14 replies to this topic

[Cici2018]

Hi, can anybody give me some clue for doing hazard analysis for new process steps? Where can I find some references. For example, we are going to start organic chicken process. I think the hazard will exist between non-organic and organic. If organic product is contaminated with non-organic, this should be chemical contamination?

 

We have Reference Database for Hazard Identification 2008 from CFIA. Maybe there is already an updated one. I do not find any PDF format but got an online link on CFIA's website.

 

Thank you for any clue for doing hazard analysis!

[pHruit]

Are you looking at HACCP with regard to any specific certification standard?
If it's just a "general" HACCP plan, i.e. solely looking at food safety, then I can't see how non-organic chicken would be a chemical hazard for organic chicken, as surely your non-organic chicken is still safe and compliant with the relevant regulations?

If it's a broader HACCP plan that that needs to meet the likes of e.g. the BRC standard, where the expectations have been somewhat expanded (corrupted? ) to meet their ever-growing list of "hazard" categories then in this case you may need to consider it as a potential risk, but probably more in terms of product authenticity/label claims than in terms of an actual food safety hazard.

[kfromNE]

For general HACCP steps -

https://meatsci.osu....ation-materials

 

Hazards between organic vs non-organic - not sure.

[Scampi]

Use the CFIA on line tool

 

https://active.inspe...introe.aspx?i=1

 

It covers absolutely everything (except organic). 100s of hour have gone into this database to assist producers, and was updated re: SFCR to encompass more products/processes than ever before

 

Yes, contaminating organic with non is a chemical hazard, but you can then label it all traditionally and save the product

 

Easiest thing to do it have set days for organic production, then you can ensure everything is cleared out of the chiller and segregated in combos for further processing

 

Don't forget that organic approved detergents and sanitizers will have to be used the night before an organic day

[KTD]

I agree with pHruit and disagree with Scampi. I am not aware of any food safety risk from non-organic chicken. I guess that there could be certain individuals who are ultra-sensitive to any allowed chemical residuals that might be in the non-organic chicken, but I have not heard of any such situation.

In the US, cross-contamination is a labeling (USDA AMS)/authenticity issue...and GFSI audit schemes.

[Scampi]

It's considered a chemical hazard in Canada, as well as a labelling issue

[pHruit]

It's considered a chemical hazard in Canada, as well as a labelling issue

I was just about to say that in this case I disagree with me and agree with Scampi, since Scampi is far more familiar with Canadian regs/expectations than I am!

 

Although from a ye olde HACCP perspective I don't believe it is a "hazard" within the purely food-safety sense originally intended, so I don't entirely disagree with myself, but I do recognise that this view of HACCP seems to be very much on the decline courtesy of various regulators and certification standards.

 

(O/T, but Scampi, your signature makes it really difficult to resist addressing you as Sir Scampi )

[KTD]

Wow - seems to be a bit of a reach, but I don't know the history in Canada...

Thanks

 

Keith

[ESuttmiller]

Scampi is usually on top of things! 

[Scampi]

oh, I'm good with Sir Scampi!!!!   Just not sir/ma'am  I feel old enough, don't need any help there LOL

 

 

The poultry inspectors in Canada are all trained at one central super secret location and all play out of the same play book----they are used to seeing a HACCP plan presented in a particular way (theirs) and have a really difficult time with anything else, which in turn makes your life very very very difficult.

 

And then there's this --- some studies have shown that between 25 and 31% of free range and/or organic carcasses tested positive for salmonella..........so yep, totally in your HACCP plan    (me thinks this will be due to the inability/lack of desire  to adequately treat the wash water in the process)  but that's just my opinion

 

https://www.research..._Responsibility

 

various foodborne diseases (55, 81). Meat, poultry, raw milk, and eggs have been identified as sources of Salmonella. In various studies, Salmonella seroprevalence has been compared in finishing pigs from conventional and organic housing systems, but no significant differences have been found (60, 79, 87). No significant difference in Salmonella prevalence was found when comparing pastured and conventionally reared broilers (72). However, Bailey and Cosby (3) found that 31%of carcasses from free-range chickens and 25%of carcasses from organic chickens were positive for Salmonella.

Farms with vaccinated hens are exempt from these measures, but because of restrictions in the export of products from vaccinated animals, few farmers have vaccinated their chickens. Eggs from organic chickens that are raised in confinement because of veterinary reasons can still be sold as organic, diminishing the economic reason to vaccinate animals.

Campylobacter.Campylobacteriosis is a serious disease that is mainly caused by consumption of contaminated poultry, although numerous other sources should not be overlooked (39). Several studies have been conducted on the prevalence of Campylobacter in organic versus conventionally reared farm animals

Edited by Charles.C, 14 September 2021 - 10:49 PM.

[Charles.C]

For a given Location, a (haccp) Organic Food "Hazard" is presumably no different to a non-organic one from a purely safety POV. ?

 

"Organic food is safer" is a false statement
The organic label is not a guarantee of food safety. Organic refers
only to a product that has been produced in accordance with
certain standards throughout the production, handling, processing
and marketing stages; it does not refer to the characteristics
and properties of the finished product. In general, provided that
growers adopt proper agricultural practices, both conventional
and organic farming systems have the potential to produce safe
food. Organic standards will not exempt producers and processors
from compliance with general regulatory requirements such as
food safety regulations, pesticide registrations and general food
and nutrition labelling rules.

 

 

 FAO,Organic Foods - Are they Safer,2021.pdf   1.88MB   15 downloads

 

@Cici -  pdf (2008) attached. afaik no formal updates per se exist however i am not located in Canada.

 

 Canada,hazarddatabase_english__2008.pdf   1.15MB   15 downloads

(the online version in Post4 should obviously be more up-to-date)

 

PS - USDA approach -

 

Produce can be called organic if it’s certified to have grown on soil that had no prohibited substances applied for three years prior to harvest. Prohibited substances include most synthetic fertilizers and pesticides. In instances when a grower has to use a synthetic substance to achieve a specific purpose, the substance must first be approved according to criteria that examine its effects on human health and the environment (see other considerations in “Organic 101: Allowed and Prohibited Substances”).

https://www.usda.gov...nic-label-means

 

 

The current list of "prohibited substances" certainly appears to be focussed on "chemicals"

Edited by Charles.C, 15 September 2021 - 12:56 AM.
edited

[Cici2018]

Are you looking at HACCP with regard to any specific certification standard?
If it's just a "general" HACCP plan, i.e. solely looking at food safety, then I can't see how non-organic chicken would be a chemical hazard for organic chicken, as surely your non-organic chicken is still safe and compliant with the relevant regulations?

If it's a broader HACCP plan that that needs to meet the likes of e.g. the BRC standard, where the expectations have been somewhat expanded (corrupted? ) to meet their ever-growing list of "hazard" categories then in this case you may need to consider it as a potential risk, but probably more in terms of product authenticity/label claims than in terms of an actual food safety hazard.

Thank you! I am working on our HACCP plan to satisfy the BRC audit. So, based on the discussion here, I think I need to add chemical hazard for organic process steps and also fraud hazard for wrong label issue.

[pHruit]

Thank you! I am working on our HACCP plan to satisfy the BRC audit. So, based on the discussion here, I think I need to add chemical hazard for organic process steps and also fraud hazard for wrong label issue.

Yes, that seems like a reasonable approach based on the discussion here. Personally I'd be inclined to list one hazard (non-organic contamination of organic product) and assign both hazard types (authenticity and chemical) to it. I'd also add an explanatory note that the chemical hazard element is included due to Canadian regulatory requirements - hopefully your auditor will already be sufficiently familiar with this, but spelling it out may help avoid a tedious discussion if the auditor takes a very black and white view that in BRC-land the hazard strictly relates to authenticity.

 

 

 

oh, I'm good with Sir Scampi!!!!   Just not sir/ma'am  I feel old enough, don't need any help there LOL

 

Very well. In that case, I dub thee Sir Scampi of HACCPshire
 

[Cici2018]

We have risk assessment matrix in our HACCP plan for each hazard identified. For the likelihood, severity, risk number of a hazard, how to determine the level? For example, likelihood is 1 or 2, Severity is 3 or 4, and then final risk level is Sa, Mi, Ma or Cr.

 

Can anybody give me any clue for this? Thank you!

[Charles.C]

We have risk assessment matrix in our HACCP plan for each hazard identified. For the likelihood, severity, risk number of a hazard, how to determine the level? For example, likelihood is 1 or 2, Severity is 3 or 4, and then final risk level is Sa, Mi, Ma or Cr.

 

Can anybody give me any clue for this? Thank you!

 

Hi Cici,

 

This thread is becoming somewhat "haccp-circular".

 

As I understand the thread is actually BRC-centric rather than Canadian. Note that one BRC clause is organic-specific, ie 5.4.5. -
 

 

Where claims are made about the methods of production (e.g. organic, halal, kosher) the site shall maintain the necessary certification status in order to make such a claim.

 

Some other BRC clauses also contain caveats related to an existing parallel organic assertion.

 

One lengthy BRC thread already exists here in respect to merging organic into HACCP -

 

https://www.ifsqn.co...cp/#entry169989

 

Another one is this (2015) mixed SQF/BRC discussion -

 

https://www.ifsqn.co...sqf/#entry85994

(esp see post 3)

 

I also noticed this Australian Organic Certifier's comment  on organic/haccp -

 

Hazard analysis critical control  point  (HACCP) -   Management  system  oriented  towards minimising or
eliminating hazards posed as part of the production process through means of monitoring and verification.

For organic operators, HACCP management implies a system of identification of all significant hazards that
may compromise an ability to conform to this [ Certifier's] Standard for organic production, identifying control points,
putting in place management practices that help eliminate or reduce risks associated with those hazards,
and then maintaining verification processes to ensure that management practices are effective.

 

 

Basically, i interpret  "organic hazards" are those which may impact "organic integrity".

 

Personally, I doubt the necessity to include "organic" hazards in the BRC haccp plan (cf post 15 / 1st link, post 3 / 2nd link) although post 23 / 1st link does succeed in manouevering the organic aspect in via the "Fraud option". The latter seems rather over-contrived to me albeit having some generic historical support. Nonetheless the BRC scope for "hazard" is amenable to "organic hazard" although scope for "organic CCP" is not.

 

As far as query in post 14 is concerned, this is always a subjective issue and depends on the specifics (if any), eg how many "Organic CCPs" do you seek ? The observations in examples attached below may help.

 

Alternative viewpoint - If you have a look in the Literature, you can find a few previous attempts at responding to Organic Production in a "HACCP type of way".  None IMO are simple for reasons such as extolled in my Post 11. Notably there is a tendency  for avoiding "haccp" terminology in favour of "risk assessment".

 

Examples of an Organic Risk Assessment and a  HACCP-based Organic Control Point (OCP) Program are attached -

 

 organic risk assessment.doc   74.5KB   13 downloads

 HACCP--based Organic Control Point (OCP) Program.pdf   292.12KB   16 downloads

Edited by Charles.C, 16 September 2021 - 06:10 AM.
edited