8 replies to this topic

[anna898]

Hi All

I have a question as Im a bit confused   and I hope you can explain or advice 

SO for my HACCP I normally do a hazard analysis where I assess the likelihood and severity for each hazard( B/C/P) indicating which risks and steps are high risk , (normally M/M, M/H, H/H) then only these steps I put through the CCP decision tree ( codex) to see which of them will be a CCP others will be controlled by PRP/OPR 

 

Recently an auditor told me that I should put all process steps through the decision tree to see which ones I should control via PRP and which ones will be a CCP.

 

In my understanding the hazard analysis would be pointless if all the steps have to go through decision tree. if a step is managed by PRP and is not significant (L/M, L/H) the decision tree will indicate the same.

Moreover I have seen some haccps for a meat industry where a deliver/intake step  is controlled by PRP (with B= M/H), and in other HACCP it is a CCP.

 

It is a bit confusing and Im not sure If I'm doing it wrong ?

 

 

 

regards 

Anna

[VThiruselvi]

Hi Anna,

 

what you has being doing is correct. some of the risk assessment may combined together with other process flow, hence when to be deciding the PRP or CCP, you have look into the process flow and each individual product. 

[Charles.C]

Hi All

I have a question as Im a bit confused   and I hope you can explain or advice 

SO for my HACCP I normally do a hazard analysis where I assess the likelihood and severity for each hazard( B/C/P) indicating which risks and steps are high risk , (normally M/M, M/H, H/H) then only these steps I put through the CCP decision tree ( codex) to see which of them will be a CCP others will be controlled by PRP/OPR 

 

Recently an auditor told me that I should put all process steps through the decision tree to see which ones I should control via PRP and which ones will be a CCP.

 

In my understanding the hazard analysis would be pointless if all the steps have to go through decision tree. if a step is managed by PRP and is not significant (L/M, L/H) the decision tree will indicate the same.

Moreover I have seen some haccps for a meat industry where a deliver/intake step  is controlled by PRP (with B= M/H), and in other HACCP it is a CCP.

 

It is a bit confusing and Im not sure If I'm doing it wrong ?

 

 

 

regards 

Anna

Hi Anna,

 

Yr difficulties arise from variations in opinions within the HACCP  "community".

 

Yr OP contains queries on 2 topics -

 

(1) How to determine CCPs,

(2) How to determine PRPs.

 

The queries also overlap difference between  "systems" of HACCP, eg, Codex, NACMCF, ISO, FSMA.

 

Regarding (1) Codex, NACMCF,,ISO support yr "basic" procedure. However various standard textbooks/Literature publications use alternative methods such as you refer. Presumably auditors may similarly  also differ depending on their own training histories. afaik, GFSI-recognised FS Standards typically claim to "base" their haccp Principles on Codex (probably following GFSI itself ?).

 

Regarding (2) Codex, NACMCF, ISO support defining PRPs in advance of the hazard analysis which thereby predetermines related likelihoods in the subsequent  hazard analysis. Again, some recognised texts determine PRPs from risk determination within the hazard analysis.

 

One well-known CCP decision tree (Campden) modifies Codex by adding an initial "Stop" question, eg - is the appropriate control measure handled by a PRP ?

 

FSMA introduced it's own risk assessment variant which I believe was borrowed from other RA areas. Personally I have so far failed to comprehend it.

[anna898]

Thank you Charles and VThiruselvi for your answer

 

I do understand that there can be a different approach and outcomes of the applied HACCP plan depending on the standard or even decision tree used. Sometimes even using codex decision tree and campden one can give different outcomes. 

 

 

But can auditor request to change my Haccp because he thinks I should put all process steps in a CCP decision tree? 

[GMO]

To my mind it is the right approach you are taking, also no auditor has the right to say an "interpretive" element like this is right or wrong.  For one, how you're doing it is absolutely how Campden BRI trained me on Level 4.  If they can point to a standard and explain where you're not complying with it then fair enough but I bet they can't... 

[El Molino]

Our HACCP plan is based on the CFIA FSEP framework with the forms outlining all the requirements of hazard analysis and CCP determination. Since SFCR, CFIA has watered down the programs but most federally inspected plants have maintained the FSEP framework - check out Form 8 combined which provides the PRP, oPRP and CCP determination in a full spreadsheet summary where you add each step of the process. I don't think an auditor should tell you to " change" your plan as it is your program - not theirs - they are just there to determine if your FS program meets the standard.

[Charles.C]

Thank you Charles and VThiruselvi for your answer

 

I do understand that there can be a different approach and outcomes of the applied HACCP plan depending on the standard or even decision tree used. Sometimes even using codex decision tree and campden one can give different outcomes. 

 

 

But can auditor request to change my Haccp because he thinks I should put all process steps in a CCP decision tree? 

So which audited Standard are you talking about ?

[Hoosiersmoker]

Our HACCP plan takes all identified hazards into account. If they are controlled by PRPs it is stated in the plan as such with no need for CCPs. If you exclude certain hazards just by identifying them as already being controlled by your PRPs, where is the assessment for those written down? If the assessment / analysis isn't recorded somewhere it technically doesn't exist.

[anna898]

Hi All 

Thanks for all replies, 

I've done some research, even asked my uni professor.

And As I though I'm doing it right. If my hazards analysis states that identified hazard is not significant and its controlled by PRP, there is no need to put it through the CCP decision tree. 

We are not certified by BRC/GFSI just FSA and SALSA, it was auditor from FSA who said that my HACCP is wrong. Maybe he need a HACCP refresher

Thanks again for your help