Ingredient Hazard Analysis - Flour
Good Evening All,
I am doing some upgrading to my plant's hazard analysis' and noticed that in general it was set up and handled differently than I am used to. I'd like to see if this is a valid way of having this, and just not what I am used to, or something that we will need to change because it is invalid and just has not been caught yet by the auditor.
We are running SQF, but the last plan I had set up was FSSC22000.
The ingredient hazard analysis for flour lists the following:
- Biological: Pathogens (Salmonella & E-Coli)
- Chemical: Allergen ( Wheat)
- Physical: Metal, Wood, Glass, Etc.
My concern is the lack of mention of Mycotoxins as a whole, but in specific Ocratoxin, DOM, and Vomitoxin. I have seen in the past, and how I set up my last Hazard Analysis was to mention the hazard, no matter how well controlled, and then to list those controls or complete a Risk Assessment. This plant however appears to have gone the route of using supplier control as a control without actually mentioning it as a hazard and not completing the risk assessment.
Are both of these methods valid? Or must the mycotoxins be listed on the ingredient Hazard Analysis even though we cannot take any additional action for them.
Thank you for your help.
Hi C,
It sounds like it's based off HARPC, not HACCP.
Good Evening All,
I am doing some upgrading to my plant's hazard analysis' and noticed that in general it was set up and handled differently than I am used to. I'd like to see if this is a valid way of having this, and just not what I am used to, or something that we will need to change because it is invalid and just has not been caught yet by the auditor.
We are running SQF, but the last plan I had set up was FSSC22000.
The ingredient hazard analysis for flour lists the following:
- Biological: Pathogens (Salmonella & E-Coli)
- Chemical: Allergen ( Wheat)
- Physical: Metal, Wood, Glass, Etc.
My concern is the lack of mention of Mycotoxins as a whole, but in specific Ocratoxin, DOM, and Vomitoxin. I have seen in the past, and how I set up my last Hazard Analysis was to mention the hazard, no matter how well controlled, and then to list those controls or complete a Risk Assessment. This plant however appears to have gone the route of using supplier control as a control without actually mentioning it as a hazard and not completing the risk assessment.
Are both of these methods valid? Or must the mycotoxins be listed on the ingredient Hazard Analysis even though we cannot take any additional action for them.
Thank you for your help.
Hi chrkut,
It may depend on what type of flour is involved, eg raw/heat treated.
Ideally, hazard analyses should specify or give reference to examples of the primary BCPA potential hazards included. (Obviously a complete BCPA list might generate an Encyclopedia).
Some published hazard analyses shortcut and state, for example, "micro.hazards" but this, IMEX, is not usually an officially favoured approach.
I suggest a browse (eg search flour / grain) through the attached FDA's suggested ingredient/hazard compilation which probably supports yr mycotoxin comment.
FDA Draft-Guidance-Hazard-Analysis-and-Risk-Based-Preventive-Controls-Appendix-1.pdf 1.9MB 194 downloads
PS - JFI generic E.coli is not considered a safety hazard.
The FDA draft guidance that Charles posted lists mycotoxins and pesticides under potential chemical hazards so you will want to be able to show that you have at least considered these hazards in your risk assessment. Your supplier may own the control of these hazards, but you want to show that in your analysis.
Also note that the guidance includes L. mono and B. cereus under biological hazards.