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How to include Organic Activity in HACCP?

HACCP Organic

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#1 technicalDS

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Posted 02 February 2021 - 09:53 AM

Hello, we have recently gain our first Organic certification. Our company is an agent who imports and exports dry food ingredients. I am wondering if anybody knows how organic activity should be included in our HACCP? I am looking forward to your ideas :) Barbara



#2 pHruit

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Posted 02 February 2021 - 10:16 AM

I was initially very confused about how organic status had any bearing on HACCP, and then I spotted that this was posted under the Agents & Brokers standard, and it has some rather avant-garde ideas about "HACCP"...

What hazard classes do you currently have in your HACCP plan?

The biological / physical / chemical / allergen / radiological / fraud / security ones are somewhat "normal", being present in the BRC Food standard, but the "hazards mandated by the customer or relevant regulatory authorities" one has an interesting interpretation IMEX.

I'd put this into a class called something like "paperwork" or "import/export", as that covers a multitude of potential delays/rejections relating to transit across customs lines.

For the organic bit specifically, your risk is loss of organic status (therefore potentially rendering the product useless to you / your customers) or delay/rejection at the border. (There is of course also the potential fraud by misrepresentation risk, but that probably falls into your existing hazard category for fraud - just make sure you document that you've considered it ;) ).

I'm not currently doing any organic import/export work so am honestly a little out of the loop on how things are working with e.g. the EU TRACES system for the UK at present, but there are potentially several process steps at which this could be an issue - obviously customs clearance is a significant one, but the paperwork itself needs to move around correctly through the supply chain too. You'll need to go through your flow diagram and hazard analysis to work out where this is relevant for you, and potentially introduce new process steps if needed.



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#3 technicalDS

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Posted 02 February 2021 - 10:33 AM

Thank you #pHruit.
My HACCP flow contains 4 steps - buying, Transport, Storage & Delivery/ Rejection. We have no CCPs I am not sure whether to change the HACCP from the beginning - we do not store or touch the product; or just put any separate step for the organic ? I would be very grateful for our help as this is my first time with the organic status.

If you have a minute to help me o this i could email you my HACCP and we could look on it together ?



#4 pHruit

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Posted 02 February 2021 - 10:57 AM

Happy to help, but only via the forum - that way others get benefit from it. I originally found this place via googling an obscure question, and it really helped me out, so I'm willing to give my time to give others the same benefit.
Private assistance is more like traditional consultancy, and I'm trying to limit the amount of that I'm taking on at present as I've got too much work really, particularly given that I'm not actually a consultant! (It's also somewhat more costly than a discussion on a forum ;) ).

 

If you're willing to post your HACCP here then I'll happily take a look, and I'm sure others will too, but I'll also completely understand if you aren't able to do this.

My initial thoughts are that you may have fewer process steps than I'd use - e.g. your "transport" step potentially encompasses several distinct activities, so these might be easier to present, risk assess, and potentially to control, if split into its constituent parts - e.g. transport to port, export inspection/clearance (if relevant for your product types), transport via sea/road (optional process - relevant e.g. coming into/out of the UK, less so moving across a land border into/out of the EU), import inspection, transport again to destination.

You could also opt to break down the storage step, as this is also multiple activities (inspection, unloading, intake, transfer to warehouse, then the same again on the way out) although you could also take the not unreasonable position that this is covered by your providers' HACCP plans.

Similarly you could also opt to split the buying step into subsections - supplier approval (or at least a check that the supplier is approve), contract agreement etc as separate parts. May not be necessary but possibly something to consider.

If you've already passed a BRC then there is perhaps an argument for not making loads of massive changes and overcomplicating things, but equally you want a HACCP plan that really works for what you're physically doing as a business.

 

FWIW I'd also suggest looking at the Incoterms you use to buy/sell products, as these will contractually define the parts of the supply chain for which you're actually responsible. If you're not using Incoterms at present then I'd very much recommend looking at this with your colleagues in purchasing and logistics, as it really does provide a very simple and clear mechanism for defining where you, your supplier, and your customer, are responsible for the goods as they move from source factory to end destination, particularly with international trade and customs tariffs etc, and this can save you time and money when things go wrong. (Things going wrong is an inevitability at some point, if you move enough products around the place).

Overview on the ICC's website here: https://iccwbo.org/r...incoterms-2020/



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#5 technicalDS

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Posted 02 February 2021 - 11:01 AM

Thank you!

 

The reason I've asked for a private email is because i don't know if I can upload a document on here? I have tried but cannot see an option .. I am more than happy to share everything on here:)



#6 pHruit

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Posted 02 February 2021 - 11:07 AM

Ah, in that case you need to use the "more reply options" button:

zZiYs3s.jpg

From there you can then add attachments etc:

EvCYXfD.jpg



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#7 technicalDS

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Posted 02 February 2021 - 11:20 AM

Hi, thank you again! I am new o here so I wasn't sure if on the standard membership I am allowed to attach any files !

 

I have attached all my HACCP documents, please feel free to review them and let me know your thoughts.

Attached Files



#8 Scampi

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Posted 02 February 2021 - 01:59 PM

You've got a good base there

 

I would add organics to all of them---you need to demonstrate SPECIFIC controls for the organic stream. If it's easier, imagine the organic items are peanuts-treat it like al allergen and demonstrate how you will ensure no cross contamination and, more importantly, how you ensure your final customer actually gets organic product and not traditional

 

Agree with PP, the approval program is probably you're single most important function for organic products. You need to see everything they have, certificates, audits reports etc.  Organic products are often faked


Please stop referring to me as Sir/sirs


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#9 Charles.C

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Posted 02 February 2021 - 02:43 PM

Hi Barbara,

 

Apologies but I am confused.

 

I don't quite see how w/wo an Organic Classification is related to Food Safety ?

 

I also don't yet see how the attached documents equate to a BCPA Codex haccp plan., eg where is the hazard analysis/risk assessment ?

 

Is there a Standard involved ?


Kind Regards,

 

Charles.C


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#10 pHruit

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Posted 02 February 2021 - 03:07 PM

Hi Barbara,

 

Apologies but I am confused.

 

I don't quite see how w/wo an Organic Classification is related to Food Safety ?

 

I also don't yet see how the attached documents equate to a BCPA Codex haccp plan., eg where is the hazard analysis/risk assessment ?

 

Is there a Standard involved ?

Hi Charles - ref red bit, the BRC Agents & Brokers standard mandates a "hazard and risk assessment" that is sort of a corruption of HACCP principles with a notably broader scope than food safety. It's sort of an application of the methodology to both food safety and to "hazards" that are more of an annoyance / financial / customs / legal (but not food safety law) / logistics issue / source of potential complaints than they are a food safety hazard.

 

In some ways one could argue that it makes sense within the context of the A&B standard (i.e. showing that a business is competent in areas that agents and brokers need to be competent), but it's a bit of a shock to the system if you're used to more traditional HACCP...

I actually quite enjoyed it in the end, and done right it can engage with departments who'd not normally think about HACCP and help them work efficiently and with focus. Or maybe it just felt a bit more light-hearted due to the general absence of the "will this kill someone or not" aspect that goes with "real" HACCP :happydance:

 

@Barbara / TechnicalDS (never sure if people want to be addressed by name or username!):
I see from your process flow that you have grouped the process steps within larger "HACCP Steps", so you are actually covering a lot of the separate items I'd mentioned previously. Without the associated hazard analysis it's difficult to interpret this, but personally I'd be inclined to take each process step (even though it may not be a step where something physically happens) as a step in its own right, and do the hazard analysis individually for each of these.

I'd definitely have customs clearance as a step in its own right, as for the paperwork side of things that is a source of significant potential issues. Scampi's point about organic from origin very much stands, but that's all wasted if you don't get the import/export side right and the product loses the organic status or simply gets stuck.



#11 Charles.C

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Posted 02 February 2021 - 03:20 PM

Hi Charles - ref red bit, the BRC Agents & Brokers standard mandates a "hazard and risk assessment" that is sort of a corruption of HACCP principles with a notably broader scope than food safety. It's sort of an application of the methodology to both food safety and to "hazards" that are more of an annoyance / financial / customs / legal (but not food safety law) / logistics issue / source of potential complaints than they are a food safety hazard.

 

In some ways one could argue that it makes sense within the context of the A&B standard (i.e. showing that a business is competent in areas that agents and brokers need to be competent), but it's a bit of a shock to the system if you're used to more traditional HACCP...

I actually quite enjoyed it in the end, and done right it can engage with departments who'd not normally think about HACCP and help them work efficiently and with focus. Or maybe it just felt a bit more light-hearted due to the general absence of the "will this kill someone or not" aspect that goes with "real" HACCP :happydance:

 

@Barbara / TechnicalDS (never sure if people want to be addressed by name or username!):
I see from your process flow that you have grouped the process steps within larger "HACCP Steps", so you are actually covering a lot of the separate items I'd mentioned previously. Without the associated hazard analysis it's difficult to interpret this, but personally I'd be inclined to take each process step (even though it may not be a step where something physically happens) as a step in its own right, and do the hazard analysis individually for each of these.

I'd definitely have customs clearance as a step in its own right, as for the paperwork side of things that is a source of significant potential issues. Scampi's point about organic from origin very much stands, but that's all wasted if you don't get the import/export side right and the product loses the organic status or simply gets stuck.

 

Hi pHruit,

 

I couldn't see any mention of BRC ?

 

If it is BRC, does AB Standard copy Food and include Quality, Legality "hazards" (eg organic) in a risk assessment requirement (not a haccp plan) ?.

 

The details in attached FS document text (sort of expanded Codex) seem disconnected from the other documents.


Kind Regards,

 

Charles.C


#12 pHruit

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Posted 02 February 2021 - 03:26 PM

Hi pHruit,

 

I couldn't see any mention of BRC ?

 

If it is BRC, does AB Standard copy Food and include Quality, Legality "hazards" (eg organic) in a risk assessment requirement (not a haccp plan) ?.

 

The details in attached FS document text (sort of expanded Codex) seem disconnected from the other documents.

How strange - this topic was in the BRC Agents & Brokers forum when I first started replying this morning?!

That standard lumps various things into section 2 of the standard - i.e. the equivalent of the HACCP section of the BRC Food standard - although it calls it "Hazard and Risk Assessment". It's sort of a quasoi-HACCP plan in that it isn't pure HACCP, but the methodology should theoretically be broadly the same.
 



#13 Charles.C

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Posted 02 February 2021 - 03:49 PM

How strange - this topic was in the BRC Agents & Brokers forum when I first started replying this morning?!

That standard lumps various things into section 2 of the standard - i.e. the equivalent of the HACCP section of the BRC Food standard - although it calls it "Hazard and Risk Assessment". It's sort of a quasoi-HACCP plan in that it isn't pure HACCP, but the methodology should theoretically be broadly the same.
 

 

^^^(red) The nebuchadnezzar trick. :smile:

 

Maybe Barbara can confirm if BRC. Probably is in UK of course.

 

BRC Food separates risk assessment (including everything conceivable) and haccp (covering [nominally] Codex safety).

 

Seems ABS have attempted to fuse the two topics which highly ambitious.

 

My difficulty is that the documents "FS" layout is distinctly unorthodox as compared to a typical Codex food haccp plan (in fact I have never seen a similar layout). But maybe the result is OK for ABS.


Kind Regards,

 

Charles.C


#14 technicalDS

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Posted 02 February 2021 - 05:47 PM

Hi All

 

This topic was added to BRC Agents & Brokers, not sure why this has been moved :( 

I work in a technical team and adding this organic activity to HACCP was my task to do this week, but to be honest I've got no clue how to start with it..

 

If anybody would like to help i will be ore than grateful 

 

Regards,

Barbara



#15 olenazh

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Posted 02 February 2021 - 06:03 PM

My Organic Program includes Organic Policy, Cleaning & Pre-Op forms for organic production days, HACCP Form #3 (Process flow chart) for all organic HACCP plans, some SOPs for organic storage, etc. I don't have separate hazard analysis for organic process steps or products as it would be redundant (food safety hazards are the same) I've included organic products into my Food Fraud analysis because as it was stated in this thread organic products often are objects of fraudulent activities.



#16 technicalDS

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Posted 02 February 2021 - 06:11 PM

Hi Olenazh

 

Thank you. 

The problem I've got is that I can create all the procedures etc for the production as I'm from the production background, but now at this Agent & Broker business i don't know how to include this in hazard analysis as only risk there is from the organic activity is that the conventional product could be sold as the organic, but this is nit really the food safety issue, is it ? I am working according to BRC Agents & Brokers standard.



#17 olenazh

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Posted 02 February 2021 - 06:20 PM

Then do hazard analysis from the standpoint of food fraud - at least, you'll do something to address your activity plan for this week.



#18 pHruit

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Posted 03 February 2021 - 09:02 AM

Hi Olenazh

 

Thank you. 

The problem I've got is that I can create all the procedures etc for the production as I'm from the production background, but now at this Agent & Broker business i don't know how to include this in hazard analysis as only risk there is from the organic activity is that the conventional product could be sold as the organic, but this is nit really the food safety issue, is it ? I am working according to BRC Agents & Brokers standard.

 

I know it seems counter-intuitive if you've got experience in HACCP, but I'd treat loss of organic status as being a "risk" in roughly the same way you would do for e.g. allergen contamination. (Almost can't believe I've typed that, but having done A&B since issue 1, IMEX it's what auditors are expecting to see).

For example, at step 17 in your flow diagram, your "hazards" could be loss of organic status / delay at customs due to absence of correct CoI etc.You'd then look at your prereqs to control that potential "hazard", assign a likelihood & severity / put that through your risk matrix / decision tree or whatever method you're using. Note that "severity" or equivalent obviously isn't about food safety, so is very subjective.

 

I know it's very odd, and I had some weird discussions with auditors particularly in our first audit just after Issue 1 of the standard came out, but it sort of fits if you work at it and think of it more in terms of "overall business" HACCP than "food safety" HACCP.

Can't believe I've typed that either. Must go and flay myself with the Codex standard :happydance:



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#19 technicalDS

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Posted 03 February 2021 - 11:21 AM

I know it seems counter-intuitive if you've got experience in HACCP, but I'd treat loss of organic status as being a "risk" in roughly the same way you would do for e.g. allergen contamination. (Almost can't believe I've typed that, but having done A&B since issue 1, IMEX it's what auditors are expecting to see).

For example, at step 17 in your flow diagram, your "hazards" could be loss of organic status / delay at customs due to absence of correct CoI etc.You'd then look at your prereqs to control that potential "hazard", assign a likelihood & severity / put that through your risk matrix / decision tree or whatever method you're using. Note that "severity" or equivalent obviously isn't about food safety, so is very subjective.

 

I know it's very odd, and I had some weird discussions with auditors particularly in our first audit just after Issue 1 of the standard came out, but it sort of fits if you work at it and think of it more in terms of "overall business" HACCP than "food safety" HACCP.

Can't believe I've typed that either. Must go and flay myself with the Codex standard :happydance:

Hi, 

Thank you for this. I have started with updating my PPRS, please see attached - number 6. Please let me know what you think.

 

Now, I am going to update the flow and the risk scores etc.

 

Regards,

Barbara

Attached Files


Edited by technicalDS, 03 February 2021 - 11:22 AM.


#20 pHruit

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Posted 03 February 2021 - 01:54 PM

For PRP purposes I'd suggest also including the initial purchasing stage - i.e. your potential hazard is not just loss of organic status, but purchase of non-organic product. Your supplier approval, purchasing etc procedures likely already cover this, but I'd also include your VACCP plan (or equivalent - whatever it is you're doing for section 4.8) as part of the PRPs related to this.

In terms of overall hazards (i.e. not step-specific) you'd potentially have loss of organic status at point of delivery, if labels/paperwork etc is incorrect or missing when it arrives with the customer?



#21 Charles.C

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Posted 04 February 2021 - 01:00 AM

Hi Barbara,

 

JFI here are some vaguely related posts/threads from the BRC, AB sub-forum which may be useful reading -

 

https://www.ifsqn.co...rs/#entry156067

https://www.ifsqn.co...ce/#entry126512

https://www.ifsqn.co...rs/#entry156994

https://www.ifsqn.co...rs/#entry142448

https://www.ifsqn.co...nt/#entry103641

And

https://techni-k.co....roduct-defence/

 

I note there is also a BRC Intepretation Guide for this Standard. Usually worth purchasing.

 

@pHruit, - I see what you meant in respect to blending risk assessment and haccp (and "risk analysis"). The glossary (I only have draft Issue2) still seems fixated on food/safety despite main text's inclusion of fraud and BRC's Uncle Tom Cobley.

 

TBH, using a traditional hazard analysis layout still looks the easiest, most compact, approach to me  but perhaps depending on familiarity with conventional food HACCP/risk assessment. 

 

Just as an example, this, usually haccp-fundamental, clause seems currently by-passed within the attached documents -

 

2.7
The company shall complete a documented risk analysis of the potential hazards in order to identify which need to be controlled. The following should be considered:
-  the likely occurrence of the hazard,  
- the severity of the hazard (e.g. injurious to health, potential to cause food poisoning, rejection or a product recall)

- existing pre-requisite programs which effectively prevent or reduce the hazard to acceptable limits.

 

 

Perhaps BRC's textual hopes are auditorially modified for the real world (ie actual brokers).

 

I imagine that SQF would simply manage "Organic" as a haccp Quality certification factor.


Kind Regards,

 

Charles.C


#22 pHruit

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Posted 04 February 2021 - 09:06 AM


@pHruit, - I see what you meant in respect to blending risk assessment and haccp (and "risk analysis"). The glossary (I only have draft Issue2) still seems fixated on food/safety despite main text's inclusion of fraud and BRC's Uncle Tom Cobley.

 

TBH, using a traditional hazard analysis layout still looks the easiest, most compact, approach to me  but perhaps depending on familiarity with conventional food HACCP/risk assessment. 

 

Just as an example, this, usually haccp-fundamental, clause seems currently by-passed within the attached documents -

 

 

Perhaps BRC's textual hopes are auditorially modified for the real world (ie actual brokers).

 

I imagine that SQF would simply manage "Organic" as a haccp Quality certification factor.

Hi Charles,

Glossary remains the same in the published version - reading that alone, one would conclude that the requirements in the section are more akin to "real" HACCP.

My advice is very much based on experience of how it's audited in practice, across multiple audits with different auditors, and including one senior auditor/trainer overseeing an auditor conducting their final training audit for sign-off against the standard.

 

I agree r.e. taking a more traditional HACCP-based approach to structure, and indeed I'd assumed that Barbara also has the more typical hazard analysis / likelihood x severity elements in another document / part of the system.

If not then I'd very much recommend doing so. Whilst the auditors aren't expecting "true" HACCP as such, they unsurprisingly largely seem to have backgrounds auditing the food standard and thus will be most familiar with / expecting this type of structure.

 

I wonder what the odds on Issue 3 of A&B / Issue 9 of the Food standard somehow managing to cram food safety culture into the required HACCP hazards are? :ejut:



#23 technicalDS

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Posted 04 February 2021 - 10:13 AM

Hi,

 

I have attached my HACCP Risk assessment amended to include organic fraud. Please let me know your thoughts.

I am open for suggestions.

 

Thank you :) 

Attached Files



#24 Charles.C

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Posted 05 February 2021 - 01:01 AM

Hi,

 

I have attached my HACCP Risk assessment amended to include organic fraud. Please let me know your thoughts.

I am open for suggestions.

 

Thank you :) 

 

Hi Barbara,

 

Thks yr Risk Asessment document.

 

Comments are based on my experience of Food Haccp since not familiar with typical responses for AB Standard..

 

(1) Nice layout. Risk matrix/interpretation looks like one of the many Literature published forms (similar to that proposed by/for SQF?)

(2) This RA Matrix may not be appropriate for Fraud/Organic/Others since, afaik for BRC, these are not necessarily Safety-related "hazards".**

(3) The RA lumps all sub-processes within the 4 "Main" Steps together. This seems questionable but maybe acceptable for AB Standard.

(4) I deduce that the RA assumes every potential hazard can be routinely controlled by PRPs. Is this assumption supported by existing data, ie validatable ?

(5) The likelihood(s) and severity(s) associated with every potential hazard are identical. This seems improbable ?

(6) Type of hazard if other than (directly) Safety-related might be usefully noted, eg Fraud (Quality/Legality), Organic (Quality/Legality[?])

 

** Maybe implement 2 matrices, eg add something like the one attached below -

 

Attached File  quality risk matrix.pdf   41.33KB   4 downloads

 

Also a couple of thoughts regarding previous attached documents -

 

 (i) The STORAGE step in flowchart seems relatively limited in detail.

(ii) I cannot see any specific (eg numbered) mention of a Raw Material/Product RA/Procedure for Safety  in PRP or flowchart document. IMEX, this is often a key input for Supplier Approval Procedures.


Edited by Charles.C, 05 February 2021 - 04:11 AM.
added

Kind Regards,

 

Charles.C


#25 pHruit

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Posted 05 February 2021 - 08:16 AM

I largely agree with the comments from Charles - as I mentioned earlier, I'd definitely break each of your four large steps into their individual elements, so you can consider each actual activity separately.

 

The risk matrix element (point two in Charles's post) is an interesting one that you can potentially tackle in two ways - either a separate matrix as Charles suggested, or a combined hybrid matrix where your severity rating could be something like "serious illness / business-critical impact", giving a relevant non-safety impact type for an agent/broker. I prefer this method as it keeps it all in the one RA document, but I can understand that others would want to have a more pure HACCP-type approach as a standalone thing.

 

Personally I'd also add more detail to the hazards to show that you really have considered every scenario - e.g. "temperature abuse" in transport could be commissioning the wrong type of vehicle, chiller breakdown, an idiot on a dockside forgetting to connect a chilled container to a power source (yes, I've seen it happen...).






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