26 replies to this topic

[Sudais Asif]

Hello, I run a gluten free foods company and we are preparing for FSSC 22000 currently. For HACCP, we have created flowcharts for a range of products, however, they are a bit different from your standard flowcharts since a lot of visualization has been used. I am attaching 2 photos below as an example, would these be acceptable? In your opinion, what disadvantages would it pose compared to traditional flowcharts and anything that auditors may be concerned with?

Attached Files

•  Gulab Jamun Flow CHart.PNG   154.6KB   2 downloads
•  Bread & BUns Flow Chart.PNG   182.42KB   2 downloads

[FSM4you]

Hello, I run a gluten free foods company and we are preparing for FSSC 22000 currently. For HACCP, we have created flowcharts for a range of products, however, they are a bit different from your standard flowcharts since a lot of visualization has been used. I am attaching 2 photos below as an example, would these be acceptable? In your opinion, what disadvantages would it pose compared to traditional flowcharts and anything that auditors may be concerned with?

Hello,

 

IMO, these are a little too informative. I believe they would be acceptable, but I think it opens you up to unnecessary headaches for HACCP violations in the future. My USDA inspector would give us an NR if any part of that was not followed, or done differently then the flowchart states.  

[SQFconsultant]

I go with what FSM4you said and add that as a former Auditor THESE WOULD open up a lot of rabbit holes to be run down that don't need to run down, leading to errors that were not intentional at time of creation - it looks very pretty, but Auditors are not looking for pretty.

 

I'd go the traditional route.

[nwilson]

These seem more like a work instructions flow chart not a HACCP based flow chart.  You should keep things simple and more general in the description of each processing step.  As others have already stated this could be interpreted in a way that would lead to a NC during an audit.  

 

An example:  Mix ingredients --> Create dough --> Form dough balls --> Fry dough balls --? Etc...... Your risk assessment will also be catered and more clear for each step and change in the process.  

[jfrey123]

I don't think there's anything wrong with making it pretty with the pictures, but if you were to review a few publicly searchable examples I think you'll see where you can make some improvements to your flow chart.  Couple things I'm spotting right away:

• The receiving step does not include receiving packaging, nor does it specifically indicate where packaging is introduced into the flow.
• There is no step for storage of raw material or storage of finished goods (I do see a fridge/chiller step with the gulab, but that's prior to packaging so likely only applies to WIP material).  The bread flow chart does not list the receiving step for any ingredients either.
• I speculate that there are some ambient temperature raw ingredients (oils, flours, etc.), and some that likely require refrigeration (eggs).  I normally see flow charts differentiate between cold and ambient receiving and storage, both on the flow chart and hazard analysis.
• If creating either doughs requires water, I'm not seeing water as an input on the flow chart (which should also be included near the receiving part of the flow chart and listed on your HA).
• Bread flow chart does not indicate any CCP's (if there are none then never mind).

[GMO]

What purpose are you trying to make them pretty?  Which audience?  I'd stick to photos in procedures and science in the HACCP plans.

[Scampi]

Those are work flows, not a HACCP flow diagram

 

K.I.S.S. is what you should follow for your flow chart

[Sudais Asif]

These seem more like a work instructions flow chart not a HACCP based flow chart.  You should keep things simple and more general in the description of each processing step.  As others have already stated this could be interpreted in a way that would lead to a NC during an audit.  

 

An example:  Mix ingredients --> Create dough --> Form dough balls --> Fry dough balls --? Etc...... Your risk assessment will also be catered and more clear for each step and change in the process.  

Can you please elaborate on what would differentiate work instructions and haccp based flow charts? From my understanding, a HACCP based flow chart needs to include all steps involved and as others have stated, need not be so detailed but making it detailed should not take away from it being a HACCP flowchart.

 

TIA.

[Sudais Asif]

Those are work flows, not a HACCP flow diagram

 

K.I.S.S. is what you should follow for your flow chart

Why would they not qualify for being HACCP flow diagrams, anything missing? 

 

Asking purely for my understanding, appreciate your response.

[Sudais Asif]

 

I don't think there's anything wrong with making it pretty with the pictures, but if you were to review a few publicly searchable examples I think you'll see where you can make some improvements to your flow chart.  Couple things I'm spotting right away:

• The receiving step does not include receiving packaging, nor does it specifically indicate where packaging is introduced into the flow.
• There is no step for storage of raw material or storage of finished goods (I do see a fridge/chiller step with the gulab, but that's prior to packaging so likely only applies to WIP material).  The bread flow chart does not list the receiving step for any ingredients either.
• I speculate that there are some ambient temperature raw ingredients (oils, flours, etc.), and some that likely require refrigeration (eggs).  I normally see flow charts differentiate between cold and ambient receiving and storage, both on the flow chart and hazard analysis.
• If creating either doughs requires water, I'm not seeing water as an input on the flow chart (which should also be included near the receiving part of the flow chart and listed on your HA).
• Bread flow chart does not indicate any CCP's (if there are none then never mind).

 

Agreed on all points, I will work on those.

 

A question about the water point, wouldn't it fall under the same category of other raw material or is it necessary to list it separately? Asking generally rather than just in the context of the attached examples.

[GMO]

Agreed on all points, I will work on those.

 

A question about the water point, wouldn't it fall under the same category of other raw material or is it necessary to list it separately? Asking generally rather than just in the context of the attached examples.

 

Yes, normally any utilities should be listed separately.  Your control measures on water are unlikely to be similar to other suppliers.

[jfrey123]

A question about the water point, wouldn't it fall under the same category of other raw material or is it necessary to list it separately? Asking generally rather than just in the context of the attached examples.

 

What GMO said.  Unless you're bringing in the water on pallets from a water supplier, it's not receiving the benefit of inspection at receiving with COA's and a LoG to guarantee purity.  The biological hazards for using water from your taps at the plant are addressed through monitoring in your EMP program, something not likely done for raw materials received via truck.

Edited by jfrey123, 30 April 2025 - 04:07 PM.

[nwilson]

Can you please elaborate on what would differentiate work instructions and haccp based flow charts? From my understanding, a HACCP based flow chart needs to include all steps involved and as others have stated, need not be so detailed but making it detailed should not take away from it being a HACCP flowchart.

 

TIA.

 

There is no branch off at any step to show waste, the movement of the materials to the location of processing (such as staging or being stored in a warehouse), or an appropriate call out to CCP's (baking/thermal processing for your bread).  If you are performing a risk assessment for all associated hazards to this process flow then steps are missing and it is incomplete, meaning your risk assessment is not complete either.  As others said where is water coming into this process flow?  

 

This is why I stated that this looks like work instructions.  If you want to include pictures as a visualization aid by all means do so, just make sure you include every step in the process by walking the entire process and documenting it appropriately.  

[GMO]

I have to be honest I agree with all of the other comments.  I'd look at this and have a bit of a reaction along the lines of "WTAF is that meant to add?"

I'm very much of the opinion that HACCP is not an esoteric tool only for Techies, but at the same time, this looks very much like style over substance.

 

After being annoyed, these are the questions I'd ask you as an auditor. 

Flow 1

Cook milk powder, to what temperature / time?

Fry at what temperature / time?  

If the soaking stage is a CCP, what are the parameters?  Why is that unrefrigerated when there is a CCP for refrigeration later?

Is there no labelling step to indicate ingredients including allergens?  No coding?

Where is incoming water and packaging, outgoing waste?

 

Flow 2

 

What is the bake time / temperature?

What temperature are you cooling to?  (Not enough and you risk mould growth.)

Where is the packaging and waster infeed and waste outfeed?

Do you not label and code?

 

Take out the pictures.  What are they adding?  I'm being honest I'd find this really annoying.  I would start delving deep into your HACCP plan as I'd assume the team leader didn't know what they were doing.

[Sudais Asif]

I have to be honest I agree with all of the other comments.  I'd look at this and have a bit of a reaction along the lines of "WTAF is that meant to add?"

I'm very much of the opinion that HACCP is not an esoteric tool only for Techies, but at the same time, this looks very much like style over substance.
 
After being annoyed, these are the questions I'd ask you as an auditor. 

Flow 1

Cook milk powder, to what temperature / time?
Fry at what temperature / time?  
If the soaking stage is a CCP, what are the parameters?  Why is that unrefrigerated when there is a CCP for refrigeration later?
Is there no labelling step to indicate ingredients including allergens?  No coding?
Where is incoming water and packaging, outgoing waste?
 
Flow 2
 
What is the bake time / temperature?
What temperature are you cooling to?  (Not enough and you risk mould growth.)
Where is the packaging and waster infeed and waste outfeed?
Do you not label and code?
 
Take out the pictures.  What are they adding?  I'm being honest I'd find this really annoying.  I would start delving deep into your HACCP plan as I'd assume the team leader didn't know what they were doing.

Thank you for the detailed reply, to answer a few questions:
 
The soaking stage does not involve refrigeration because the Gulab Jamun/Sugar Balls are supposed to soak up the sugar while still hot and by definition of how the sweet is made, refrigerating them would result in a change of texture at this stage. It is defined as a CCP because any microbial growth here would not be fixed later on because their is no other frying kill step afterwards.
 
As for the labelling, we pack these in plain trays which are then dispatched but I have include a packaging & labelling step now which would include adding a manufacturing & expiry date to the tray + mentioning allergens if not all ingredients.
 
For the other points, I have attached a revised flowchart based on feedback from all and you, I would appreciate if you could review it and let me know if it now fills all the checkboxes.
 
Also another question, do flowcharts always need to mention time & temperature for processes?

[Sudais Asif]

Attached is a revised flowchart I have created based on everyone's feedback, any comments would be appreciated.

Attached Files

•  Gulab Jamun Flowchart.png   358.19KB   1 downloads

Edited by Sudais Asif, 02 May 2025 - 02:53 PM.

[FSM4you]

Attached is a revised flowchart I have created based on everyone's feedback, any comments would be appreciated.

I think this is better, but I see a lot of CCP's. Is there a reason for so many CCP's? I don't have a background in making these kinds of products, but most should be just CP's IMO.

 

Also, I would group all the processing stuff into one category. 

Edited by FSM4you, 02 May 2025 - 03:03 PM.

[jfrey123]

I think this format is more common and will be appreciated by your customers and auditors alike.  Couple thoughts for you to consider:

• Water is usually shown coming into the side the way you show oil coming in from the side.
• Speaking of oil, "Reworked oil"?  I can't say I've ever seen a facility with so much rework they list it on their HACCP, that would signal to me there's a process not being controlled well enough as rework is pretty usually rare and heavily scrutinized.
• Listing your temp/time specifics is usually done in the Hazard Analysis where you can describe it better.  Flowcharts are usually simpler, so I'd go with "Cook Milk Powder" and "Frying" as the description on the flowchart with specifics on the HA.  The way you have it listed, it makes me want to ask, "Cooking milk powder, are you going for 10 min or to 60C?  What happens if it takes 12 minutes to hit 60C?  What happens if you hit 60C in 4 minutes?"  Describing it in the HA prevents the confusion I'm having right now, lets you describe whether the time or the temp is your actual critical limit.
• Just a guess, but I bet "Formulation of dough balls" is a mixing and forming step, yes?  You might want to clarify that there is mixing at this step that includes forming the dough balls because mixing adds its own set of hazards you'll want to discuss in the HA.  You'll also want to have something referencing how your company decides what full mixed or homogenized looks like.
• Is there storage after packaging?  Or are you able to package and load directly to trucks?  If finished packages go into storage, you'll need to add that step prior to Dispatch.  And you'll probably want to describe how your storage practices separate finished packages from those WIP items that are stored prior to packaging.

[Sudais Asif]

I think this is better, but I see a lot of CCP's. Is there a reason for so many CCP's? I don't have a background in making these kinds of products, but most should be just CP's IMO.

 

Also, I would group all the processing stuff into one category. 

 

1. CCP 1 is because we make gluten free and halal food so any contamination at this point can not be controlled later on.

2. CCP 2 is because frying serves as a lethality kill step, if not done properly, any micro-contamination may survive and cannot be killed later on as no other process after this is a lethality based one - CCP measured based on internal cooking temperature logs.

3. CCP 3 is because cooling at a specific temperature and with proper hygiene will prevent mold, fungal and other micro growth which if done cannot be removed after this step - CCP measured through temperature logs & time records.

4. CCP 4 is because storage unless done properly in a refrigerated manner again will lead to micro-growth that is not killable - CCP measured through temperature logs of fridge.

 

But can we categorize them into Control Points regardless? if yes, that would work too, would not like to overdo things.

 

Secondly, can you elaborate on which processing are you talking about grouping into one category?

[Sudais Asif]

 

I think this format is more common and will be appreciated by your customers and auditors alike.  Couple thoughts for you to consider:

• Water is usually shown coming into the side the way you show oil coming in from the side.
• Speaking of oil, "Reworked oil"?  I can't say I've ever seen a facility with so much rework they list it on their HACCP, that would signal to me there's a process not being controlled well enough as rework is pretty usually rare and heavily scrutinized.
• Listing your temp/time specifics is usually done in the Hazard Analysis where you can describe it better.  Flowcharts are usually simpler, so I'd go with "Cook Milk Powder" and "Frying" as the description on the flowchart with specifics on the HA.  The way you have it listed, it makes me want to ask, "Cooking milk powder, are you going for 10 min or to 60C?  What happens if it takes 12 minutes to hit 60C?  What happens if you hit 60C in 4 minutes?"  Describing it in the HA prevents the confusion I'm having right now, lets you describe whether the time or the temp is your actual critical limit.
• Just a guess, but I bet "Formulation of dough balls" is a mixing and forming step, yes?  You might want to clarify that there is mixing at this step that includes forming the dough balls because mixing adds its own set of hazards you'll want to discuss in the HA.  You'll also want to have something referencing how your company decides what full mixed or homogenized looks like.
• Is there storage after packaging?  Or are you able to package and load directly to trucks?  If finished packages go into storage, you'll need to add that step prior to Dispatch.  And you'll probably want to describe how your storage practices separate finished packages from those WIP items that are stored prior to packaging.

 

1. Couldn't get your point about water since its a separate step in the main flow, can you kindly elaborate further?
2. For oil, actually, we reuse oil a certain amount of times for frying so I have categorised that as rework, any suggestions on how to mention it in a more acceptable way? We confirm periodically that the oil is safe to use by micro-testing it in our lab.
3. Point noted, will shift the time and temperature to our CCP worksheet & HACCP plans.
4. True, I will add mixing as a separate step from forming, understood. Also well homogenized/mixed is as same as visually seeing that  a uniform ball has been made, so should it be added and if yes, in the hazard analysis?
5. Yes their is storage, will add it.

 

Thank you for your valuable input, would appreciate more clarity on points 1 and 2.

[GMO]

How does cooling to 25-30oC prevent yeast, mould and bacterial growth?  

 

Your CCPs need to be determined after your hazard analysis.  For your hazard analysis, you need to have been specific about your hazard.  What specific hazard(s) are you controlling in CCP 3 and what are your control measures?  For me, I cannot see how CCP 3 is valid as a CCP when you also need to refrigerate later.  I get the question on quality but HACCP is a food safety tool not a quality one.  What food safety risk is being controlled by refrigeration which is not uncontrolled at CCP3.  I cannot see how that currently makes sense.

[Sudais Asif]

How does cooling to 25-30oC prevent yeast, mould and bacterial growth?  

 

Your CCPs need to be determined after your hazard analysis.  For your hazard analysis, you need to have been specific about your hazard.  What specific hazard(s) are you controlling in CCP 3 and what are your control measures?  For me, I cannot see how CCP 3 is valid as a CCP when you also need to refrigerate later.  I get the question on quality but HACCP is a food safety tool not a quality one.  What food safety risk is being controlled by refrigeration which is not uncontrolled at CCP3.  I cannot see how that currently makes sense.

Gulab Jamun are fried in oil when made and undergo a cooling step afterwards before refrigeration. If the cooling step is not done properly (product kept in danger zone for too long or the cooling is not done inside the sugar syrup which acts as a protector against mold & fungus), it can lead to microbial growth.

 

This is why it is a CCP - because if microbial growth occurs, even refrigeration later on will not be able to fix or undo that growth, it is there with no other lethality step to clean things up.

[GMO]

Gulab Jamun are fried in oil when made and undergo a cooling step afterwards before refrigeration. If the cooling step is not done properly (product kept in danger zone for too long or the cooling is not done inside the sugar syrup which acts as a protector against mold & fungus), it can lead to microbial growth.

 

This is why it is a CCP - because if microbial growth occurs, even refrigeration later on will not be able to fix or undo that growth, it is there with no other lethality step to clean things up.

 

Hmm.  I audit HACCP plans and I'd be sat there thinking about what level of non conformance this is looking like by this point.  I've asked you, what specific hazard you're controlling for.  Specific.  You've said "mould, fungal and other micro" and now "mould and fungus".  Those are not specific hazards.  Most yeasts and moulds are not pathogenic.  Some create mycotoxins.  What is the hazard and what is the control measure in the syrup controlling it?  

Also I am familiar with the product, I've eaten it many times, you don't need to explain the product to me, you need to be able to explain your decision process to an auditor.  So, if that sugar syrup is effective at controlling those food safety hazards (once you have properly defined them), why do you then need to chill the product?  You're missing my point in I do understand chilling later will not remove the hazard for CCP3 but chilling later makes no sense if CCP3 is required and effective unless there is some reason why it's only effective for a limited time.  Do you understand that?  The flow creates so many questions around the understanding of HACCP and food safety that I would dig and dig...  And I'm not trying to be combative but the answers you're giving suggest some knowledge gaps which would make me dig more.  Does that make sense?

 

When you do your hazard analysis it's really important you clearly and specifically define the hazard.  So this is normally described as "presence, introduction, growth or survival" and for microbiological hazards it will not normally be accepted that you do not define the specific species or group of species.  In this syrup stage I'm still unclear what you're controlling for.  You need to define that, understand why it's there (has it survived frying at the previous stage or is it being introduced here with a risk of growth and mycotoxin formation?)  Then later you will need to define the control measure which is effective against the hazard that you can point the auditor in the direction of why you've chosen it.  So for example, if your sugar syrup is, say, 50% sugar by weight, that has an Aw of xx in which yy mould cannot grow according to academic paper... etc.  

 

At the moment I'm unsure how you could possibly have chosen the CCPs you have without being clear about the hazards you have.  I'm suspicious that you may just have copied a process from somewhere else or inherited it...  Would I be right?

[Sudais Asif]

Hmm.  I audit HACCP plans and I'd be sat there thinking about what level of non conformance this is looking like by this point.  I've asked you, what specific hazard you're controlling for.  Specific.  You've said "mould, fungal and other micro" and now "mould and fungus".  Those are not specific hazards.  Most yeasts and moulds are not pathogenic.  Some create mycotoxins.  What is the hazard and what is the control measure in the syrup controlling it?  

Also I am familiar with the product, I've eaten it many times, you don't need to explain the product to me, you need to be able to explain your decision process to an auditor.  So, if that sugar syrup is effective at controlling those food safety hazards (once you have properly defined them), why do you then need to chill the product?  You're missing my point in I do understand chilling later will not remove the hazard for CCP3 but chilling later makes no sense if CCP3 is required and effective unless there is some reason why it's only effective for a limited time.  Do you understand that?  The flow creates so many questions around the understanding of HACCP and food safety that I would dig and dig...  And I'm not trying to be combative but the answers you're giving suggest some knowledge gaps which would make me dig more.  Does that make sense?

 

When you do your hazard analysis it's really important you clearly and specifically define the hazard.  So this is normally described as "presence, introduction, growth or survival" and for microbiological hazards it will not normally be accepted that you do not define the specific species or group of species.  In this syrup stage I'm still unclear what you're controlling for.  You need to define that, understand why it's there (has it survived frying at the previous stage or is it being introduced here with a risk of growth and mycotoxin formation?)  Then later you will need to define the control measure which is effective against the hazard that you can point the auditor in the direction of why you've chosen it.  So for example, if your sugar syrup is, say, 50% sugar by weight, that has an Aw of xx in which yy mould cannot grow according to academic paper... etc.  

 

At the moment I'm unsure how you could possibly have chosen the CCPs you have without being clear about the hazards you have.  I'm suspicious that you may just have copied a process from somewhere else or inherited it...  Would I be right?

Thank you for the detailed reply again.

 

I haven't copied it from anywhere, I run a small food company and I'm trying to establish our documentation according to the best of my knowledge and industry experience. However, I'm doing HACCP for the first time so that may be one reason that some points are lacking which as I understanding will need further refinement and review.

 

So I'll ask to understand and put my point across of why I believe chilling is needed after cooling in the sugar syrup:

 

Cooling in the sugar syrup lets the fried Gulab Jamun soak up the syrup and take on its typical sweetness. During this period, the sugar solution prevents if we put it very specifically, the growth of fungal colonies beyond microbiologically defined limits (it may grow if the Gulab Jamun was not kept soaked), hence it becomes a CCP.

 

Now for the short term, this works but let's say, 14 days, letting it remain soaked in the syrup would not be as effective as chilling to maintain the Jamun's shelf life and freshness.

 

Therefore, after obtaining the benefit of "sugar soaking" during the cooling period, we shift it to the chilling step.

 

The chilling step itself becomes a CCP because now if the temperature is not controlled during this step, again fungal colonies which we by experience know to grow on such products become a danger. For example if the temperature is 15*C (fridge is not working), and the product is not soaked in the sugar syrup either now, it will develop fungal spores which are visible after a few days.

 

I agree on defining specific hazards and that's a point I will implement in our HACCP plans.

[GMO]

Ok, I will try and explain again.  I think you're misunderstanding what I mean.

 

"Fungal colonies" is not a specific food safety hazard.  What fungus, what harm will it cause a consumer?

 

If it's ok for "the short term", how is that validated?

 

In chilling, "fungal colonies" is again not a specific food safety hazard.

 

Some people do HACCP (IMO badly) and include things like "moulds".  If you are going to be as unspecific as that (and remembering most moulds are spoilage organisms not food safety), then you need to know the hurdles you're trying to overcome for all mould.  Mycotoxins are probably valid but it's worth doing some reading up on what kind of moulds are likely to be present in your process and also consider what other controls you have for general cleaning and air standards to reduce the risk of mould issues (although this again is probably more of a quality than a food safety issue.)

 

I think it might be worth getting some more HACCP training.  What have you had so far?