4 replies to this topic

[BALA Prasanna]

Dear Team,

 

I am currently updating our HACCP hazard analysis and risk assessment, specifically addressing microbiological hazards in line with BRCGS standard requirements. According to the standard, the HACCP food safety team must conduct a hazard analysis to identify significant hazards—those reasonably likely to occur at unacceptable levels—that need to be prevented, eliminated, or reduced to acceptable levels. 

 

I have updated our hazard analysis in the attached format:

 

My Question:

 

I want to ensure that my hazard analysis fully complies with the standard requirement, particularly regarding survival and multiplication of micro-organisms.

 

Could anyone confirm if this format is compliant, or share a recommended format that meets the standard requirements for microbiological hazard documentation? Any practical guidance or examples would be greatly appreciated.

 

Thank you in advance for your support.

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[SHQuality]

If I'm honest, it looks like you've lumped too many risks together in groups and you have not specified WHICH yeasts, moulds and other bacteria are a risk factor for your products. Do the PRPs specify a sampling method that avoids missing a contamination when it's not homogenously distributed in the product?

[BALA Prasanna]

Thank you for your valuable reply. Actually, In our raw material specification, we have to check those para meters at receipt time. So that I was mentioned the same. But we have control measure like Supplier Inspection Report and Incoming Inspection practice. So How I can give the clear justification about this?

[GMO]

My concern is slightly different. The clause is after two things:

 

Specific identification of microorganisms of concern.

 

Whether they are present, being introduced at that step, growing (or multiplying) or surviving.

 

So on point 1, have you specifically identified the microorganisms? I'd say no, you have not. You've identified a mixture of potentially pathogenic organisms (Salmonella) along with types of microorganism which are sometimes pathogenic (E Coli) and wider classes which may do very little (yeasts) or may produce mycotoxins (moulds) along with wide classes of things from the innocuous to the downright dangerous (coliforms and TPC).

 

Go back, specifically identify microorganisms which are a food safety hazard at that step.

 

On the second point, are you describing how they're changing? You've used the terms survival and multiplication but, in my opinion, inappropriately. What is the "receiving" step doing to change these microorganisms in any way? In my mind, I'd suggest the only appropriate word to use here is "presence".

 

I am of the opinion that it's useful to include a sentence on hazard description not just bullet points like you have.

Let's take the example of flour? I don't know your product but flour, unless it's heat treated will contain Salmonella spp. and E Coli.

 

So for flour specifically, I might write the hazard description something like this:

 

"Presence of Salmonellae and HUS causing E Coli due to field and farm environment. Baking step later in process."

 

If it's heat treated, I might write the hazard description like this:

 

"Presence of Salmonellae and HUS causing E Coli due to failure of supplier heat process and inadequate supplier controls."

 

So there's a few things I'd think about for compliance, but, more importantly, for food safety.

• Do you need to split apart which raw materials are being receipted? Sugar is a very different microbiological risk from flour.
• Include only food safety hazards into your HACCP plan.
• Be specific about what is changing at that step or if the microorganism is simply present.
• Include why it's present, being introduced, growing or surviving (i.e. what has failed for that to happen).
• Then what has failed is often your control measure or at least a starting point for it.
• Remember a control measure is the intent, inspections are monitoring or verification depending on the frequency as are COA. (A lot of people do include monitoring items into their control measure boxes but just for completeness I thought I'd flag it.)

 

Just some other points.

• If you're bringing in white flour, I'd be shocked if you're not sieving it. Most flour silos have sieves and tailings bags / sample points but that's not included in your physical section (e.g. flour sieving later in process... which might be another reason to split apart ingredients here.)
• If you're bringing in wheat flour, how is wheat a hazard at this point as it's intentionally present? How is the likelihood "1"?
• Raw materials might be the only point radiological hazards are relevant. Have you looked up for risks of where any of the crops are grown or processed?

[GMO]

One of the best resources I've found for HACCP is the food standards agency in the UK. They have a system called "MyHACCP" which helps you through each step. I would recommend it all of the time to global clients but most people don't want to use a resource produced by one specific country. I'd say though that it is the only HACCP resource I've gone to where I've not found actual mistakes (even the FAO manage some believe it or not.)

MyHACCP | Helping you produce safe food

 

Have you had some training as well? And have your team?