10 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

[Tony-C]

Hi hossaim6,

 

I think marking PCs on the flow diagram is adding confusion but I’d like to know the exact wording of the Non-Conformance.

 

There is no specific requirement in the SQF Food Safety Code to mark CCPs on a flow diagram (see clause 2.4.3.6). The SQF Code does however require: ‘A food safety plan shall be prepared in accordance with the twelve steps identified in the Codex Alimentarius Commission HACCP guidelines’ (clause 2.4.3.1).

 

Codex Alimentarius Commission HACCP guidelines for flow diagrams are in 19.4 Construct flow diagram (Step 4) and do not state that CCPs should be indicated on the diagram.

 

As the SQF Code requires you to follow Codex HACCP guidelines, you should follow the CODEX guidance in determining your CCPs, CODEX indicate this can be helped by using a decision tree or a CCP determination worksheet (see below). CODEX guidance also states the CCPs identified could be … highlighted at the appropriate step on the flow diagram which IMO means that is advisable to do so but not compulsory.

 

19.7 Determine the critical control points (CCPs) (Step 7/ Principle 2)

 

CCPs are to be determined only for hazards identified as significant as the result of a hazard analysis. CCPs are established at steps where control is essential and where a deviation could result in the production of a potentially unsafe food. The control measures at CCPs should result in an acceptable level of the hazard being controlled.

 

Determining whether or not the step at which a control measure is applied is a CCP in the HACCP system can be helped by using a decision tree or a CCP determination worksheet (see Annex IV, Figure 1 and Table 1). A decision tree should be flexible, given whether it is for use in production, slaughter, processing, storage, distribution, or other processes. Other approaches such as expert consultation may be used.

 

To identify a CCP, whether using a decision tree or other approach, the following should be considered:

• Assess whether the control measure can be used at the process step being analysed.

– If the control measure cannot be used at this step, then this step should not be considered as a CCP for the significant hazard.

– If the control measure can be used at the step being analysed, but can also be used later in the process, or there is another control measure for the hazard at another step, the step being analysed should not be considered as a CCP.

• Determine whether a control measure at a step is used in combination with a control measure at another step to control the same hazard; if so, both steps should be considered as CCPs.

 

The CCPs identified could be summarized in tabular format, e.g. the HACCP worksheet presented in Annex IV, Table 2, as well as highlighted at the appropriate step on the flow diagram.

 

Kind regards,

 

Tony

Edited by Tony-C, Yesterday, 04:22 AM.

[GMO]

Process PCs identified on a flow diagram is expected by FDA auditors.

 

But I don't personally find that confusing.  Many (not all) will be CCPs or oPRPs.  Some will be PRPs but that won't be a huge number.

[GMO]

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

 

 

Both the Codex and Campden BRI decision trees have good initial questions on them to determine if this is the case.  That's why I'd recommend use of either of them (Codex preferred in this case as it's not a UK plant) to prove you've used an industry best practice process to establish whether or not something is a CCP.

 

From my experience in US plants though they identify a lot more process PCs than you would have CCPs.  It's the way the FSMA legislation is written.  There are sadly some really BS comments in HACCP texts (including the newest Campden one) claiming equivalence with oPRPs or CCPs and that's not true.  FSMA gets you to apply the thinking before prerequisites are applied, only after GHPs.  Most HACCP plans advise the opposite.

[Tony-C]

Process PCs identified on a flow diagram is expected by FDA auditors. Expected or a requirement?

 

But I don't personally find that confusing.  Many (not all) will be CCPs or oPRPs.  Some will be PRPs but that won't be a huge number. 

 

Process PCs, which are more than likely to be key controls including CCPs, would make sense but what I meant was putting all preventative controls on a flow diagram would be confusing, apologies if that wasn't clear. 

 

 FDA Guidance Table 4-3 Common Process Controls.png   513.52KB   0 downloads

 

Kind regards,

 

Tony