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Hazard Identification And Evaluation to align with the new CFIA regulations


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#1 James Dough

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Posted 20 February 2020 - 10:02 PM

Good day all,

 

We are adjusting our Food Safety program to align with the new CFIA regulations. There are some changes such as new CCP determination questions and more justification/validation evidence.

I am referencing the CFIA website guidance for meeting requirements.

I have attached the CFIA example for Hazard Identification And Evaluation Template. It all makes sense but when you look at the last row regarding allergen cross contamination, they have an allergen program in place for post allergen cleaning and pre non allergen production inspections. They still claim a significant hazard with the justification that if the allergen program is not strictly followed there could be allergen cross contamination that can harm consumers with allergies.

 

I find this confusing because if any control program is not followed there is risk of harm to consumers.

Is it the fact that that the item is allergen?

 

Looking forward to comments.

 

Here is the link to the page and please see the attached guideline example.

 

https://www.inspecti...80440822085#a3a

 

Attached File  CFIA Hazard 2020-02-20.png   85.96KB   5 downloads

 

Thanks,

 

James



#2 Brendan Triplett

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Posted 21 February 2020 - 11:41 AM

I feel as though they are looking at significant risks that are likely to occur.  They mark this as a CCP and they have the justification and work that they do to mitigate the risks.  It is not so much that the product is the allergen but rather that it contains allergens that could contaminate other product or be contaminated by other product.  This is primarily for manufacturing.  When I work with distributors they have much less likelihood of this and it is controlled at the labeling step (I got this guidance from the FDA).  If you are transporting uncovered  raw product through an open area before packaging and there is a chance it can be contaminated with an allergen then it would be a CCP that would need documentation.  The map you have on this document shows the risk point that they have marked.  Part of the HACCP is the Hazard Analysis and that is where the determination would be made for the allergen contamination.  They show the hazards and justifications for why in the hazard section of the sheet.  You will just need to provide some critical limits and how you mitigate the hazard.  Hope this helps a bit.

 

Cheers!


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#3 Charles.C

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Posted 21 February 2020 - 02:12 PM

Good day all,

 

We are adjusting our Food Safety program to align with the new CFIA regulations. There are some changes such as new CCP determination questions and more justification/validation evidence.

I am referencing the CFIA website guidance for meeting requirements.

I have attached the CFIA example for Hazard Identification And Evaluation Template. It all makes sense but when you look at the last row regarding allergen cross contamination, they have an allergen program in place for post allergen cleaning and pre non allergen production inspections. They still claim a significant hazard with the justification that if the allergen program is not strictly followed there could be allergen cross contamination that can harm consumers with allergies.

 

I find this confusing because if any control program is not followed there is risk of harm to consumers.

Is it the fact that that the item is allergen?

 

Looking forward to comments.

 

Here is the link to the page and please see the attached guideline example.

 

https://www.inspecti...80440822085#a3a

 

attachicon.gif CFIA Hazard 2020-02-20.png

 

Thanks,

 

James

 

Hi James,

 

I agree with you but I am not a user of CFIA.

 

IMEX the allergen control program would typically in "Codex" haccp be a PRP. and presumably include the control measures mentioned on yr attachment.

 

Accordingly the risk of the potential hazard would IMO not justify the hazard being regarded as significant.

When allergenic hazards were first sucked in to haccp plans this stage hazard probably would have generated a CCP. Shortly after, the use of PRPs was promoted, notably to avoid creating allergen CCPs plus the associated documentation.

 

I'm not a user but It seems that CFIA do not believe in PRPs (what does their fsep manual say?).

 

PS - The link/example also seems to have missed the potential allergenic hazard aspect at the packing stage (ie labelling declaration) in the case where the item might have not been allergen free (eg shrimp !).


Kind Regards,

 

Charles.C


#4 Taralynn

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Posted 02 April 2020 - 07:46 PM

Hi James, 

 

In the example you provided to add an extra measure of confidence that cleaning was sufficient, I would add in a ATP Allergen Protein swabbing,  that way it would reduce the risk of trace allergenic proteins from carrying forward. 

 

There is always a risk that programs are not followed, the key is self verifying tasks, that would catch the lapse in the program. 

 

Unfortunately CFIA's FSEP Manual was archived, and is no longer a reference which was a great tool. 

 

I know this is a rather late reply, hope it helps.






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