3 replies to this topic

[Celestinene]

Hi all,

 

I am new to the site and in welcoming myself, I am Celestine Newton and work for OK Foods Inc. I have been with the company for 29 years. I have been the HACCP/BRC Manager for the last 13 years at the facility.

 

I have a question concerning BRC new requirement on adding waste to the flow chart and Hazard analysis. We produce raw poultry products, as well as ice glazed, fully cooked, par-fry, marinated flavored products as well. 

 

In adding the poultry waste, our poultry waste goes through a separate offal area into a tank for animal surplus / animal by products for food and feed. the facility is a USDA inspected Plant. I know we would have to ensure the poultry by products are safe throughout our process. Would we use the same B,C,P aspects that we use to control the waste until it leaves the facility as we would as receiving and processing the live bird. Due to the Biological agents, chemical agents are still on the offal by products? We have obtained letters from supplier that states they cook the by products for their animal food or feed that helps support our control measure.

 

However, I am not sure if B, C, aspects will have to be identified since the product is not fit for human consumption. Would the biological and chemical aspects be none identified. And as for the P, physical aspect, we have control of the metal, plastic, wood aspects with our pre-requisite program and additional security measures/monitoring activities.

 

In addition, in adding the radiology contaminates and fraud- deliberate/intentional adulteration, substitution. Would you only consider and identify theses hazards at the receiving of raw material, ingredients and packaging, and the operation process where the hazard could exist? 

[SQFconsultant]

Celestine Newton, welcome!

 

I have been to OK Foods - years ago actually as a 3rd party auditor.

[Celestinene]

Oh wow this is a small world. 

[pHruit]

Hi all,

 

I am new to the site and in welcoming myself, I am Celestine Newton and work for OK Foods Inc. I have been with the company for 29 years. I have been the HACCP/BRC Manager for the last 13 years at the facility.

 

I have a question concerning BRC new requirement on adding waste to the flow chart and Hazard analysis. We produce raw poultry products, as well as ice glazed, fully cooked, par-fry, marinated flavored products as well. 

 

In adding the poultry waste, our poultry waste goes through a separate offal area into a tank for animal surplus / animal by products for food and feed. the facility is a USDA inspected Plant. I know we would have to ensure the poultry by products are safe throughout our process. Would we use the same B,C,P aspects that we use to control the waste until it leaves the facility as we would as receiving and processing the live bird. Due to the Biological agents, chemical agents are still on the offal by products? We have obtained letters from supplier that states they cook the by products for their animal food or feed that helps support our control measure.

 

However, I am not sure if B, C, aspects will have to be identified since the product is not fit for human consumption. Would the biological and chemical aspects be none identified. And as for the P, physical aspect, we have control of the metal, plastic, wood aspects with our pre-requisite program and additional security measures/monitoring activities.

 

In addition, in adding the radiology contaminates and fraud- deliberate/intentional adulteration, substitution. Would you only consider and identify theses hazards at the receiving of raw material, ingredients and packaging, and the operation process where the hazard could exist? 

 

Welcome to the forum

I can't help with the USDA side of things, but in terms of BRC and your flow diagram my approach here would be to treat the offal as an output byproduct/waste stream as indicated in section 2.5, and also note clearly in your intended use definition that this output is for animal feed and not for human consumption.

 

For the radiological / fraud requirements, I treat these as any other hazard type - I'd only consider them in the analysis at the steps where they are applicable. Unless you have some very unusual processes (or are in a very strange location), the radiological bit will probably only apply at the raw materials intake. It's not strictly required, but I found it useful to write a separate risk assessment / position statement on the radiological hazards considerations just to substantiate the risk being very low.

The fraud / malicious contamination may require discussion at several steps as there is obviously theoretically potential for this to occur inside your facility - again I'd make reference to other systems that for part of the general prerequisite programs, in this case those for section 4.2 (security) and 5.4 (product authenticity). I still find it a bit incongruous that BRC has decided to stick them into "HACCP" as well, given that specific systems are required for exactly this purpose, but it's one of those hoops through which we all need to jump...