Back to Basics - HACCP Audit Table

After 12 years of internal auditing and reviewing our HACCP plan, I've decided to strip the plan back to "raw steel" and start from scratch, looking at everything as if I was setting it up for the first time.

 

It's been a worthwhile exercise, and the plan is stronger than it was before.

 

I am now working on the Hazard Audit Table and adopted columns for the:

Production Step
Hazard
Control Measure
CCP or CP Identifier
Critical Limit
Monitoring 
Corrective Action and 
Records

 

I am seeking your input on what (if anything) to put in the Critical Limit column for non-Critical control points (mere CP's or QCPS).

 

I currently have settings limits like (No more than 45% of the capacity of the equipment) but in truth these are not CRITICAL limits as the control point is not a CRITICAL one.

 

Should I just put a "-" in that column unless it is a CCP?

 

Any advice is greatly appreciated.

This is the form I use

 

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

 

It's the combined 8 form (use control F to find it) and tells you exactly what to put in each step

I think auditors would prefer to see N/A versus "-" for items where there is no Critical Limit necessary.

 

I would possibly caution against listing any limit in that column for non-CCP items.  I invite others to chime in if I'm off base here, but I think it invites a lot of uncomfortable questions regarding why you're declaring Critical Limits on non-critical steps.  Even in your example of "No more than 45% of the capacity of the equipment":  Why is the equipment unable to run at maximum capacity?  Who monitors this to ensure 45% of capacity is not reached?  Where are the records of you monitoring this limit?  So on, so forth.  

I am going to go the N/A route. No auditor has challenged it in the last 12 years (with the QCP limits included).  If they complain I'll put them back in, but my principle will be "only critical control points have critical limits" If for informational purposes they want more information I can provide it.

 

The auditors tend to focus more on the Hazard Analysis Worksheet, which is a much larger document, I think by the time they get to the HAT they are like, "okay enough already we get it".  

We have CCP tables separate to our Hazard Analysis Table (HAT).

 

We use N/A in the HAT tables when not assessed as a CCP or OPRP.

 

CCP tables list all the limits, monitoring requirements, corrective actions etc.

We have CCP tables separate to our Hazard Analysis Table (HAT).

 

We use N/A in the HAT tables when not assessed as a CCP or OPRP.

 

CCP tables list all the limits, monitoring requirements, corrective actions etc.

Thank you, that makes sense to me.

I’d use N/A in that table but after I adapted a HACCP plan for FSMA a few years back it did make me challenge prerequisites more and really think about how they are monitored or verified (as both is not always possible with prerequisites) and validated. It was a worthwhile exercise and as part of that I did think about limits of what was in and out of control. I can’t remember if I called them critical limits, I don’t think I did because of having a purist HACCP approach drummed into me by Campden BRI but I agree, good exercise to do.