7 replies to this topic

[izzimac]

 Hi 

 

Can some one help me? please . I have just moved into working with a small charcuterie company . Our recent visit by EHO was unprofessional and not at all helpful for a small business. However we have been asked to make our corrective actions more detailed for each control or critical control point to include past present and future. Whilst I get present and future .I am at lost for the past ? 

 

Any views or  help ?

 

They have also informed us that we are not allowed to use the  Campdens HACCP Guidleine 42 layout for our HACCP too. And want everything written in the the old fashioned way.

 

Obviously our Licence is hanging over us like a noose. 

 

[QAGB]

Hi Izzimac,

 

Using the phrasing "past, present, and future" with corrective actions is indeed a bit puzzling. It sounds like you are talking about corrective actions for failure of a CCP. Are they looking for the following:

 

• past - corrective actions & disposition for product you already packed before understanding your CCP failed.
• present - corrective actions & disposition for product you are currently handling - stopping the line and getting QA and other team members involved in fixing the issue
• future - preventive actions on how to ensure CCP doesn't fail in the future or can be addressed before failure happens (for example building in a tolerance higher than your critical limits to ensure CCP doesn't fail, or more frequent monitoring)

That's the best guess I have for that.

[pHruit]

Is there another EHO in your area with whom you can discuss this?
I'm astonished that they've shunned the Campden guideline - there is no regulatory basis for this, as the onus is on your business to ensure a suitable system is in place. The EHO's role in this area is not to dictate formatting choices, but rather to verify that the HACCP plan complies with your legal obligations under Article 5 of Regulation (EC) 852/2004. I'm genuinely astonished given that the Campden guide is vastly superior to the "Safer Food, Better Business" scheme they promote for smaller businesses.

It's very much suppositional, but it could be the case that the EHO isn't that hot on HACCP and finds more "complex" approaches harder to get to grips with?

 

In the first instance I'd work through the CAs so you can show that you're genuine in your intent to comply with your legal obligations and the reasonable requirements imposed by the EHO, but I'd also very much be asking (as patiently and non-aggressively as possible) if they can provide more detail in writing on why the Campden approach is not acceptable. If this still doesn't get you anywhere you can try picking up with a more senior EHO if there is one in your area, or potentially raising via https://www.food.gov.../make-an-appeal

[izzimac]

Is there another EHO in your area with whom you can discuss this?
I'm astonished that they've shunned the Campden guideline - there is no regulatory basis for this, as the onus is on your business to ensure a suitable system is in place. The EHO's role in this area is not to dictate formatting choices, but rather to verify that the HACCP plan complies with your legal obligations under Article 5 of Regulation (EC) 852/2004. I'm genuinely astonished given that the Campden guide is vastly superior to the "Safer Food, Better Business" scheme they promote for smaller businesses.

It's very much suppositional, but it could be the case that the EHO isn't that hot on HACCP and finds more "complex" approaches harder to get to grips with?

 

In the first instance I'd work through the CAs so you can show that you're genuine in your intent to comply with your legal obligations and the reasonable requirements imposed by the EHO, but I'd also very much be asking (as patiently and non-aggressively as possible) if they can provide more detail in writing on why the Campden approach is not acceptable. If this still doesn't get you anywhere you can try picking up with a more senior EHO if there is one in your area, or potentially raising via https://www.food.gov.../make-an-appeal

 

Thanks for this. I have to say I am astonished too at this stance. Feel like I have been using the Campden approach for ever and I have been creating HACCP's for 15 plus years. Think as you said I will ask them in writing and copy in the lead in the department. Sadly we have two EHO attending us as we are the only site on their area that does charcuterie .They are nervous of what we are doing. Despite the fact its made commonly in Europe and beyond. 

Edited by izzimac, 30 August 2019 - 08:28 AM.

[izzimac]

Hi Izzimac,

 

Using the phrasing "past, present, and future" with corrective actions is indeed a bit puzzling. It sounds like you are talking about corrective actions for failure of a CCP. Are they looking for the following:

 

• past - corrective actions & disposition for product you already packed before understanding your CCP failed.
• present - corrective actions & disposition for product you are currently handling - stopping the line and getting QA and other team members involved in fixing the issue
• future - preventive actions on how to ensure CCP doesn't fail in the future or can be addressed before failure happens (for example building in a tolerance higher than your critical limits to ensure CCP doesn't fail, or more frequent monitoring)

That's the best guess I have for that.

Thanks for this, still not sure about the past ...surely if your CCPs have failed at a step before.The corrective actions for the step kicks in to make it safe or reject ( that is a simplistic example I know).  

 

Feel like I don't know what I am doing any more.The EHO team involved are being less than helpful. Which again is unusual too. Usually they work with you.

[GMO]

 

 Hi 

 

Can some one help me? please . I have just moved into working with a small charcuterie company . Our recent visit by EHO was unprofessional and not at all helpful for a small business. However we have been asked to make our corrective actions more detailed for each control or critical control point to include past present and future. Whilst I get present and future .I am at lost for the past ? 

 

Any views or  help ?

 

They have also informed us that we are not allowed to use the  Campdens HACCP Guidleine 42 layout for our HACCP too. And want everything written in the the old fashioned way.

 

Obviously our Licence is hanging over us like a noose. 

 

 

 

Ah... It's a phrase I've commonly heard and surprised others haven't.

 

• With a CCP you need to consider the past, i.e. what has been made on that machine since the CCP was out of control?  How is that brought back into control / made safe or scrapped?
• The present, i.e. stop the machine now.  Don't make more dangerous product!
• The future, what was the root cause for the failure?  How can you prevent recurrence. 

 

I think that's all they're after.  They're checking that you've controlled product which is now potentially dangerous, that you're controlling your production now and you're preventing it occurring again.  While this is not explicitly written in legislation, it is an expectation that for a CCP to be in control you need to control non conforming product, prevent more being made and prevent it happening again.  I don't think it's rocket science but perhaps the person describing it explained it poorly.

 

Perhaps my knowledge on this is from old HACCP plans which were often poor on this kind of thing and frequently just said "stop the machine" forgetting about the product which had been made and the risk of recurrence. 

[QAGB]

Ah... It's a phrase I've commonly heard and surprised others haven't.

 

• With a CCP you need to consider the past, i.e. what has been made on that machine since the CCP was out of control?  How is that brought back into control / made safe or scrapped?
• The present, i.e. stop the machine now.  Don't make more dangerous product!
• The future, what was the root cause for the failure?  How can you prevent recurrence. 

 

I think that's all they're after.  They're checking that you've controlled product which is now potentially dangerous, that you're controlling your production now and you're preventing it occurring again.  While this is not explicitly written in legislation, it is an expectation that for a CCP to be in control you need to control non conforming product, prevent more being made and prevent it happening again.  I don't think it's rocket science but perhaps the person describing it explained it poorly.

 

Perhaps my knowledge on this is from old HACCP plans which were often poor on this kind of thing and frequently just said "stop the machine" forgetting about the product which had been made and the risk of recurrence. 

 

I think it's a syntax difference depending on where you live. I have never heard past, present, future in relation to CCPs, but I estimated these based on my knowledge of HACCP. I actually do like it, and might adopt the phrasing.

[QAGB]

Thanks for this, still not sure about the past ...surely if your CCPs have failed at a step before.The corrective actions for the step kicks in to make it safe or reject ( that is a simplistic example I know).  

 

Feel like I don't know what I am doing any more.The EHO team involved are being less than helpful. Which again is unusual too. Usually they work with you.

 

I'm not 100% certain I understand what you mean. You're going to have times where you didn't realize your CCP failed. If your metal detector stops functioning mid-day, but was functioning an hour previously, you wouldn't know exactly when it stopped functioning. You would be putting product from mid-day to previous hour on hold. That is where the "past" comes in.