6 replies to this topic

[hossaim6]

Our company produces dry blend ingredient and we are SQF certified. Our process flow indicated screening and metal detector are process preventive control (PC). It didn’t indicated as a CCP. Upper Quality Team is saying no need to indicate those are CCP, instead writing a memo that process PC is CCP.  I believe we need to indicate both PC/CCP however they disagree.

 

SQF auditor issued a Non conformance as SQF is Codex Alimentarius HACCP based Food Safety Plan. They also disagree with the auditor.

 

What is your opinion?

[GMO]

Glenn will no doubt be along shortly to explain the specifics of SQF's view on this. 

 

There is a specific clause I can see though which appears to indicate your auditor is right.  But I do think it's nitpicking.

 

2.4.3.10 Suggests you need to identify CCPs.

 

I have to admit with GFSI schemes including things like radiological hazards that they permitted FSMA based food safety plans instead.  But looking at the wording of BRCGS it's similar.

 

From a HACCP perspective however, people will tell you a process PC is the same as a CCP.  It's not.  Sometimes it's an oPRP and sometimes (certainly if you don't work to ISO22000) even a PRP in "traditional" HACCP due to the way that prerequisites are considered within decision trees.  You will have more preventive controls (including more process preventive controls) in a FSMA food safety plan than you'll have CCPs in a HACCP plan.

 

But does it matter to food safety?  No, not at all.  The process to get to the end point of control measure that is controlling what would be a significant hazard in the absence of PRP control is just a different tool to get to a similar place.  If it was a problem, the US would have vastly worse outputs for food safety related to the way risk is considered.  (You don't.)

 

It is possible and perfectly acceptable to combine a food safety and HACCP plan.  In fact I'd really recommend it.  Those of us who have been under FDA for export to the US have done that for years.  It's only US plants I see doing separate food safety and HACCP plans for audit purposes only.

 

So I'd recommend just having an extra column and using the Codex decision tree to decide which of your PPCs are CCPs.  Far too many Ps and Cs...

[hossaim6]

Thank you. 

 My understanding is as SQF is Codex Alimentarius based Food Safety Plan. CCP must be identify on process flow and justification of CCP is also required. 

[GMO]

Yes, the justification of the CCP identification can be via a decision tree.  My point is yes, you need to follow the letter of the standard you're being assessed to even if the impact to food safety is zero.  That's where I find some of these standards frustrating.  But also you can have a food safety and HACCP plan combined in one document.  Yes, also put them on the flow diagram.  This is standard practice.

[G M]

In most cases it is up to the team writing the safety plan to define which steps are PC / CCP / etc. and to provide the risk analysis justification for that status. 

 

You can call it whatever you want, if you can explain why.

[GMO]

In most cases it is up to the team writing the safety plan to define which steps are PC / CCP / etc. and to provide the risk analysis justification for that status. 

 

You can call it whatever you want, if you can explain why.

 

It looks as though an assessment to determine which (if any) are CCPs is required by SQF.

[Scampi]

SQF will want to see a codex decision tree that makes the determination of a CCP (or not) e.g. can you identified a PRP that FULLY controls the hazard, thus no CCP required  or NO your PRP(s) do not fully control the hazard hence is CCP IS required

 

YOU get to decide if it is a CCP or not, but your reasoning must be sound and you must demonstrate that the hazard is fully controlled 

 

Foreign material control has a CCP is wildly debated------would WHOLY depend on what FM your worried about, and whether or not full control measures have been put in for control

 

SQF does NOT however, tell you whether something should or should not be a CCP