13 replies to this topic

[Zahn.R]

Hi

 

Me and a colleague are currently in a heated discussion with regards to the hazard analysis.  If you have for example micros that can be introduced with your raw material intake, do you "carry over" that hazard to each of your production steps until it is eliminated at sterilization or cooking or can you reference it in control measures that it will be eliminated and carry on?  Our HACCP study has a lot of these hazards that can only be eliminated much later in the process so the study is currently too lengthy

[LesleySR]

Hi Elzaan

 

Most HACCP studies are really lengthy & this does show that you have thought about the process at each step (so it gives reassurance to customers).

 

If your HACCP study is detailed it will probably classify microbiological hazards as:

 

Presence

Introduction

Growth

Survival

 

of each microbiological hazards

 

Therefore your HACCP would show that, even if microorganisms are introduced at raw material intake (although you may mean that microorganisms are present in the incoming raw material, but not introduced here?) your storage conditions, or the condition of the material (eg. low aW)  prevent growth & a subsequent thermal treatment will eliminate the hazard?...

[Dr.Khan]

Hello Elzaan Retief

 

The effective way of dealing with the issue is to have a control measure which will reduce the chances of having  the intake of micro from raw materials  The following two options will resolve the issue

 

1. approved supplier programme. That is ask every suppliers of raw material to provide you certificate of analysis for each delivery. The certificate of analysis must includes micro analysis showing the raw material is in spec in regard to micros and use only that raw materials which are safe.

 

2.if the raw materials are chilled or frozen then  the maintenance of the cold chain at every step should be verifiable. This can be done by recording loading and receipt temperature.

 

kind regards

Dr humaid Khan

Managing Director

Halal International Services

Australia

[Charles.C]

Hi

 

Me and a colleague are currently in a heated discussion with regards to the hazard analysis.  If you have for example micros that can be introduced with your raw material intake, do you (a) "carry over" that hazard to each of your production steps until it is eliminated at sterilization or cooking or (b) can you reference it in control measures that it will be eliminated and carry on?  Our HACCP study has a lot of these hazards that can only be eliminated much later in the process so the study is currently too lengthy

 

The answer (for yr examples) is haccp-simple. It's (b).

 

Just have a look at some of the haccp plans on this forum.

[QAGB]

Hi

 

Me and a colleague are currently in a heated discussion with regards to the hazard analysis.  If you have for example micros that can be introduced with your raw material intake, do you "carry over" that hazard to each of your production steps until it is eliminated at sterilization or cooking or can you reference it in control measures that it will be eliminated and carry on?  Our HACCP study has a lot of these hazards that can only be eliminated much later in the process so the study is currently too lengthy

 

I don't know that either method is right or wrong, but I always carried the hazard over into each production step until the hazard was controlled/eliminated/reduced at that step.

[Hank Major]

I agree with the above posters.  I just looked at my most recent hazard analysis, and don't see how one could "carry over" the hazard of bacteria being present in the raw materials.  That hazard only appears in the Receiving step.  The Storage step, for example, only considers growth of microbes. 

 

One always assumes that there are a few bacteria present in the raw materials.  There would need to be NASA-level sterilization to completely eliminate all bacteria; in food safety we are talking about significantly minimizing or preventing the hazard of bacterial contamination.

[QAGB]

I agree with the above posters.  I just looked at my most recent hazard analysis, and don't see how one could "carry over" the hazard of bacteria being present in the raw materials.  That hazard only appears in the Receiving step.  The Storage step, for example, only considers growth of microbes. 

 

One always assumes that there are a few bacteria present in the raw materials.  There would need to be NASA-level sterilization to completely eliminate all bacteria; in food safety we are talking about significantly minimizing or preventing the hazard of bacterial contamination.

 

 

Hmm... I always viewed it differently.

 

Let's just use foreign material in raw seeds as an example. You know that you are going to get particulate in your seeds that you will sieve later. It is introduced in the receiving step because you know the product comes in that way. You're not going to eliminate the particulate when you store the raw materials. However, this particulate is still there when you store it. It hasn't disappeared. When the seeds have been put into the holding hopper, the particulate is still there. When the seeds are passed through the auger system, the particulate is still there. At the point of sieving, the particulate is removed, so I would no longer list this as a hazard after this step.

 

Again, that's just always how I viewed it. Auditors were always happy with it.

 

On the other hand, I could see how you would list something where the hazard is introduced and where it is controlled. I could also see how hazards could be potentially missed downstream in the analysis, if it isn't carried through. 

 

Also - yes I realize we're talking about micro, but foreign material is sometimes easier to explain in examples.

Edited by QAGB, 01 November 2019 - 08:13 PM.

[Hank Major]

Hmm... I always viewed it differently.

 

Let's just use foreign material in raw seeds as an example. You know that you are going to get particulate in your seeds that you will sieve later. It is introduced in the receiving step because you know the product comes in that way. You're not going to eliminate the particulate when you store the raw materials. However, this particulate is still there when you store it. It hasn't disappeared. When the seeds have been put into the holding hopper, the particulate is still there. When the seeds are passed through the auger system, the particulate is still there. At the point of sieving, the particulate is removed, so I would no longer list this as a hazard after this step.

 

Again, that's just always how I viewed it. Auditors were always happy with it.

 

On the other hand, I could see how you would list something where the hazard is introduced and where it is controlled. I could also see how hazards could be potentially missed downstream in the analysis, if it isn't carried through. 

 

Also - yes I realize we're talking about micro, but foreign material is sometimes easier to explain in examples.

 

Instead of calling the hazard "particulates in the raw seeds", you could call the hazard "failure to remove particulates in the sieving step". 

[Charles.C]

I had a look at 10 random haccp plans in my archives, the approx. result for b, a (see post4) was approx 50/50 so it seems that some people do enjoy repeating themselves.

 

JFI here is a (current) example of (carry over)  "repetitions"  but neatly done so as to avoid mass duplications

 

 cooked meat-poultry hazard analysis.doc   110.5KB   52 downloads

 

In contrast, here is a FDA/FSMA example of a haccp plan format which rather ingeniously justifies no repetitions

 

 haccp plan - vegetable salad.pdf   841.74KB   61 downloads

 

Seems like one can take one's pick.

[althene_cg]

Hello I am new to this forum. :)

 

I have the same query but for chemical hazards. 

 

At the point of Receiving, we have identified antibiotic residues as a potential hazard but cited this as not a significant hazard due to low likelihood based on our controls and PRPs. We also backed it up by validation studies and scientific data. Our auditor called it as a finding that we did not carry over the said hazard at succeeding steps. He wanted this as a potential hazard at all succeeding steps (storage, cooking, cooling, reheating, hot holding) moving forward until food service but also tagged as not significant as he said there is no way we can remove the antibiotic residues. I work in catering and this is the first time this was called as an audit finding for us. 

 

I have been including at my hazard analysis "what can be introduced, multiply, grow, contaminate" at each step ever since. 

 

If I follow the auditor's recommendation, does this mean that for all other hazards (vulnerability, biological and physical), I would also have to do the same? Even though the hazard is not significant and can be controlled?

 

Would really appreciate your expert advice. 

Thanks all! 

[Charles.C]

Hello I am new to this forum. :)

 

I have the same query but for chemical hazards. 

 

At the point of Receiving, we have identified antibiotic residues as a potential hazard but cited this as not a significant hazard due to low likelihood based on our controls and PRPs. We also backed it up by validation studies and scientific data. Our auditor called it as a finding that we did not carry over the said hazard at succeeding steps. He wanted this as a potential hazard at all succeeding steps (storage, cooking, cooling, reheating, hot holding) moving forward until food service but also tagged as not significant as he said there is no way we can remove the antibiotic residues. I work in catering and this is the first time this was called as an audit finding for us. 

 

I have been including at my hazard analysis "what can be introduced, multiply, grow, contaminate" at each step ever since. 

 

If I follow the auditor's recommendation, does this mean that for all other hazards (vulnerability, biological and physical), I would also have to do the same? Even though the hazard is not significant and can be controlled?

 

Would really appreciate your expert advice. 

Thanks all! 

Hi althene,

 

You might have asked yr auditor as to why, if likelihood of presence of antibiotic residue is negligible (I presume), what is there to be carried over ?

[Scampi]

Hello I am new to this forum. :)

 

I have the same query but for chemical hazards. 

 

At the point of Receiving, we have identified antibiotic residues as a potential hazard but cited this as not a significant hazard due to low likelihood based on our controls and PRPs. 

 

I'd like to know what your controls really are to control antibiotic residue?  Are you testing, what is the raw material where this could occur?   This should be on a traditional HACCP form 10 as it's actually out of your hands completely UNLESS you're testing for residue on EVERY incoming lot

[althene_cg]

Hi Charles and Scampi! 

 

Thanks for your inputs and comments. :)

 

I actually fought this over with my auditor during the audit. I justified that if the hazard is not significant, what can be carried over?

 

We have been HACCP certified for the last 10 years and our controls include (1) getting meat only from sources approved by the government (2) requiring certificates of analysis for antibiotic residue and letters of guarantee (3) quarterly random checks of meat delivered into our facility for antibiotic residue, samples are sent to the government laboratory regulating this for testing (4) vendor assurance program which includes supplier audits to check for our supplier's antibiotic residue controls. 

 

Would love to know of your feedback if the above controls are still not sufficient for this hazard to only be controlled at the point of receiving. 

 

Thanks again! 

[Charles.C]

Hi Charles and Scampi! 

 

Thanks for your inputs and comments. :)

 

I actually fought this over with my auditor during the audit. I justified that if the hazard is not significant, what can be carried over?

 

We have been HACCP certified for the last 10 years and our controls include (1) getting meat only from sources approved by the government (2) requiring certificates of analysis for antibiotic residue and letters of guarantee (3) quarterly random checks of meat delivered into our facility for antibiotic residue, samples are sent to the government laboratory regulating this for testing (4) vendor assurance program which includes supplier audits to check for our supplier's antibiotic residue controls. 

 

Would love to know of your feedback if the above controls are still not sufficient for this hazard to only be controlled at the point of receiving. 

 

Thanks again! 

Hi Althene,

 

So did yr auditor accept yr current controls  (ie 1-4 above) as sufficient for establishing a PRP for non-presence of antibiotics ? If not, why not ?