Three audit NCNs due to the risk assessment

Hi All,

I just came out from our Audit today. We have three NCNs due to the risk assessment.
The haccp team leader left the business few weeks back and now I have to deputise in his absence.

One floe diagram with all process steps, the auditor challenge the fact that the risk assessment was just for few process and didn't include others thT according to him should be consider. On his view every step of the flow diagram must be risk assessed. I disagree as I believe the risk assessment should include only the critical steps for your process.

I would like to know your opinion on this.

...On his view every step of the flow diagram must be risk assessed. ...

 

He's right.

 

 

ETA:   the conclusion may be that there is no risk for one or more steps, but the assessment must be done for the entire process.

You should determine your critical steps based on risk assessment, not the other way around. How do you know that the unassessed steps pose little or no risk without performing an assessment? HACCP usually starts by looking at each and every step in your process and determining the hazards present. You also need to look at the hazards introduced by your ingredients. It simply doesn't work if it's not a comprehensive process.

Hello, 

 

Risk assessment should be conducted on all process steps regardless of wether you believe they are a risk or not. If it is not a risk after being assessed then you add that to the assessment with evidence. Rather be safe than sorry and it also eliminates that the auditor will challenge you.

Hi All,

I just came out from our Audit today. We have three NCNs due to the risk assessment.
The haccp team leader left the business few weeks back and now I have to deputise in his absence.

One floe diagram with all process steps, the auditor challenge the fact that the risk assessment was just for few process and didn't include others thT according to him should be consider. On his view every step of the flow diagram must be risk assessed. I disagree as I believe the risk assessment should include only the critical steps for your process.

I would like to know your opinion on this.

 

Hi NewQA,

 

This is combination of two clauses in the BRCGS standard, you are required to identify and record all the potential hazards that are reasonably expected to occur at each step and then assess those hazards. So, your Auditor is correct. I have quoted the relevant requirements From BRCGS Global Standard for Food Safety Issue 9 below.

 

Section 2.7 List all potential hazards associated with each process step, conduct a hazard analysis and consider any measures to control identified hazards (equivalent to Codex Alimentarius Step 6, Principle 1)

Clause 2.7.1:

The HACCP food safety team shall identify and record all the potential hazards that are reasonably expected to occur at each step in relation to product, process and facilities.

Clause 2.7.2:

The HACCP food safety team shall conduct a hazard analysis to identify the significant hazards (i.e. those hazards that are reasonably likely to occur at an unacceptable level), which need to be prevented, eliminated or reduced to acceptable levels. Consideration shall be given to the following: …. etc.

 

From BRCGS Global Standard for Food Safety Issue 9 Clause 2.7.1 Guidance:

Any hazards identified in clause 2.7.1 must be evaluated against the criteria detailed in this clause to identify those which are significant.

 

Kind regards,

 

Tony

Hi NEWQA,

 

As per Post 5, I deduce you are basically referring to a Hazard Analysis.

 

If you look up any published HACCP Plan I think you will see that every Hazard Analysis is performed the same way, Step-by-Step.

Critical steps are determined by risk assessment. Let's take an imaginary apple juice with the following flow of activities or steps: 

1. Receiving of raw material
2. Washing 
3. Crashing
4. Pressing
5. Juice filtration 
6. Pasteurization 
7. Bulk package 
8. Cold Storage 
9. Completing individual orders from customers (e.g., packaging based on client demand)

Now, find physical, biological and chemical hazards in every step.

Then conduct a risk assessment: Risk is calculated as follow: Risk =  likelihood of a hazard to happen x potential impact of that hazard. 

Now, you find if your risk is tolerable or not. 

 

Then, you determine if the risk is tolerable, you consider it not Critical, if not then a risk is to be considered critical. You can also use the Codex 4 questions to find if a hazard is critical or not. 

Now, find physical, biological and chemical hazards in every step.

Then conduct a risk assessment: Risk is calculated as follow: Risk =  likelihood of a hazard to happen x potential impact of that hazard. 

Now, you find if your risk is tolerable or not. 

 

Hi Sayed M Naim Khalid,

 

The BRCGS Global Standard for Food Safety Issue 9 standards specifies more than likelihood and severity in clause 2.7.2:

Consideration shall be given to the following:

• likely occurrence of hazard

• severity of the effects on consumer safety

• vulnerability of those exposed

• survival and multiplication of micro-organisms of specific concern to the product

• presence or production of toxins, chemicals or foreign bodies

• contamination of raw materials, intermediate/semi-processed product, or finished product.

 

Kind regards,

 

Tony

Thanks all for your recommendations and valuable points. I think at this point the best thing I can do is re-do the risk assessment and include all what we have got in the process.