11 replies to this topic

[lucho]

The template I have for 2.4.7 is a bit more robust than what we actually do as far as product release.   We really do not have an official product release program in place.   Our HACCP plan is our actual product release program.  If any of the lots do not meet the critical control points, it does not get released.  Product is rejected and returned to the supplier.   Would it be ok to write up 2.4.7 with the aforementioned HACCP critical point criteria?   We do not do any laboratory testing.  

Edited by lucho, 19 January 2024 - 03:53 PM.

[jfrey123]

You can release based on your HACCP and whatever other PRP's you deem necessary, but the release criteria needs to be defined in the product release SOP and you need to have some verification step (some sign off that all the release requirements were reviewed before release).

 

One of the last times I was involved in this was at a spice plant as a consultant.  All of their paperwork for a lot/order was mostly paper based, and would get turned into QA for final review.  We developed a paper form to staple to the top of the batch records showing all reviews had been checked, labels had been verified as correct, and no HACCP deviations were recorded.  QA would then sign off that the batch was good to release, mark it as such in their WMS, and off the order went.

[lucho]

You can release based on your HACCP and whatever other PRP's you deem necessary, but the release criteria needs to be defined in the product release SOP and you need to have some verification step (some sign off that all the release requirements were reviewed before release).

 

One of the last times I was involved in this was at a spice plant as a consultant.  All of their paperwork for a lot/order was mostly paper based, and would get turned into QA for final review.  We developed a paper form to staple to the top of the batch records showing all reviews had been checked, labels had been verified as correct, and no HACCP deviations were recorded.  QA would then sign off that the batch was good to release, mark it as such in their WMS, and off the order went.

 

In bold would be a tough task in our operation.  We receive and ship out product same day within 4-5 hours.  By the time qa/haccp paperwork would come across my desk, product is on its way to the customer.  

 

The last CCP we have before product leaves is a label check.  Perhaps on that label check log, we can make an addition for "product is acceptable, ok to release"?  

[Tony-C]

Hi Lucho,

If you don't want to gather all the paperwork and have someone check and then release, perhaps you could have a 'Product Release Log Sheet' that follows the product though the process and logs that the product has passed the necessary checks at each stage & signed by the person doing the checks and then after the label check the product gets a final sign off for release by a supervisor?

Kind regards,

Tony

[jfrey123]

The last CCP we have before product leaves is a label check. Perhaps on that label check log, we can make an addition for "product is acceptable, ok to release"?

Earlier you also mentioned that your HACCP program is your release program. So I don’t know whether basing release off the last CCP alone would be acceptable to your own program.

You can assign release authority to multiple people, and maybe they can keep a running release log where they show they’ve verified no problems with each lot code’s CCP records before signing the date and time it was ok to ship.

Based on shipping volume like what you described though, you’re going to need support from your production teams and shippers. If they’re used to slamming orders out at will, finding a proper sign off wherever it may be is going to annoy them. But it’s a good fs culture builder.

[Tony-C]

You can assign release authority to multiple people, and maybe they can keep a running release log where they show they’ve verified no problems with each lot code’s CCP records before signing the date and time it was ok to ship.

 

Strange 

 

I'm sure that is what I wrote in my post? 

 

Kind regards,

 

Tony

[MOHAMMED ZAMEERUDDIN]

The template I have for 2.4.7 is a bit more robust than what we actually do as far as product release.   We really do not have an official product release program in place.   Our HACCP plan is our actual product release program.  If any of the lots do not meet the critical control points, it does not get released.  Product is rejected and returned to the supplier.   Would it be ok to write up 2.4.7 with the aforementioned HACCP critical point criteria?   We do not do any laboratory testing.  

Kindly share the CCP details you decided. It will ease to respond your query.

[acarver]

We have a policy of passive or active release, depending on the situation. Most of our product would fall under passive release. Our policy states that product will be released if verifiers have signed off on appropriate records during production. Active release occurs when there has been a hold for any reason: micro testing, production or labeling error, etc.

 

We are a low-risk facility. We have not had any issues with the policy during audits.

[lucho]

Hi Lucho,

If you don't want to gather all the paperwork and have someone check and then release, perhaps you could have a 'Product Release Log Sheet' that follows the product though the process and logs that the product has passed the necessary checks at each stage & signed by the person doing the checks and then after the label check the product gets a final sign off for release by a supervisor?

Kind regards,

Tony

 

Thanks Tony.  Please let me know your thoughts.   I'm thinking of adding a "ok to release" column on our CCP monitoring forms.   The CCP receiving monitoring form is to evaluate time/temperature abuse.  If I add a column stating "Did time/temp. exceed the critical limits, if not, ok to release"    I'd also do that on the next CCP/form and so forth.  If any critical limits are exceeded product will be held, evaluated, destroyed or returned to supplier.   I see this as the only option so far to not hold up production.  

[Tony-C]

Thanks Tony.  Please let me know your thoughts.   I'm thinking of adding a "ok to release" column on our CCP monitoring forms.   The CCP receiving monitoring form is to evaluate time/temperature abuse.  If I add a column stating "Did time/temp. exceed the critical limits, if not, ok to release"    I'd also do that on the next CCP/form and so forth.  If any critical limits are exceeded product will be held, evaluated, destroyed or returned to supplier.   I see this as the only option so far to not hold up production.  

 

Hi Lucho,

 

I'm not sure how that works if there are separate sheets? For example at the first stage someone signs off 'okay to release' before the next CCP/form. This means it could be interpreted as 'okay to release' before all your checks are complete so could create confusion for the site and an auditor.

 

If you do have multiple sheets logging checks then my previous suggestion of a 'Product Release Log Sheet' that follows the product though the process and logs that the product has passed the necessary checks at each stage & signed by the person doing the checks and then after the label check the product gets a final sign off for release by a supervisor would seem to be the best option.

 

Other than that you could have all the paperwork follow the product and at the last stage have someone in authority check all the paperwork, sign all the sheets and have a sign off on the last (label) sheet that the product is 'okay to release'.

 

Kind regards,

 

Tony

[lucho]

Hi Lucho,

 

I'm not sure how that works if there are separate sheets? For example at the first stage someone signs off 'okay to release' before the next CCP/form. This means it could be interpreted as 'okay to release' before all your checks are complete so could create confusion for the site and an auditor.

 

If you do have multiple sheets logging checks then my previous suggestion of a 'Product Release Log Sheet' that follows the product though the process and logs that the product has passed the necessary checks at each stage & signed by the person doing the checks and then after the label check the product gets a final sign off for release by a supervisor would seem to be the best option.

 

Other than that you could have all the paperwork follow the product and at the last stage have someone in authority check all the paperwork, sign all the sheets and have a sign off on the last (label) sheet that the product is 'okay to release'.

 

Kind regards,

 

Tony

 

I was thinking along the lines that if a lot does not meet a CCP it immediately gets flagged and set aside.  Lots that do meet critical limits continues on with the process.  As you can see I'm trying to make this as easy as possible for production workers/monitors.  As you can imagine, constant pushback whenever I give them new logs to fill out.  

[jfrey123]

I was thinking along the lines that if a lot does not meet a CCP it immediately gets flagged and set aside.  Lots that do meet critical limits continues on with the process.  As you can see I'm trying to make this as easy as possible for production workers/monitors.  As you can imagine, constant pushback whenever I give them new logs to fill out.  

 

I see the logic there, basically saying if it's present at CCP2 it must've passed CCP1.  The simple pass off though still lacks a true verification step that all CCP's were acceptable.  How can you know for sure a product that failed or deviated at a CCP1 isn't going to pass down the line instead of going to hold?

 

It'll still come down to how you phrase your product release SOP:  if you state that product must pass all CCP's in your release program, you'll need some proof that you verified all CCP's were good for that batch prior to release.  Product release criteria are one of these places where I've seen companies get creative, and auditors are free to nitpick some of the criteria, but they have to have concrete proof of a risk to food safety to actually call it out as deficient.  If you come up with a program that works for your production crew and doesn't leave any blaring gaps, it's probably going to pass muster from the auditor.