8 replies to this topic

[Rick Schaper]

Hello all!
 

My company manufactures frozen pizzas. We have 11 varieties, 8 without meat (raw, RTE, or both) and 3 varieties without meat. We have only ever had a HACCP plan that covers the USDA-inspected varieties with meat. I am now wanting to make sure our three varieties without meat are included in a HACCP for two reasons: for better food safety (obviously), and for SQF certification on all of our products (it is my understanding that SQF Edition 9 2.4.3 would require all products in the certification scope to be under a HACCP plan). 

 

My original idea was that I could simply add these three non-meat varieties into our current HACCP plan with no issue at all, as long as I specify what is USDA-inspected and what is not USDA-inspected. My USDA inspector seems to disagree with this, and says I cannot include non-meat/non-USDA-inspected products in the same HACCP as products with meat, even though all of the processing steps and hazards (besides the meat part) are the exact same. Would I have to create a new HACCP plan for the three remaining varieties and keep it separate? It just seems so redundant to me when they should all be in the same HACCP plan. I have read as much as I can of USDA's Regulations and through previous forums and cannot find the answer to this. 

 

On a slightly similar note, we receive frozen cookie pucks and repackage them into smaller packages as well. I would like this in our SQF scope too, so I would need to include this in HACCP. I am imagining this will have to be its own HACCP plan?

 

Thanks for the help.

Edited by Charles.C, 03 November 2021 - 06:53 AM.
slightly edited

[adamperry2235]

your frozen cookies may be a new plan and under a new line. But I would agree with you on the one plan for the non-meat pizzas. The only thing you may have to do is amend your flow chart, and put that analysis in, otherwise it should be fine.

[Charles.C]

Hello all!
 

My company manufactures frozen pizzas. We have 11 varieties, 8 without meat (raw, RTE, or both) and 3 varieties without meat. We have only ever had a HACCP plan that covers the USDA-inspected varieties with meat. I am now wanting to make sure our three varieties without meat are included in a HACCP for two reasons: for better food safety (obviously), and for SQF certification on all of our products (it is my understanding that SQF Edition 9 2.4.3 would require all products in the certification scope to be under a HACCP plan). 

 

My original idea was that I could simply add these three non-meat varieties into our current HACCP plan with no issue at all, as long as I specify what is USDA-inspected and what is not USDA-inspected. My USDA inspector seems to disagree with this, and says I cannot include non-meat/non-USDA-inspected products in the same HACCP as products with meat, even though all of the processing steps and hazards (besides the meat part) are the exact same. Would I have to create a new HACCP plan for the three remaining varieties and keep it separate? It just seems so redundant to me when they should all be in the same HACCP plan. I have read as much as I can of USDA's Regulations and through previous forums and cannot find the answer to this. 

 

On a slightly similar note, we receive frozen cookie pucks and repackage them into smaller packages as well. I would like this in our SQF scope too, so I would need to include this in HACCP. I am imagining this will have to be its own HACCP plan?

 

Thanks for the help.

Hi Rick,

 

So what was the USDA inspector's objection ?

 

IMEX different input hazards demand separate haccp plans. I'm a little surprised that the subsequent processes are apparently identical.? (and similar thought to presence of raw versus cooked meat).

 

Is a frozen cookie puck[?] only eaten by hockey players ?

[kingstudruler1]

I dont see why you couldnt have all pizzas meat and free on the same haccp plan.  

 

Do you get to ignore any risks associated with the non meat pizzas?    it seams to me like you would want to include have them together to address possible risks from the different pizza varieties/ingredients.   (how do you address an allergen in a haccp plan if the ingredient / product isnt in the plan.?)   

 

if that's the rule, its seems weird to me.   

[Charles.C]

Hi Rick,

 

I will revise my previous opinion.

 

I recall some haccp plans for school meals having multiply varied ingredient mixes are USDA documented as acceptably groupable under a common haccp plan based on their sharing  common criteria - Same CCP(s)/basic flow.path, More specifically, IIRC, sharing same 1 or in some cases 2 CCPs,

( USDA document is previously posted on this Forum).

 

The USDA haccp plan essentially consisted of a core process flow + an enormous list of product types (= a menu).

 

I could anticipate that, strictly, there might be some complexities involved in presenting/formatting the typically required auditorial list of potential, raw material, hazards but I daresay you have already solved this aspect in respect to the existing meat/non-meat variations.

[kfromNE]

A concern for me - the FDA plans. We make twice baked potatoes that fall under USDA and FDA. Our FDA plans are required to be more extensive per FSMA. That's why we separated them even though the only difference is that bacon bits are added to one of the products. Especially the ingredient hazard analysis portion - FSMA is way more extensive in it's requirements than USDA.

[Rick Schaper]

I've had some conversations with my USDA inspector.

 

To preamble, we make (almost) all hand-made pizzas so when it comes to production of the pizza, the processes are the same no matter what toppings go on the pizza. The only automation we currently have is a sauce and cheese applicator, all other toppings are put on by hand. We get our vegetables in already cut (except basil and mushrooms) so our prep activities are fairly limited when it comes to non-meat. We do cook our own chicken, which is one of our CCPs, other than that the only meat we prep is shredding pre-cooked bacon.

 

Our inspector is saying that we CAN have it all in one if we want. He has some arguments as to why it shouldn't all be in one. For one, he says HACCP is gears towards meat specifically and having non-meat products and processes would be useless under the HACCP system.

 

He also says that if we have non-meat products or processes in our HACCP Plan, even if it is denoted when/where products or processes are USDA inspected, that he could write us up under FSIS if anything in the entire HACCP is done wrong, even if it is as simple as fluffing the cheese wrong. In my opinion, if I have both in the HACCP and denote what is USDA inspected and what isn't, then they should have no jurisdiction to write us up on any of that other stuff.

 

He suggests having a HARPC plan that would cover ALL pizzas until any topping would be put on, and I could then divert those pizzas that would be getting meat toppings to the HACCP plan while keeping the non-meat pizzas under HARPC. It would also cover any other non-meat processes.

 

As of right now, we only have the one HACCP plan, so our three non-meat varieties are not under any food safety plan. We had an FDA inspection just over a month ago and he never said anything about requiring a HARPC per FSMA, he suggested including the three non-meat products in the current HACCP like I suggested.

 

In summary, all of our processes are the same for production, so I think they should all be in the same plan. There are not any risks when switching from FDA to USDA products or vice versa because of our sanitation practices. When it comes to allergens, we have four on pizzas, three of which are on every single pizza (wheat, milk, and soy in crust and cheese), and one of our pizzas has egg in the sauce. 

 

What would you all suggest? Should I try to combine everything into our current HACCP or make a HARPC to keep it all separate?

 

Thanks for the help everybody.

[Charles.C]

I've had some conversations with my USDA inspector.

 

To preamble, we make (almost) all hand-made pizzas so when it comes to production of the pizza, the processes are the same no matter what toppings go on the pizza. The only automation we currently have is a sauce and cheese applicator, all other toppings are put on by hand. We get our vegetables in already cut (except basil and mushrooms) so our prep activities are fairly limited when it comes to non-meat. We do cook our own chicken, which is one of our CCPs, other than that the only meat we prep is shredding pre-cooked bacon.

 

Our inspector is saying that we CAN have it all in one if we want. He has some arguments as to why it shouldn't all be in one. For one, he says HACCP is gears towards meat specifically and having non-meat products and processes would be useless under the HACCP system.

 

He also says that if we have non-meat products or processes in our HACCP Plan, even if it is denoted when/where products or processes are USDA inspected, that he could write us up under FSIS if anything in the entire HACCP is done wrong, even if it is as simple as fluffing the cheese wrong. In my opinion, if I have both in the HACCP and denote what is USDA inspected and what isn't, then they should have no jurisdiction to write us up on any of that other stuff.

 

He suggests having a HARPC plan that would cover ALL pizzas until any topping would be put on, and I could then divert those pizzas that would be getting meat toppings to the HACCP plan while keeping the non-meat pizzas under HARPC. It would also cover any other non-meat processes.

 

As of right now, we only have the one HACCP plan, so our three non-meat varieties are not under any food safety plan. We had an FDA inspection just over a month ago and he never said anything about requiring a HARPC per FSMA, he suggested including the three non-meat products in the current HACCP like I suggested.

 

In summary, all of our processes are the same for production, so I think they should all be in the same plan. There are not any risks when switching from FDA to USDA products or vice versa because of our sanitation practices. When it comes to allergens, we have four on pizzas, three of which are on every single pizza (wheat, milk, and soy in crust and cheese), and one of our pizzas has egg in the sauce. 

 

What would you all suggest? Should I try to combine everything into our current HACCP or make a HARPC to keep it all separate?

 

Thanks for the help everybody.

 

Hi Rick,

 

Seems to me yr OP has expanded somewhat .

 

I don't quite understand why FDA never required you to present a formal haccp-HARPC plan for the 3 non-meat pizzas.

 

I’m not in USA however some older, traditional Codex -type haccp threads here discuss processes  which were intimate mixtures of FDA/USDA jurisdictions and their resolution could sometimes get logic-messy. Now you have FSMA specialties added in. The all-in-one suggestion you quote from the USDA inspector seems scope-debatable to me, I'm a bit surprised if acceptable to both USDA and FDA although pragmatism has maybe forced a compromise on them.

 

I may be wrong but I doubt whether SQF care too much about the above intricacies since, afaik, SQF should accept a unified Codex haccp scheme something like I described in Post 5 although the front-end cooking line designated for producing RTE  meat may complicate the issue unless any potential CCP, eg cooking, is "haccp-neutralized” by the subsequent pizza process.

 

Seems to me you are minimally facing 2 haccp manuals ?. Three volumes maybe easier to audit handle but not documentation-friendly if shared stuff, eg PRPs, is apt to change a lot. (IIRC PRPs in HARPC are not 100% mirrored from Codex). Unless you have software options.

 

Ultimately you are surely initially limited to options which are Regulatory acceptable, ie USDA/FDA. SQF comes in third.

 

I anticipate there must be other US members here who have encountered analogous bi-jurisdictions under SQF ??

[kingstudruler1]

HACCP is useless for non meat? - what a tool...

 

I don't think I have grasp on his adversion to one plan and desire to make things difficult for you.   For that reason only, I would say have a HACCP plan for the meat and a preventive control plan for meatless pies.   I guess you could have a preventive control plan for everything until the meat is added and then separate as he suggested.  do which every you this is less of a hassle.