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Considering Allergens in HACCP

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Miss Frankie

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Posted 27 January 2022 - 07:21 PM

I'm updating our HACCP plan and notice a LOT of areas that could probably be condensed.

 

For one step, for potential hazard, the hazard of concern is Allergenic Materials, with the source of hazard listed.

Then, the next step says the hazard of concern is Undeclared Allergens, with the source of hazard listed.  The severity of hazard is both.

Is there any reason I can put "Allergenic materials/Undeclared allergens, and list both sources of hazard?

 

This is done many times throughout the HACCP plan. 

 

I could potentially shorten the plan by several pages by combining these. 

 

*I've only been with this company 2 months and am in the process of moving the HACCP plan from PDF supplied by a software firm, to excel so we no longer need to pay for software.



Scampi

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Posted 27 January 2022 - 07:23 PM

are you talking in the hazard analysis portion of your HACCP Plan???

 

Could you possibly share a snip of the document in question because we can't answer that out of context


Please stop referring to me as Sir/sirs


Miss Frankie

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Posted 27 January 2022 - 07:41 PM

are you talking in the hazard analysis portion of your HACCP Plan???

 

Could you possibly share a snip of the document in question because we can't answer that out of context

Yes, the Process Steps of the Hazard Analysis Portion.

 

 

I haven't gotten far enough to share anything yet.  Just reading thru it and noticed a lot of redundancy.  I can't copy off the PDF file.



Charles.C

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Posted 27 January 2022 - 07:42 PM

I'm updating our HACCP plan and notice a LOT of areas that could probably be condensed.

 

For one step, for potential hazard, the hazard of concern is Allergenic Materials, with the source of hazard listed.

Then, the next step says the hazard of concern is Undeclared Allergens, with the source of hazard listed.  The severity of hazard is both.

Is there any reason I can put "Allergenic materials/Undeclared allergens, and list both sources of hazard?

 

This is done many times throughout the HACCP plan. 

 

I could potentially shorten the plan by several pages by combining these. 

 

*I've only been with this company 2 months and am in the process of moving the HACCP plan from PDF supplied by a software firm, to excel so we no longer need to pay for software.

The usual solution to (simple) allergen problems is to define as handled within Allergen PRP Control program. Abracadabara !

 

(If a specific hazard automatically/obviously  repeats in successive process steps, can either assume to still exist or simply insert  a code/xref )

 

For example if a raw material potentially brings in Salmonella, need to specify at the beginning of a chain of steps. After the first one it can be assumed as "present". On the other hand, if one step maybe increases the temperature,need to consider the Salmonella potential for growth.


Edited by Charles.C, 27 January 2022 - 08:00 PM.
added

Kind Regards,

 

Charles.C


Miss Frankie

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Posted 27 January 2022 - 09:15 PM

Not sure if this will paste correctly or not...
So this is the same process step, Potential Hazard Identified. With 3 different chemical hazards listed.  I want to combine the 3, just clean things up a bit.

C: Introduction of Chemical Hazards                                Intentional Adulteration                                                      Hazard of Concern                                                                        Non-food-grade Chemicals                                            Undeclared allergens                                                                    Sources of Hazard                                                                   Malicious introduction of adulterant by employees                                                                               

 Severity of Hazard                                                                Likelihood: 2 - Possible                                                   Severity: 4 - Severe                                                                   Risk: 8 - High

C: Introduction of Chemical Hazards                             Contaminated Equipment                                                 Hazard of Concern                                                                          Allergenic Materials                                                                                 Sources of Hazard                                                             Improperly cleaned equipment could be a potential source of contamination at this step.                                                          Severity of Hazard                                                                        Likelihood: 2 - Possible                                                     Severity: 4 - Severe                                                                 Risk: 8 - High C: Introduction of Chemical Hazards                                        Poor Employee Hygiene                                                       Hazard of Concern                                                           Undeclared allergens                                                          Source of Hazard                                                       Contaminated hands, gowns and gloves could be a source of contamination at this step.                                                          Severity of Hazard                                                                       Likelihood: 2 - Possible                                                               Severity: 4-Severe                                                                                         Risk: 8 - High


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Posted 27 January 2022 - 09:18 PM

Got it

 

I would condense into one chemical hazard, and split that into the mitigation strategies that work for each

 

Also, that looks like just a risk analysis to me---------- where's the hazard analysis-----are undeclared allergens actually likely to occur? 

 

usually (imexp) 3rd party written programs miss obvious things, and invent others

 

and non food chemicals should be under receiving, you need an approved supplier program and you shouldn't be using any chemicals with known allergies in them in the food plant unless you CANNOT find others


Edited by Scampi, 27 January 2022 - 09:25 PM.

Please stop referring to me as Sir/sirs


Charles.C

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Posted 27 January 2022 - 09:47 PM

Hi Frankie,

 

Unfortunately it's not possible to paste tables into forum posts. It's a mess.

 

As per previous post, it's not too obvious what the Primary objective is.

 

Looks like a mix of Food Defense + GMP + a Risk Analysis

 

What Standard are you trying to comply to ? What kind of Product ?


Kind Regards,

 

Charles.C


Miss Frankie

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Posted 27 January 2022 - 10:09 PM

The company doesn't like to give too much information out. But we make fake crab using surimi paste.

 

I totally agree about the 3rd party.  Our president was THRILLED when she learned that I had never used a HACCP software before.  I guess when they started their HACCP program nobody really knew how to do it, so they went the 3rd party route and has stuck with that for many years. 

 

We do have an approved supplier program.  We're SQF Certified, scored 100% last fall, before I stared (I have NO idea how that happened!)

 

I want to get it all sorted out before our USDC audit next week. Luckily, I have worked with the auditor for several years and he knows I just started here.   

He will cut us some slack, and I'll ask him more questions about revisions.  He knows I'll get it done once I understand what he wants.



Charles.C

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Posted 27 January 2022 - 10:51 PM

The company doesn't like to give too much information out. But we make fake crab using surimi paste.

 

I totally agree about the 3rd party.  Our president was THRILLED when she learned that I had never used a HACCP software before.  I guess when they started their HACCP program nobody really knew how to do it, so they went the 3rd party route and has stuck with that for many years. 

 

We do have an approved supplier program.  We're SQF Certified, scored 100% last fall, before I stared (I have NO idea how that happened!)

 

I want to get it all sorted out before our USDC audit next week. Luckily, I have worked with the auditor for several years and he knows I just started here.   

He will cut us some slack, and I'll ask him more questions about revisions.  He knows I'll get it done once I understand what he wants.

Hi Frankie,

 

Thanks for the info.

I'm more familiar with BRC but there are many users of SQF on this Forum who can advise.

Which SQF Clause(s) is yr posted content responding to ?

 

If you have the table you previously pasted in a word/excel/pdf/png file, any of these can be easily uploaded to yr post by clicking the "more reply options" box (bottom right) which will open a new page with simple instructions to allow you to select the file on yr PC and then upload it.


Kind Regards,

 

Charles.C




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