4 replies to this topic

[CamilleFlorent]

Hi everybody,

 

First let me introduce myself : I am working for an italian food Broker, IFS Broker certified for 2 years now. 

 

Here is my struggle : we have an HACCP based on our suppliers and third part warehouses/carriers evaluation. Our CCP are our supplier's CCP (we ask them what are their CCP, we carry on traceability test to control their CCP registration effectivness). Our risks are the usual ones : biological, physical, ... . This HACCP is not anymore validated by our new IFS auditor, who request an administrative HACCP plan.

 

He told us to change our HACCP and to identify risks for this folowing processes : referencing of supplier, recipe modifications, evaluation and following of suppliers. Our risks will also change and be more like : recipe modification without notification from supplier, referencing of a supplier that doesn't match with our quality requirements, ...

 

Problem is I don't understand how to create/implement this new HACCP and I have never seen something like this before...

 

Did someone already worked on it ? Do you have any examples to help me see how it should look like ? Any advice would help me.

 

Thank oyu in advance.

 

Kind regards,

 

Camille Florent

[Hank Major]

Sounds like the auditor's concern is that a supplier may change their product without changing the Product Specification and/or informing you.  Other people may have more to add, but you need to address this possibility.  One thing you can do is ask each supplier for a statement that they will inform you of any changes to the recipe and/or specification (these are essentially the same thing to me).  Keep these documents on file.  You can write a risk assessment for the possibility of a recipe change without you being informed, which would have the usual matrix of likelihood cross severity.  Or (and other people may weigh in here) you could even consider it like a food fraud Vulnerability Assessment. You would write those up with the usual matrix of Likelihood of occurrence × Likelihood of detection (by you) × Profitability (for them to commit the fraud) × Severity (to the public health). 

 

I am attaching my brand new Vulnerability Assessment for Ground Turmeric, which I wrote up because of the Stanford lead chromate adulteration article that came out on September 24th and got my clients all in a tizzy.

Attached Files

•  VA for Ground Turmeric.pdf   1.54MB   94 downloads

[Charles.C]

Sounds like the auditor's concern is that a supplier may change their product without changing the Product Specification and/or informing you.  Other people may have more to add, but you need to address this possibility.  One thing you can do is ask each supplier for a statement that they will inform you of any changes to the recipe and/or specification (these are essentially the same thing to me).  Keep these documents on file.  You can write a risk assessment for the possibility of a recipe change without you being informed, which would have the usual matrix of likelihood cross severity.  Or (and other people may weigh in here) you could even consider it like a food fraud Vulnerability Assessment. You would write those up with the usual matrix of Likelihood of occurrence × Likelihood of detection (by you) × Profitability (for them to commit the fraud) × Severity (to the public health). 

 

I am attaching my brand new Vulnerability Assessment for Ground Turmeric, which I wrote up because of the Stanford lead chromate adulteration article that came out on September 24th and got my clients all in a tizzy.

 

Slightly OT

 

Hi Hank,

 

Thks for the attachment. Nice format. i wondered what the final decision criteria were for the ODPS number ?

 

A few comments -

 

(1) I assume "2" means " Lowish"  for all 4 parameters except "detection".

 

(2) Occurrence = 2 seems slightly questionable, eg -

 

 spice incidents.pdf   65.3KB   60 downloads

 

(3) IMO the interpretation of "severity" is not necessarily incorrect but is "debatable". (cf the well-known USP food fraud document)

 

(4) The formula used seems to intrinsically disagree with BRC's basic viewpoint on Food Fraud, ie -

 

With  vulnerability assessment, severity is not a particularly useful measure as (at the very least) the resultant product will always be illegal and therefore the consequences are always severe, regardless of whether there is an associated food safety issue or not.

 

(5) JFI, using the tabled data, the BRC formula of OxD or OxDxP would have IMO generated a low vulnerability rating without involving "severity"

[pHruit]

Hi everybody,

 

First let me introduce myself : I am working for an italian food Broker, IFS Broker certified for 2 years now. 

 

Here is my struggle : we have an HACCP based on our suppliers and third part warehouses/carriers evaluation. Our CCP are our supplier's CCP (we ask them what are their CCP, we carry on traceability test to control their CCP registration effectivness). Our risks are the usual ones : biological, physical, ... . This HACCP is not anymore validated by our new IFS auditor, who request an administrative HACCP plan.

 

He told us to change our HACCP and to identify risks for this folowing processes : referencing of supplier, recipe modifications, evaluation and following of suppliers. Our risks will also change and be more like : recipe modification without notification from supplier, referencing of a supplier that doesn't match with our quality requirements, ...

 

Problem is I don't understand how to create/implement this new HACCP and I have never seen something like this before...

 

Did someone already worked on it ? Do you have any examples to help me see how it should look like ? Any advice would help me.

 

Thank oyu in advance.

 

Kind regards,

 

Camille Florent

 

"HACCP" for brokers isn't quite like "normal" HACCP

Did they accept your use of your suppliers CCPs as your own CCPs? It seems like a curious approach to me, as you are not in control of the process at those points - I'd personally dump all of that into a prerequisite program under your supplier approval controls.

The section on HACCP in the IFS broker standard is quite non-specific, so you would appear to have a reasonable degree of freedom in how you implement your system, although conversely it may also be more at the discretion of individual auditors as to whether the results are deemed to be compliant with the clauses in the standard...

It's possibly worth downloading a (free) copy of the BRC Agents & Brokers standard as a secondary reference - as with all BRC standards its far more particular in detailing requirements and expectations, so could potentially serve as a helpful guideline on an approach for implementing HACCP as a broker.

I'm not entirely clear on what you mean by "referencing" of a supplier?

 

For the recipe change question, I like Hank Major's suggestion - your supply agreement should include signed confirmation that you will be notified in advance of any change to recipes (and ideally also to HACCP, certification, allergens etc) and add this in to your supplier approval/management program.

For some product categories you may also be able to consider the potential implications of a recipe change - if for example you're trading mango smoothies then the supplier changing 10% apple juice to 10% grape juice could be a problem for your clients but is not likely to be a food safety issue, whereas if you're buying curry sauce then there could be potential for a recipe change that introduces nuts, which has potentially far more significant implications.

 

For our brokers HACCP (BRC rather than IFS), supplier selection is one stage of our process flow. As stated above, we treat our supplier approval system as a prerequisite within the HACCP plan. We know that using an unapproved supplier potentially presents a large risk (on the basis that we know nothing about them), but we can justify the likelihood of such an event as being low. Could the same approach work for you?
I'd look at what controls you have on the purchasing side of your business - can buyers raise purchase orders to anyone they feel like, or do suppliers need to be approved before they can be added to your business software? Have you got a defined purchasing procedure, and are your buyers trained against it?

If you don't have a procedure for purchasing then it's a relatively simple document to write, you can get the buyers involved so they have ownership of it (which means they're more likely to actually follow it, and less likely to view it as a quality department thing that gets in their way ), and it further strengthens your systems for what is arguably one of the key risk areas as a broker.

[Hank Major]

To my mind there are different levels of severe.  A substitution of Manuka honey with regular honey will get a company into trouble, possibly sued.  Something requiring a recalls will be expensive.  But something that actually hospitalizes and kills people may destroy the company and in at least one case, has gotten people thown in prison and ravaged the reputation of AIB.