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Supplier Without HACCP

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#1 Andy_Yellows

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Posted 12 November 2019 - 11:03 AM

Hi all,

 

One of our long-standing suppliers has recently returned their questionnaire to us only to state that they do not have HACCP documentation in place. They are a fresh produce (unprepared/non-pre-packed) wholesaler who source their product from Covent Garden market in London. It goes back to their warehouse before being picked to order and delivered to us on their own vehicles. A lack of HACCP concerns me greatly as it is not only desirable but, as far as I was aware, a legal requirement for FBOs of all natures. I don't want to go back to the supplier with questions or demands until I know the context in which I'm working which is why I've put this question out to the community first.

 

Our supplier approval policy states that a supplier must have food safety certification in place OR have completed a questionnaire if there is no accreditation. This supplier has no FS accreditation.

 

Is there something glaringly obvious that I'm missing here? Is there some kind of loophole that means they don't actually need to have HACCP? Seems pretty peculiar to me.......

 

Thanks in advance,

 

Andy


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#2 GMO

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Posted 12 November 2019 - 12:09 PM

To my knowledge even in their situation, legally they should have HACCP or a system based on HACCP.  Are there any EHOs on here who can confirm?



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#3 pHruit

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Posted 12 November 2019 - 12:12 PM

Article 5 of Regulation (EC) 852/2004 requires that: "Food business operators shall put in place, implement and maintain a permanent procedure or procedures based on the HACCP principles".

Exactly how little HACCP one can get away with using and still comply with this is an interesting question ;)

 

Astonishing though it may seem, you may find that the term "HACCP" may be unknown to lots of non-manufacturing FBOs in the UK. In the first instance you could try asking them about "Safe Food, Better Business", as that's probably the format that their EHO would push them towards.



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#4 zanorias

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Posted 12 November 2019 - 12:28 PM

I was wondering the same as pHruit; the 'Safer Food Butter Business' route.

 

An intro pack from the FSA states:

 

This pack is based on the principles of HACCP (hazard analysis and critical control point), but you will not find words such as ‘HACCP’ or ‘hazard’ in the pack because we have cut out all the jargon.

https://www.food.gov...roduction_1.pdf

 

Perhaps your supplier has a system based on SFBB that they use to comply with the legislation specific to them, so are unaware of what HACCP actually is in the same way that we regard it. Does the supplier have anything in place in the way of FSMS?

Perosnally I'm curious on when exactly a FBO is large/complex enough to require HACCP, and which line of the line your supplier should actually be on.



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#5 Andy_Yellows

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Posted 12 November 2019 - 01:16 PM

Thanks to all for your feedback so far- glad to know I'm not mad for thinking they needed one! I will enquire as to what kind of documentation they do have and suggest SFBB or MyHACCP to them if they're found to be lacking.

 

Andy


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#6 The Food Scientist

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Posted 12 November 2019 - 04:52 PM

Fresh produce and no HACCP? Yikes!


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#7 Charles.C

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Posted 13 November 2019 - 08:13 AM

Article 5 of Regulation (EC) 852/2004 requires that: "Food business operators shall put in place, implement and maintain a permanent procedure or procedures based on the HACCP principles".

Exactly how little HACCP one can get away with using and still comply with this is an interesting question ;)

 

Astonishing though it may seem, you may find that the term "HACCP" may be unknown to lots of non-manufacturing FBOs in the UK. In the first instance you could try asking them about "Safe Food, Better Business", as that's probably the format that their EHO would push them towards.

 

 

Personally I'm curious on when exactly a FBO is large/complex enough to require HACCP, and which line of the line your supplier should actually be on.

 

 

From distant memory the "FBO"  scope of the EC reference and the SFBB-related documentation may not apply to operations such as mentioned in this thread ?

 

Merely for historical interest, IIRC the launch of the EC Regulation caused consternation within the UK Food safety sphere.  A high-tech haccp system was devised specifically for this purpose (available on the Net) but was, predictably, like dumping a foreign language onto its intended users.

The consequence was the (rapid)  formulation/issue of the "watered-down"  SFBB  System - beautifully illustrated, hygienically elegant, data-driven but technically "minimalist" .

 

https://www.food.gov...s#full-guidance


Kind Regards,

 

Charles.C


#8 Andy_Yellows

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Posted 13 November 2019 - 08:40 AM

Fresh produce and no HACCP? Yikes!

My thoughts exactly!

 

 

From distant memory the "FBO"  scope of the EC reference and the SFBB-related documentation may not apply to operations such as mentioned in this thread ?

 

 

 

 

Hi Charles, I'm a little confused- are you saying that there could potentially be a scenario where this supplier wouldn't strictly be considered a 'FBO' and therefore would not necessarily be required to have a formal HACCP system in place?


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#9 charlotte27

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Posted 13 November 2019 - 09:29 AM

Can someone confirm that a food storage and distribution operation (no manufacturing at all, simply bought in goods that are not repacked, just sold on) has to have a HACCPsystem - I think it does.

Thanks



#10 pHruit

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Posted 13 November 2019 - 09:48 AM

Hi Charles, I'm a little confused- are you saying that there could potentially be a scenario where this supplier wouldn't strictly be considered a 'FBO' and therefore would not necessarily be required to have a formal HACCP system in place?

It's not something that I've ever had to look into in great detail, and being a mass of interlinked regulations and guidance it would be more than a five minute job to do so with any certainty, but there are some exemptions around "primary production" (broadly, basic agricultural products with minimal/no processing) - if they're just handling fresh / unprocessed fruit and veg then I suppose it is potentially possible that they fall into this category. Part 3 of Article 5 (the HACCP article) in 852/2004 does exempt primary producers from the requirement I mentioned above, so I guess the question is whether your supplier's activities fall within those stated in Annex 1(I)(1)(a) of the regulation.

Possibly worth asking your customer, as theoretically they probably should know, but I feel that might be an optimistic viewpoint ;)

Do you have a good relationship with your EHO? It's the sort of question they'd probably (should?) be able to answer straight away, and they're normally pretty helpful IMEX.



#11 zanorias

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Posted 13 November 2019 - 09:50 AM

Can someone confirm that a food storage and distribution operation (no manufacturing at all, simply bought in goods that are not repacked, just sold on) has to have a HACCPsystem - I think it does.

Thanks

 

It does. There are still many controls a S&D company should have in place within it's HACCP plan, temperature control, supplier approval, pests, cleaning etc etc



#12 pHruit

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Posted 13 November 2019 - 09:54 AM

Can someone confirm that a food storage and distribution operation (no manufacturing at all, simply bought in goods that are not repacked, just sold on) has to have a HACCPsystem - I think it does.

Thanks

Generally yes, but it may depend on exactly what you're doing ;)

Again from Article 5 of 852/2004:
3. Paragraph 1 (the requirement to have a HACCP system) shall apply only to food business operators carrying out any stage of production, processing and distribution of food after primary production and those associated operations listed in Annex I.







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