Radiological Hazard

Good Morning,

We just had our latest Audit, scored a 97. Our Auditor brought up "radiological" hazard was not in the HACCP Plan. I know this was brought up because of the tsunami that hit the nuclear power plant in Japan in March of 2011 contaminating fish in the ocean.

Has anyone else added this hazard to their HACCP Plan? If so, how did you address it? 

We have it addressed because we are 30 miles of an old power plant. We talk about it in our facility description and area risk assessment. 

The auditor could also be thinking of the shrimp recalls with Cesium-137. 

We address ours with a Radiological Risk Analysis document in our food safety plan that puts it in a high-level overview, and a radiological technical info folder with PDF's of the research that the risk analysis is based on such as FDA published Radionuclides in imported foods concern levels, radionuclides in food as a general doc, and radionuclides in bees and bee products for a more specific risk dive.

It's about doing your research, finding if there is risk, and then addressing that risk and then being able to show all of that to the auditor.

I always addressed this by looking at radiological risk in sourcing. I'm not sure if there is similar in the US but this document is a brilliant reference for your HACCP plans for UK plants or people sourcing from the UK:

Radioactivity in food and the environment (RIFE) report - GOV.UK

Then you could also reference the recent incident with containers and prawns / other foodstuffs. Even if it's not a risk to you, it's good to discuss in a HACCP meeting of how that kind of risk could occur and actively record you've ruled it out. 

I've not read this but just stumbled across this document in a quick google. Not sure if it's helpful. Total Diet Study Report: Fiscal Years 2018-2020 Radionuclides Data

Thank you.