5 replies to this topic

[YNA QA]

During our most recent SQF audit, my auditor asked for my HACCP plan.  I asked if he would also want to see the Food Safety plan just to verify, he was astonished I still kept up with both.  He said that everyone is essentially moving to one plan.

 

I noted that I went through PCQI training at the advent of HARP-C and back then it was strictly 2 plans and that because having two plans functioned just fine for now, I didn't see an issue in carrying this forward.

 

Am I just delaying what is an easy process? Has anyone else combined their plans? If so- can I get some guidance on how you've done so?

 

Thanks!!

[olenazh]

HACCP plan(s) is a part of your FSMS - and you can have as many plans as you need. Don't worry about an auditor being "astonished" - that is just lack of professionalism:) Your food safety management system and HACCP plans are your, and only your, business, as soon as they fully ensure your product quality, safety and legality.

[Scampi]

Your food safety management plan, you manage it as you see fit. Period

 

Having said that--when I started here they had 2 separate files AND binders to appease CFIA and SQF......................we now have one because I refuse to double the work

 

As long as you have a program that works, is well understood and implemented, the how is irrelevant 

[Charles.C]

hi YNA,

 

Not in USA but I assume an SQF auditor is not obliged to be interested in  HARPC-compliant content  if different to SQF.

 

I imagine that a caveat might occur if, for a combination option, an auditor is unable to (readily?) find the content which corresponds to their Standard.

 

For example, I would anticipate that a combined HACCP Plan for BRC/SQF could be an auditor's nightmare. (For starters, 2 different interpretations of Validation seem a likely possibility).

 

IIRC, BRC do offer a detailed "illustration" of how/where their HACCP Plan requirements can also comply to those of FSMA, ie HARPC.

[Tony-C]

Hi YNA QA,

 

I am somewhat surprised that an SQF Auditor asked for a HACCP Plan when the SQF Code predominantly refers to Food Safety Plans

 

Some background to this topic for perspective:

 

The SQF Food Safety Code: Food Manufacturing – System Elements requires compliance with food safety regulations and Codex Alimentarius Commission HACCP guidelines:

2.4.3.17 Where food safety regulations in the country of production and destination (if known) prescribe a food safety control methodology other than the Codex Alimentarius Commission HACCP guidelines, the food safety team shall implement food safety plans that meet both Codex and food regulatory requirements.

 

SQF Definition of Food Safety Plan: As described in the SQF Food Safety Codes, a prepared plan based on the CODEX HACCP method that includes process controls at control points in production to monitor product safety, identify deviations from control parameters and define corrections necessary to keep the process under control.

 

For organizations where FSMA is applicable:

 

PART 117—CURRENT GOOD MANUFACTURING PRACTICE, HAZARD ANALYSIS, AND RISK-BASED PREVENTIVE CONTROLS FOR HUMAN FOOD

§117.126   Food safety plan.

(b) Contents of a food safety plan. The written food safety plan must include:

(1) The written hazard analysis as required by §117.130(a)(2);

(2) The written preventive controls as required by §117.135(b);

(3) The written supply-chain program as required by subpart G of this part;

(4) The written recall plan as required by §117.139(a); and

(5) The written procedures for monitoring the implementation of the preventive controls as required by §117.145(a)(1);

(6) The written corrective action procedures as required by §117.150(a)(1); and

(7) The written verification procedures as required by §117.165(b).

 

SQF Definition of HACCP Plan: A document prepared in accordance with the CODEX HACCP method to ensure control of hazards which are significant for food safety or the identification of quality threats for the product under consideration.

 

I don’t see why anyone would have a separate HACCP Plan when clearly all the requirements can be included in a Food Safety Plan.

 

Kind regards,

 

Tony

[sqflady]

It is not difficult to combine your HACCP and Food Safety Plans.  You need to add your preventive controls but the remainder of the plan is basically the same.