10 replies to this topic

[broncobill]

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? 

Edited by broncobill, Yesterday, 12:00 PM.

[kfromNE]

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. 

[TimG]

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.

[GMO]

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

[broncobill]

Thank you.

[Tony-C]

Hi broncobill,

 

You need to consider if there are any that are relevant to your products/location.

 

Radiological hazards in water need to be considered in the US, some contamination was caused by nuclear testing and others from natural radionuclides.

 

You also need to be aware of any issues highlighted by USDA FSIS & FDA. For example, from my recent summary of 2025 Recalls (in January's Food Safety Essentials Webinar) there were issues with Caesium 137 in Shrimps from Indonesia:

 

 FSE January 2026 Caesium FDA Recalls 2025.png   1.03MB   0 downloads

 

See more details here FDA Advises Public Not to Eat, Sell, or Serve Certain Imported Frozen Shrimp from an Indonesian Firm

 

Kind regards,

 

Tony

[qa_maddy]

We also got hit with not having radiological hazards as part of our hazard analysis and not discussing it as part of the newly occurring hazards (Cesium Recall over the summer) because we do source shrimp out of Indonesia, just not from that vendor. 

 

I think auditors are all using the Cesium 137 recall as a gotcha to see if people are keeping up with current industry-wide recalls / "new" hazards popping up since this one took so long to figure out a root cause for. 

 

Our basic control for it is our Supplier controls - if a supplier we use was implicated we'd stop purchasing. We keep track and discuss any new industry wide recalls during monthly and HACCP review meetings. We would decide if we keep purchasing from there. 

[GMO]

The other thing we did was include it in our scope and terms of reference. We put it into the "chemical" hazards section that we would consider it if relevant. I have always had a fixed agenda for HACCP meetings as well and we include "new hazards" as a question and have examples for each chemical, biological and physical. I think I also included for example radiological in chemical so we could at least show that the question was asked and answered in the negative.

 

But I agree with the above. The caesium 137 case is an easy "gotcha" for anyone importing anything from Indonesia (or potentially you may have a sub ingredient such as spices imported from there). As it was linked to the containers, the spread of ingredients potentially impacted could be huge. I'd expect that to be minuted with an action for checking all ingredients and sub ingredients are not impacted and any potential ingredients from that country (albeit it's huge) are asked questions about whether there is a risk, e.g. for spice and prawn suppliers. Also thinking about any other risk in supply chain you can think of.

 

Still think it's weird it was caught and how caesium 137 is associated with nuclear waste but that's another topic.

 

Sorry, just can't call them shrimp. Shrimp in the UK are tiny wee things. Like less than a cm. Often served "potted".

[G M]

...

I think auditors are all using the Cesium 137 recall as a gotcha to see if people are keeping up with current industry-wide recalls / "new" hazards popping up since this one took so long to figure out a root cause for. 

...

 

They do receive some guidance, and keep up the field themselves, if there is a spate of new comments or minor non-conformances related to radiological hazards it would seem like a reasonable common incident.

[qa_maddy]

They do receive some guidance, and keep up the field themselves, if there is a spate of new comments or minor non-conformances related to radiological hazards it would seem like a reasonable common incident.

 

I'm not complaining - like. Am I little annoyed? Sure - mostly at myself though.

It should have occurred to me to include it in our own review as I was on early calls about the recall due to our product catalog and our involvement in industry groups. I was just commiserating on getting caught on an easy NC that I should have noticed. 

[GMO]

I'm not complaining - like. Am I little annoyed? Sure - mostly at myself though.

It should have occurred to me to include it in our own review as I was on early calls about the recall due to our product catalog and our involvement in industry groups. I was just commiserating on getting caught on an easy NC that I should have noticed. 

 

We got caught early with the changes when they were brought in with was it version 8 BRCGS or 7? I forget. My HACCP team leader assured me he'd made changes to the plan with the team but I didn't check myself. I was fuming when he brought it up on screen and there was nothing there on radiological. It was EXTREMELY low risk for the product I was making at the time so only a minor but still, drove me potty to have such a simple and avoidable non con.