16 replies to this topic

[kgalb]

Hello,

 

We produce two kinds of product - one that we cook, and one that is sold raw (frozen) for consumers to cook. Is it acceptable to have them on the same HACCP plan even though they have different intended uses? They use the same processing steps and we monitor them in the same way (except for not monitoring the cooking and cooling of the raw product).

 

Thanks!

[Tony-C]

Hi kgalb,

 

As one is cooked and the other raw and for consumers to cook they are not going to have the same HACCP plan.

 

Cooked chicken is regarded a high-risk product and raw chicken which will be cooked by the consumer is regarded as a low-risk product.

 

Some parts may be the same such as supplier assurance, goods in, goods in checks, initial storage etc.

 

Kind regards,

 

Tony

[Scampi]

is your process continuous when preparing the cooked?  Does it flow directly from the raw side ?   

[kgalb]

Hi Scampi,

 

Raw and cooked product are prepared on different days, but in terms of process flow, cooked product does flow directly from the raw side.

[Scampi]

Then you have one single HACCP plan and the differences will be explained through your flow chart where you show raw product going to packaging and then storage and another arrow from raw through to your cooked process

 

I would not separate into two--even an interruption in the flow can be demonstrated through the flow chart

[Charles.C]

Then you have one single HACCP plan and the differences will be explained through your flow chart where you show raw product going to packaging and then storage and another arrow from raw through to your cooked process

 

I would not separate into two--even an interruption in the flow can be demonstrated through the flow chart

 

Hi Scampi,

 

I agree with Tony on this one.

Two fundamentally risk different end products/processes should = 2 HACCP Plans.

 

Can you provide a link to an example of such a combined raw finished +  cooked finished / single Plan, I cannot remember ever seeing one.

[Scampi]

Every meat plant I've ever worked in Charles

 

One single HACCP plan as it is a continuous flow

 

Slaughter all the way to cooked in one building across two shift (slaughter am, FP both)

 

Meat went from chill tanks into totes and then into dumpers OR into cases/MAP for retail-pack case-palletize- cooler-ship

 

Minced-mixed -formed-breaded-cooked- blast frozen-boxed- palletize- ship

 

One HACCP plan

 

Why should risk dictate the number of HACCP plans???  In a well laid out facility the raw entering the cooked side is one way traffic only and separate staff with separate facilities 

 

Risk is ALWAYS mitigated by CCP and PRP and/or regulatory requirements   I don't follow the logic here

Edited by Scampi, 13 September 2022 - 12:38 PM.

[Charles.C]

Every meat plant I've ever worked in Charles

 

One single HACCP plan as it is a continuous flow

 

Slaughter all the way to cooked in one building across two shift (slaughter am, FP both)

 

Meat went from chill tanks into totes and then into dumpers OR into cases/MAP for retail-pack case-palletize- cooler-ship

 

Minced-mixed -formed-breaded-cooked- blast frozen-boxed- palletize- ship

 

One HACCP plan

 

Why should risk dictate the number of HACCP plans???  In a well laid out facility the raw entering the cooked side is one way traffic only and separate staff with separate facilities 

 

Risk is ALWAYS mitigated by CCP and PRP and/or regulatory requirements   I don't follow the logic here

Hi Scampi,

 

From a Finished Product POV there are 2 Processes in the OP.

If the Risks in the 2 Processes are equivalent I agree one could consider formulating a Unified Plan. But the risks (eg CCPs) are surely not the same in this case ?

 

For example -

 

 Number of HACCP Plans.PNG   28.97KB   16 downloads

https://www.ag.ndsu....view/introhaccp

[Kara S.]

Every meat plant I've ever worked in Charles

 

One single HACCP plan as it is a continuous flow

 

Slaughter all the way to cooked in one building across two shift (slaughter am, FP both)

 

Meat went from chill tanks into totes and then into dumpers OR into cases/MAP for retail-pack case-palletize- cooler-ship

 

Minced-mixed -formed-breaded-cooked- blast frozen-boxed- palletize- ship

 

One HACCP plan

 

Why should risk dictate the number of HACCP plans???  In a well laid out facility the raw entering the cooked side is one way traffic only and separate staff with separate facilities 

 

Risk is ALWAYS mitigated by CCP and PRP and/or regulatory requirements   I don't follow the logic here

 

 

Hi Scampi,

 

From a Finished Product POV there are 2 Processes in the OP.

If the Risks in the 2 Processes are equivalent I agree one could consider formulating a Unified Plan. But the risks (eg CCPs) are surely not the same in this case ?

 

For example -

 

Number of HACCP Plans.PNG

https://www.ag.ndsu....view/introhaccp

 

 

I'm with Scampi on this. This can be in the same plan. There should be 2 different product descriptions but 1 flow diagram and a hazard analysis makes the most sense to me. 

 

From what it sounds like - first steps are the same up until the cook step - why duplicate that to a different document? Just create a new path on the flow diagram where the processes divert and include any difference in the hazard analysis - like if the packaging equipment is drastically different, you would have to have a "Packaging Raw" and "Packaging RTE" in the hazard analysis. If the raw products are packaged on the same lines as RTE then there will need to be biological hazards that need to be taken into consideration and a sanitation CCP/ preventive control. 

[Scampi]

Hi Scampi,

 

From a Finished Product POV there are 2 Processes in the OP.

If the Risks in the 2 Processes are equivalent I agree one could consider formulating a Unified Plan. But the risks (eg CCPs) are surely not the same in this case ?

 

For example -

 

Number of HACCP Plans.PNG

https://www.ag.ndsu....view/introhaccp

 

 

Of course the risks are not the same......but that doesn't mean 2 separate plans??   

 

Perhaps it's just me being in Canada----- we have had a very robust FSEP (food safety enhancement plan) program that every MEAT plant HAD to follow where the actual HACCP plan was heavily audited by CFIA  so the issue of level of risk to me is almost inconsequential when developing a plan

 

 

A properly developed plan where a through risk analysis is done STEP BY STEP is by design supposed to dictate risk mitigation

[Scotty_SQF]

I worked in a plant with a similar situation.  We had one HACCP Plan for both and they branched off (different paths) where they differed.  It was always fine with FDA, USDA and our SQF audits.  

[Charles.C]

I worked in a plant with a similar situation.  We had one HACCP Plan for both and they branched off (different paths) where they differed.  It was always fine with FDA, USDA and our SQF audits.  

Hi Scotty,

 

I speculate that haccp audit zigzags/compromises are occurring in the "Corridors of Power".

 

For example, can compare to "official" examples like USDA's quite recent updating of their collection of HACCP Plans. All such overtly Raw/RTE systems have divided HACCP Plans afaik.

 

I wonder if it may depend on the precise style of documentation, eg it is claimable that 2 HACCP Plans do exist despite only one overall Heading. This is illustrated in following (a) text extract and (b) diagrammatic example (Note the varied terminologies) -

(a)

Modular approach
A modular approach is often used where there are multiple paths for components of the finished product through the factory. For example, there may be three or four mixing and blending processes for raw ingredients, several main processes involving cooking or kill steps, and three or four different ways to assemble and pack the finished product. If a linear approach was used there would be a large number of individual HACCP plans.
By using the modular method, each sub-process becomes a mini HACCP plan; each is linked to any relevant module before or after it to make the finished product. The danger with this approach is that transfer stages between modules can be missed.

 HACCP implementation.pdf   46.18KB   36 downloads

(b)

 Linear and Modular HACCP Plan.pdf   49.79KB   56 downloads

 

I  repeat my earlier query. Please provide an authorized link/example. Or any accessible reference for that matter.

 

@Scampi - it is true that FSEP may have defined their own version of HACCP ( cf Codex, ISO). Do they offer any documented examples of "combined" HACCP Plans ?

 

Just for interest BRC8 states - FUNDAMENTAL - The company shall have a fully implemented and effective food safety plan incorporating the Codex Alimentarius HACCP principles.

 

Similarly SQF9 states  Food Safety Plan (Mandatory) - 2.4.3.1    A food safety plan shall be prepared in accordance with the twelve steps identified in the Codex Alimentarius Commission HACCP guidelines.

 

However (perhaps intentionally) Codex afaik present zero actual examples of "compliant" HACCP Plans thereby not excluding further "interpretation".

Edited by Charles.C, 14 September 2022 - 11:10 PM.
added

[Scotty_SQF]

You may be right that it depended on the style of my documentation.  I haven't worked for that company for several years, so am unable to provide what it looked like.  I just wanted to share my experience with what he had and done and didn't have any issues.  USDA always liked the plan as it was, had several FDA inspections, and the never mentioned anything, and several SQF audits, no hits on the HACCP Plan.  I believe a well documented HACCP plan that shows your products and flow is all you need.  In fact I get frustrated when during an audit an auditor questions a minute detail in the HACCP plan as they do not know our process and flow and then want  to make off the cuff recommendations.  As an auditor you are supposed to be checking that everything was covered and risk is properly mitigated.  I guess it all depends on how you want to build your HACCP Plan based on what regulation you follow and certification you want to attain.  And in turn you have to make sure everything is covered.

 

Again, just spoke from experience in regards to the question posted that it is acceptable to have one that encompasses both, if you document it correctly.

[Scampi]

here is a link to the FSEP manual

https://inspection.c...7674768_eng.pdf

 

It is a codex system where all 12 steps must be accounted for

 

Charles, I would attach the plan but I am no longer working there

 

As traditional Codex requires you to address each processing step for risks (including inbound, outbound, transfer, temporary storage, chill etc) i see no reason not to use a single combined plan. I stand behind my statement

 

As for the USDA not listing any on the site, combined plants are relatively new.  Slaughter houses are the most expensive part of the build, so FP plants were built and the raw materials were shipped there

 

Now, with the rising costs of transportation, new plants are being built where all stages are under one roof

 

Cargill in Ontario Canada-one HACCP plan

 

Sofina Foods in Ontario, one HACCP plan

 

Maple leaf foods is building the largest poultry facility that will be one of the, if not the, largest plants in the world

https://lfpress.com/...2m-london-plant

 

I worked at the first two, so I know for certain what happened inside, I also know that they were 1 HACCP plan as there was only interim storage between them.  Both facilities were FSEP, both facilities were 3rd party certified.  One of those 2 plants processed products for one of the largest restaurant companies in the world, who themselves has one of the strictest auditing procedures out there (IMHO)

[Miss Frankie]

We have 1 HACCP plan and 1 flow chart that encompasses everything we do. 

Our base product and basic process is the same, but we end up with different end products.

Each step of our flow chart is numbered, then I have a list of each product and what numbers it uses in the flow chart.

Each type of CCP is a different color (chemical, physical, etc), to make it easy to spot.

Our USDC auditor hated our previous flow chart, but loves the new one. He raves about it at every audit.

[Charles.C]

We have 1 HACCP plan and 1 flow chart that encompasses everything we do. 

Our base product and basic process is the same, but we end up with different end products.

Each step of our flow chart is numbered, then I have a list of each product and what numbers it uses in the flow chart.

Each type of CCP is a different color (chemical, physical, etc), to make it easy to spot.

Our USDC auditor hated our previous flow chart, but loves the new one. He raves about it at every audit.

Hi Miss Frankie,

 

Thks yr input.

 

I do recall the intricate process web you posted previously. I predict yr auditor is also an expert crosssword solver.

I will assume, just for illustration, that yr starting material is "raw".

I anticipate that some of the initial (raw) process stages on yr flowchart, say X,Y,Z,  occur jointly in multiple processes for different end products.

I also speculate, as per the OP, that one or more of such XYZ may occur in (a) a process with a raw, ie NRTE, finished product and (b) a process with a RTE product.

If so any pathogen risk assessment, eg Salmonella, at such a "common" Stage will presumably involve two (different) risk justifications. I cannot readily envisage, other than by some tabular convolutions, the avoidance of presenting at least  2 separate hazard analyses at such locations, ie two haccp "plans". A similar but amplified hazard analysis conundrum will also occur if any common stage is a CCP and non-CCP depending on the process.

 

I hypothesize that yr documentation (and that in Post 14) are effectively  modular HACCP Plans as described in Post 12. Unfortunately published, haccp-analysed, examples of this type are, afaik, rare.

 

PS - IMEX there is a customary HACCP Plan / hazard analysis requirement of an introductory Product sheet summarising elements such as the process characteristics/handling/storage/shelf life/consumer for the included finished Products.. Combining the, I anticipate, somewhat divergent data for RTE/NRTE finished products into one sheet/Table while retaining clarity seems a formidable challenge. I wonder how you do it ? Or perhaps all your finished products are RTE ?

 

PPS - Ultimately this discussion may simply be a question as to what, terminologically, defines a "HACCP Plan".

For example the attachments in Post 12 describing  Modular HACCP Plans refer to the individual component chunks as mini-HACCP plans and HACCP Studies respectively.

 

ie "Much Ado about Nothing" ? !

Edited by Charles.C, 15 September 2022 - 11:10 PM.
added PS, PPS

[Charles.C]

Hello,

 

We produce two kinds of product - one that we cook, and one that is sold raw (frozen) for consumers to cook. Is it acceptable to have them on the same HACCP plan even though they have different intended uses? They use the same processing steps and we monitor them in the same way (except for not monitoring the cooking and cooling of the raw product).

 

Thanks!

Hi kgalb,

 

I apologize for missing yr comment in the OP that both declared RTE/NRTE products received identical, cooked processing.

 

I can recall a few analogous previous threads here where a processed, fully cooked item was labelled as "raw" but this, predictably, generated some awkward audit HACCP/hazard analysis queries. IIRC, an effective solution/response was not achieved for the previous cases.

 

JFI, in the context of recent, previous Posts in this thread, I was able to find a published  Modular Process approach for one Product where  judicious numbering enabled the final presentation of a readily intelligible, single, integrated hazard analysis.  But I was unable to find any equivalent published examples where  RTE/NRTE products with different processes/CCPs occurred. Accordingly, afaik this latter situation is as per the reference in Post 12 to multiple mini-haccp plans. Contrarial refs are of course Welcome.

 

Above does not of course preclude the overall Study being titled as a "Complete" HACCP Plan".

 

PS - FWIW I also found this quote -

15. Different (Modular) HACCP plans. Often, due to the complexity of the production, it is easier to develop different HACCP plans for different parts of the production. This is usually known as Modular HACCP plans as the process is split into “process modules” and HACCP principles are applied to each one. It is important to ensure that a proper link between the different HACCP plans exists and that errors do not occur as a result of this practice, e.g. skipping a step, omitting certain hazards.

 HACCP Misconceptions.pdf   712.19KB   29 downloads