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HACCP Analysis Raw Veg Mixes (non RTE) - Please comment

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astro

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Posted 25 November 2020 - 10:11 PM

Hi, please can you take a look at my analysis although it's not quite finished but I do think i may of gone overboard a bit especially with the critical limits. HA001 is the one to look at Please help and advise as I have my BRC next week. Thanks

 

 

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Edited by Jacob Timperley, 26 November 2020 - 11:30 AM.


Charles.C

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Posted 26 November 2020 - 05:20 AM

Hi

 

Please can you take a look at my analysis although it's not quite finished but I do think i may of gone overboard a bit especially with the critical limits.

 

HA001 is the one to look at

 

Please help and advise as I have my BRC next week

 

Thanks

Hi Astro,

 

I assume this is BRC8.

 

I assume this is intended to be a haccp plan and not a BRC risk assessment. ie intended for brc section 2

 

It would help to provide a flowchart so as to know what the product/process specifically is. eg Raw (ie non-RTE), chilled,  "Vegetable" Production ?

 

No offence intended but from a quick view, It looks to be developed by someone who is not yet experienced with the Principles of basic Codex haccp plans.

 

There appear to be no PRPs ?

 

Food threat/Vulnerability is part of a haccp plan ?

 

I suggest to compare with some similar process haccp plans on this forum or perhaps the UK/FSA website Examples.


Kind Regards,

 

Charles.C


astro

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Posted 26 November 2020 - 08:30 AM

Ouch..... 

 

Please see flow charts

 

And yes I do have PRP's

 

VACCP& TACCP i have separate



astro

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Posted 26 November 2020 - 08:48 AM

Forgot to add flows

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Charles.C

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Posted 26 November 2020 - 09:41 AM

Hi Astro,

 

Thks for the flowcharts.

 

Is the finished product RTE ?

 

If so, can compare the hazard analysis to this one (more simplified flowchart) -

 

Attached File  HACCP Generic Model for Fresh produce, Ready-To-Eat Fresh-Cut Vegetables.pdf   427.08KB   61 downloads

 

The above attachment  is initially over- compartmentalised IMO but I like the clarity of the later hazard analysis and the final stages.

 

there are a variety of equally acceptable presentation styles for hazard analyses including yr array  but, at least IMO, it is important that certain aspects are spelled out (somewhere), for example -

 

(1) the interactions  between PRPs and other control measures with respect to hazard risk assessment are identified.

(2) Specific hazards are declared.

(3) Validations for Critical Limits are fully justified

 

It may be that some of the above are handled elsewhere in yr haccp analysis.

 

Personally, I never use Codex type tree structures since I consider it unnecessary but I appreciate that many methodologies find it useful.


Edited by Charles.C, 26 November 2020 - 10:00 AM.
added

Kind Regards,

 

Charles.C


zoelawton

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Posted 26 November 2020 - 09:49 AM

Hello. 

 

I would make sure you have covered the following for each process step:

 

-microbiological 

-physical

-chemical

-radiological (i received a nc for this in july)

-fruad

-malicious contamination

-allergen risks

 

Also, see typo (i think, could be wrong) HA002 Pelling or Peeling?

 

Pleas ensure your Process Flow Diagrams are signed. 

 

I like that the monitoring procedures are referenced in this - i think auditors will like this as it gives them lists of documents to refer to.

 

I know it's not a simple process, but try and make it as simple as possible in the lay out and all in one area. How do you show this to auditors? is it printed or do you show them on screen?



zoelawton

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Posted 26 November 2020 - 09:53 AM

me again, 

 

On your process flows, could you highlight the steps which are either CCP or QCP?

 

This will help an auditor to see where the points are - 

 

From an auditing point of view i would want to know where the CCP/QCP are so i can further look into those areas.



astro

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Posted 26 November 2020 - 10:06 AM

Hi

 

Thanks for your comments.

 

The product is not RTE this is all raw veg, mixes etc to be further processed.

 

I will be showing this on screen due to covid reasons so we will not be going through folders. Flows will be signed once I have competed the analysis, regarding the CCP this is highlighted on the flow diagrams in RED.

 

Whats your thoughts on the Analysis layout, I think I may of gone overboard by putting Critical Limits for everything.

 

I am a out with this as I did a HACCP for the Meat products but for some reasons I am struggling with this, 

 

I just need someone to tell me what I need to do :)



zoelawton

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Posted 26 November 2020 - 10:36 AM

Hi

 

Thanks for your comments.

 

The product is not RTE this is all raw veg, mixes etc to be further processed.

 

I will be showing this on screen due to covid reasons so we will not be going through folders. Flows will be signed once I have competed the analysis, regarding the CCP this is highlighted on the flow diagrams in RED.

 

Whats your thoughts on the Analysis layout, I think I may of gone overboard by putting Critical Limits for everything.

 

I am a out with this as I did a HACCP for the Meat products but for some reasons I am struggling with this, 

 

I just need someone to tell me what I need to do :)

 

Is it necessary to have critical limits for everything? 

 

I understand for example, that contamination of water (i presume water used within the process) has a critical limit and that its tested and you have clearly defined critical limits, however, for receipt of packaging your critical limit states 'fit for purpose with no migration present' - what is your procedure for confirming the absence of chemicals within the packaging / do you document this? If you are to have a critical limit for everything, it is just as important to record the compliance as well as non the compliance. I think 'fit for purpose' is very vague and if this is going to be a critical limit i would just say 'absence of any chemical contamination / taint /  migration or something. 

 

Also, i'm sure the critical limit (regarding the safety of food) would differ between primary, secondary, tertiary packaging?

 

 

I'm not an auditor (internal only) and i come from a low risk process with only a few years experience so forgive me if anything doesn't make sense, i'm just trying to give my opinion and i'm sure this thread will also help me. 



Charles.C

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Posted 26 November 2020 - 11:00 AM

Hi

 

Thanks for your comments.

 

The product is not RTE this is all raw veg, mixes etc to be further processed.

 

I will be showing this on screen due to covid reasons so we will not be going through folders. Flows will be signed once I have competed the analysis, regarding the CCP this is highlighted on the flow diagrams in RED.

 

Whats your thoughts on the Analysis layout, I think I may of gone overboard by putting Critical Limits for everything.

 

I am a out with this as I did a HACCP for the Meat products but for some reasons I am struggling with this, 

 

I just need someone to tell me what I need to do :)

Hi Astro,

 

Yes, I think you have over-complicated the layout and massively regarding the CLs.

 

Modern haccp attempts to minimise number of CCPs via using PRPs. Used to be the opposite.

 

IMO it's easier/more clear to others by using the (basic) flowchart as a 1:1 numerical guide for the hazard analysis

 

An example of my own type of hazard analysis presentation (for fssc22000) is here -

 

https://www.ifsqn.co...ge-4#entry50651

 

For BRC, Columns E,F,M,O,P etc onwards  would be deleted. Column L would be moved to follow Column D. Topmost chunk is also fssc-specific.

 

I detail the Corrective actions, Validations, Verifications etc separately to the excel hazard analysis to keep the work down. Free choice.

 

Such a haccp-type layout was readily BRC acceptable a few years back.

 

The current raw material/risk assessment segment is IMO even more complicated due to BRC's addictions to RA.

 

PS - If the onward processing you mention will validatably (including end-user) remove any existing micro. pathogens etc the the result should be a low risk product, eg if going to be cooked. This tends to substantially simplify any audit IMEX.


Edited by Charles.C, 26 November 2020 - 11:16 AM.
edited

Kind Regards,

 

Charles.C


Charles.C

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Posted 26 November 2020 - 01:36 PM

Hi astro,

 

Had time for a closer look at yr haccp analysis.

 

It's clear that you have a large collection of SOPs and similar, many of which are presumably GMP-type PRPs and others like for allergens...

 

I note that most of the "step" entries have no data for likelihood (L) x severity(S)

 

The "textbook"  logic here is that if the relevant hazard is controlled by PRPs, its risk can automatically be assumed as  low due a Low  L-value. This would then automatically eliminate a large number of items currently associated with "critical limits" since no CCPs would be involved (ie not significant hazards).


Kind Regards,

 

Charles.C


astro

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Posted 26 November 2020 - 01:55 PM

Hi

 

Please find risk assessment I use

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Charles.C

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Posted 26 November 2020 - 02:38 PM

Hi

 

Please find risk assessment I use

Thanks. Mostly reads OK for me. Every matrix will have some subjectivity.

 

I suspect you forgot to label the X/Y axes but the result is anyway symmetrical.

 

The table has one textbook debatable but  haccp-valuable characteristic,  > non-significance for all severities when Likelihood is "negligible", ie =1. This works smoothly for my comment in previous post.

 

Some of the Severity tabs are a little theatrical, eg what happens if off work for precisely 3 days ? :smile:

 

The definition of "Likelihood" is probably more accurately stated as something like -  The likelihood of the hazard being present in the finished product

 

<<< The importance/significance is established by evaluating the likelihood vs severity based on judgement and expertise, reaching a balanced judgement.>>>

Not too sure what a "balanced judgement" actually means but never mind. :smile:

 

<<< Urgent action required to reduce exposure and re-access >>>> Not sure what re-access means ?


Kind Regards,

 

Charles.C


astro

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Posted 26 November 2020 - 02:51 PM

Hi

 

Ok thanks for feed back

 

I think I will change the Likelihood and severity



astro

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Posted 26 November 2020 - 04:22 PM

Hi
 
I have updated my analysis 
 
What do you think please as I am desperate to finish this

 

Will this get me through the BRC

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Charles.C

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Posted 26 November 2020 - 06:23 PM

Hi Astro,

 

IMO the layout looks a lot better than before.

I can’t comment on the Source/Cause very much because I am unfamiliar with Process.

 

Some Comments/Opinions -

  1. Column D preferably titled “HAZARD”
  2. Column G preferably titled “RISK”
  3. No specific mention of key terminologies like PRP, GMP
  4. Critical Limit should have a unique column (ie delete target)
  5. Critical limits (and related entries) should only exist for a CCP within a haccp analysis.
  6. Many Exel Values entered in  “Severity” column look  unrealistic (ie multiple “1”s)
  7. 3 day entries used  in ratings for severity look illogical
  8. Column P is redundant
  9. No specific micro-hazards are mentioned
  10. Cell D72 corrupted
  11. Cell R46 is typically regarded as Verification, not Validation.
  12. Cell O46 is preferably expanded a little, eg compare text in attachment Post 5
  13. Risk value (=9) for generating a CCP in Cell G46 is INCORRECT as per Risk Matrix.
  14. The likelihood ratings (3, 4, 5) in Word document IMO are preferably changed to  Possible, Likely, Very Likely respectively.

PS - Some auditors may expect the chlorine rinse to be a CCP. This relates to the specific Process objective.


Edited by Charles.C, 27 November 2020 - 02:10 AM.
edited

Kind Regards,

 

Charles.C


Jason Mah

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Posted 27 November 2020 - 12:33 AM

Hi, please can you take a look at my analysis although it's not quite finished but I do think i may of gone overboard a bit especially with the critical limits. HA001 is the one to look at Please help and advise as I have my BRC next week. Thanks

 

Hi, 

 

May i know what are the 5 questions that you used to evaluate whether the process step is a CCP or not? Would you please share with us?

 

Thanks a bunch, have a great day ahead!

 

Jason



Charles.C

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Posted 27 November 2020 - 01:53 AM

Hi astro,

 

Please note Comment 13 in Post 16. Either the Likelihood or the Severity (or both) must be adjusted.


Kind Regards,

 

Charles.C


Charles.C

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Posted 28 November 2020 - 07:26 AM

Hi, 

 

May i know what are the 5 questions that you used to evaluate whether the process step is a CCP or not? Would you please share with us?

 

Thanks a bunch, have a great day ahead!

 

Jason

Hi Jason,

 

Possibly/Probably based on attachment below which IIRC is often attributed to Campden.

 

It's basically (Codex + 1) designed to "utilise"  PRPs.

 

Attached File  HACCP Decision Tree 2.pdf   76.69KB   35 downloads


Kind Regards,

 

Charles.C


astro

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Posted 28 November 2020 - 08:42 PM

Hi

 

Thanks for your feed back

 

I am currently just re doing and I will post once complete ready for your feedback

 

Please watch this space

 

Thanks



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Posted 28 November 2020 - 11:17 PM

Hi
 
I have finally finished another version of my HACCP
 
Please take a look and make any comments, criticism or advice to help have this audit ready as I have my audit next Tuesday
 
Thanks

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Charles.C

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Posted 29 November 2020 - 06:34 AM

Hi
 
I have finally finished another version of my HACCP
 
Please take a look and make any comments, criticism or advice to help have this audit ready as I have my audit next Tuesday
 
Thanks

 

Hi Astro,

 

Thks revised version. The PRP layout looks quite attractive.

 

The word "cleaning" appears in numerous places. It's perhaps a nitpick but "cleaning/sanitising" is more accurate (as stated in suggested PRPs/BRC8)

 

IMHO Column C is not really necessary if stated in Column D.

 

IMO there are some missing "M" entries, for example within Step 11. (This item is also, I think, usually regarded as an input so is somewhat misplaced).

 

I deduce you have changed the risk matrix. Consequently following comment is somewhat "speculative" - numerous entries in Sheet1, Columns U,V,W look either illogical or incorrect. i suggest you recheck (rethink?) the entries in these columns. Just as two examples -  U11 is surely impossible, V12 looks nearly impossible.

 

I only just noticed yr specified numbers for metal detector critical limits. IMEX these values are highly unusual (ie high) as representative  MD sensitivity limits.

 

Some of the text reads a little strange to me, eg Sheet 3, E5, but I am unfamiliar with some of the terminologies so may be usual..

 

Otherwise no further additions to my comments in Post 16 and previous Posts.

 

Good Luck !

 

PS (added) - 

 

(1) Extending above comment, just noted there is no "M" section included for the Raw Material. This IMO is a significant omission which I should have spotted earlier. It is advantageous to automatically list BCP(A) Rows for every Process step. Avoids omissions.

 

(2) Also just noted that recycled water is used in this process. IMEX this is likely to be auditorially questioned at some depth from a Safety POV..


Kind Regards,

 

Charles.C


astro

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Posted 29 November 2020 - 10:02 AM

Hi Charles

 

I feel like I am your project lol  :spoton:

 

I appreciate your feedback and your comments.

 

If I correct these issues which you have kindly pointed out do you think this would get me through.

 

Cheers

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Charles.C

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Posted 29 November 2020 - 04:21 PM

Hi Charles

 

I feel like I am your project lol  :spoton:

 

I appreciate your feedback and your comments.

 

If I correct these issues which you have kindly pointed out do you think this would get me through.

 

Cheers

 

Hi Astro,

 

Thks for Introduction / Risk Matrix. Looks like a typical 3x3. One (debatable) comment is that some Authorities (eg NACMCF) consider it is not appropriate to apply a  Decision tree at every Step of the Flowchart but only for Significant Hazards. Codex is ambiguous. Textbooks vary. Consultants seem to prefer the "all in" approach.

 

As I understand this will be a 1st BRC audit for this (quite complex) process. (Personally I would have have opted for a trial audit to get an initial evaluation).

 

IMEX, the "Risk" Level of the Finished Product has substantial influence on the "Intensity" of the audit Procedure, eg RTE versus non-RTE..

The designated Risk is particularly related to the intended  onward use of the Product(s) as per its detailed Specification and (hopefully) Labelling, eg Must be Cooked.

 

One quite useful way to assess the adequacy of one's HACCP Plan (and overall FS Presentation) is to do a Gap Analysis and "tick the boxes" eg via the BRC self-assessment document.


Kind Regards,

 

Charles.C


astro

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Posted 03 December 2020 - 03:10 PM

Hi

 

Thanks for all your comments but as I started from scratch, my call to do this payed off and the audit finished with a AA grade

 

Thanks again





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