision tree you've used etc.

If this isn't a CCP in your other HACCP plans, is that because you have a subsequent process that address the potential hazards at the receipt step, or because in those it just doesn't score as a significant risk?

If the latter then I'd be inclined to go the same way with your traded goods plan unless the intended use dictates otherwise, but you're the one who has to make it work (and defend it to auditors) in practice.

[Highland Girl]

Thank you for your advice.

 

Yes we are already certified to BRC, I never throught to look at these guidelines but will do so now.

 

The products which we pack/manufacture all have metal detection and sieveing as CCPs to protect the products but as we do not do anything to the traded products and some of them are direct delvieries from suppliers to customers i feel like i am leaving myself open if this is not correctly monitored. The only way I can see to monitor/control this is to have COCs/COAs for all traded products which should cover the product in terms of metal contamination, foreign bodies and in the COAs for micro etc. Does this make sense? Its whether it counts as a CCP or not but in my mind it does if it covers off things in my other plans that are classed as CCPs.

[Charles.C]

Hi Highland Girl,

 

The specific (modified?) requirements for haccp in the BRC A&B code (not viewed) may render next comments irrelevant but never mind.

 

As an extension of pHruit's post, for yr manufactured items, how did you handle raw material reception ? With PRP's (eg via Supplier Approval) or direct risk assessment ? (the latter traditionally tends to be more debatable IMEX).

 

I ask because, for non-manufactured goods, I would have anticipated it is easier to extend a PRP approach as compared to non-PRP.

 

PS - I would also anticipate that if, as per post 4, auditors  routinely find haccp plans with no CCPs, yr zero presentation is less likely to be questioned. IMEX auditors like to "go with the flow".

Edited by Charles.C, 25 August 2019 - 03:02 PM.
added

[pHruit]

I ask because, for non-manufactured goods, I would have anticipated it is easier to extend a PRP approach as compared to non-PRP.

 

I agree that PRP is probably the approach I'd be going with in the example given here, and I think that's how the A&B standard envisages it too - at least that's how we've approached it, and it seems to have been accepted every audit since the first year that Issue 1 was launched.

Indeed the A&B standard doesn't actually discuss an equivalent to CCPs in the context of the plan itself, as the parallel to clause 2.8 in the food standard (determination of CCPs) is replaced with an alternative clause and sub-clause discussing review of service provider HACCP plans, effectively shifting the responsibility towards them for actually addressing the hazards, whereas the agent/broker is simply expected to verify that this is the case.

 

The products which we pack/manufacture all have metal detection and sieveing as CCPs to protect the products but as we do not do anything to the traded products and some of them are direct delvieries from suppliers to customers i feel like i am leaving myself open if this is not correctly monitored. The only way I can see to monitor/control this is to have COCs/COAs for all traded products which should cover the product in terms of metal contamination, foreign bodies and in the COAs for micro etc. Does this make sense? Its whether it counts as a CCP or not but in my mind it does if it covers off things in my other plans that are classed as CCPs.

 

I see where you're coming from on this, but in terms of actually controlling the hazards, is receipt not a bit late in the process?

IMO these are really addressed via supplier approval prior to purchase - as per 2.8/2.8.1 of the A&B standard, your primary "control" here is verifying that the suppliers' HACCP plans are adequately addressing the hazards, through direct inspection of the plans and/or them sitting within the scope of "appropriate" certification. If there are specific hazards you feel should be considered then you'll probably need to see at least a summary of the plans, but whichever route you take I'd be inclined to call it part of supplier approval and label it as a prerequisite program.

Your control at receipt is then perhaps just a case of verifying that you've been supplied with the correct product from the correct approved supplier, which is presumably the same as you'd be doing for other ingredients anyway?

[Highland Girl]

Hi Both,

 

Thank you so much for your responses.

 

Current acceptance of all raw materials, from our other HACCP plans, does come under PRP's, supplier approval, goods in procedure, visual inspection, all products tested on site for moisture etc. 

 

I was surprised to hear that no CCP's is a regular occurrence, this is not something I have come across so far and we have an extensive array or raw materials and suppliers.

 

pHurit I do agree in hindsight that receipt is too late to control hazards and fully agree that these should have been addressed well before this point. Thank you for explaining how you would use HACCP and cover this under PRP's, this is something I will use and put into practice.  We do have a few suppliers who are certified to BRC Agents & Brokers but also some who are not. I have already requested HACCP flow diagrams and at a minimum info covering their CCPS as part of my supplier approval.

 

Thank you so much for your time and help on this matter you have no idea how much I really appreciate it.

[Charles.C]

Hi Both,

 

Thank you so much for your responses.

 

Current acceptance of all raw materials, from our other HACCP plans, does come under PRP's, supplier approval, goods in procedure, visual inspection, all products tested on site for moisture etc. 

 

I was surprised to hear that no CCP's is a regular occurrence, this is not something I have come across so far and we have an extensive array or raw materials and suppliers.

 

pHurit I do agree in hindsight that receipt is too late to control hazards and fully agree that these should have been addressed well before this point. Thank you for explaining how you would use HACCP and cover this under PRP's, this is something I will use and put into practice.  We do have a few suppliers who are certified to BRC Agents & Brokers but also some who are not. I have already requested HACCP flow diagrams and at a minimum info covering their CCPS as part of my supplier approval.

 

Thank you so much for your time and help on this matter you have no idea how much I really appreciate it.

 

Hi Highland Girl,

 

Originally haccp plans for a manufacturing facility tended to focus on the "internal' process and also included Sanitation CCPs. This often led to a multitude of CCPs due to  hazards associated with (a) reception stage, (b) Hygienic aspects, (c) allergens

 

PRPs have mainly  eliminated CCPs due (a,b,c) and concomitantly a substantial amount of documentation.

 

I daresay It is  true that (somewhat catalysed by BRC's UK-retail aspect) for many UK processes, auditors may expect to see a metal detector and thus a minimum of 1-CCP. For my low haccp risk process I resisted this auditory expectation for several years but eventually "BRC-caved" to a 2nd-hand MD to avoid incessant arguments. However I get the impression that, as in yr traded process and particularly for other Industries/locations/GFSI-recognised Standards, MDs are still regarded as a needless 'luxury".

 

Some haccp texts, particularly where a significant raw material hazard could reach a consumer's mouth, conceptually equate related PRPs to an "external"  CCP on the supplier.

 

JFI I attach (a) a detailed Supplier Requirements Manual which is oriented to various GFSI-recognised Standards and certain 2ndParty Receivers, (b) a more generic "SOP" for Supplier Approval (I noticed that it lacks Traceability)

 

 Supplier-Requirements-Manual-2017.pdf   2.93MB   71 downloads

 Supplier approval evaluation procedure.pdf   286.99KB   75 downloads

[Highland Girl]

Hi Charles.C

 

I like how you say you caved, I suspect this does now cause less arguments. I agree that metal detectors are a needless luxury especially when your supplier metal detects the product before it arrives however it is retail and BRC driven. 

 

I had not thought before about using the CCPs that the supplier has in place although I suspect this will now all come under supplier approval and PRP. Obviously now I will be scrutinisng their HACCP information some what. 

 

Thank you for the attachments. I see the second one is similar to the supplier approval document I have in place although mine does need some updating and it includes traceability.

 

Thanks again for all your help