References to Legislation and Codes of Practice in HACCP plan

I have another question...

Is it standard practice to include references to relevant legislation and codes of practice e.g. Codex Alimentarius in the HACCP plan? If so, can someone explain where and how, with examples if possible.

Thanks,
Simon

Dear Simon,

In view of the new avatar, I'm sure this is some kind of trick question but since I don't mind being a patsy -

One routine use is related to the validation of CCPs.
I won't add any examples until I see where the trick is.

Regards / Charles.C

In view of the new avatar, I'm sure this is some kind of trick question but since I don't mind being a patsy -

One routine use is related to the validation of CCPs.
I won't add any examples until I see where the trick is.

I just wanted to show off my new haircut and spectacles, nothing sinister Charles, I promise I won't bite you.

I really do want to know.

Regards,
Simon

Hi Simon,

It is standard practice for me now. I was not involved seriously in the FSM system for maybe 5 years. When I went trough the recently HACCP I saw points that seemed very sensible but that lacked any reference to who brought them up and why.
I introduced again that for every point a rock solid reference should be available.
For instance if you would use polymers for packaging a reference should be made to the EU directive or local legislation, what directive and what page of the directive can the information be found.


Remember to share good fortune with your friends, Okido

Dear Simon,

Okido states it nicely.

I haven't picked out a specific example yet but the basis of using references such as Codex to validate CCPs and Critical Limits is illustrated by an extract from this link -

http://europe.ilsi.o...le/ILSIVali.pdf.

'To meet the objectives of validation it is necessary to critique (1) the supporting evidence used in the HACCP study and (2) the control measures, including monitoring and corrective actions.
1. Validation of the supporting evidence requires that evidence be provided to justify first the selection of the significant hazards and, second, the effectiveness of the proposed control measures.
Evidence supporting the selection of significant hazards may come from the scientific literature, trade associations, regulatory and legislative departments, historical data, professional bodies, or company knowledge. Evidence must be gathered for both the inclusion and the exclusion of all relevant hazards considered during the hazard analysis.
Supporting evidence is needed to show that the established target values and critical limits will adequately control the identified hazards to a level which meet company product safety requirements. This may be achieved using the same sources that were used for the selection of the hazards (see above) and by testing. Testing is the process by which proposals for control are positively tested for their effectiveness. Examples of testing include deliberate contamination, heat distribution and penetration tests, 100% incubation or inspection of production lots, and mathematical modelling of microbial growth.
2. Validation of the control measures is the reconciliation or cross-checking of the HAC'

Rgds / Charles.C

Thanks guys, that's really useful for me. The reason I wanted to know is an old client I helped develop a system for (BRC Packaging) had their HACCP system questioned by a VIP auditor. He said it should include references, and I suppose he's right. Thanks again for making it clear.

Regards,
Simon

thanks Charles

I assume you made a good point: a supportive evidence as a company knowledge it seems a lot of us are sometimes afraid to be confident with their system to put it in.

hi members

as Simon mentioned do you think we should put our forum discusion as a reference?

bibi

as Simon mentioned do you think we should put our forum discusion as a reference?

bibi

Sorry I missed your post Bibi; I wasn't actually proposing to use particular forum discussions as a reference. I don't know if it would be accepted or not, after all they are just discussions with opinions.

What do other [more] learned members think?

Regards,
Simon

I think, we can take example of pasteurization of raw milk. In my country, the ligislation requires pasteurization at 74oC for 15 sec. We take this as reference for validation of past. temp. for packed liquid milk.
Thanks,
Gireesh

Dear Simon,

Okido states it nicely.

I haven't picked out a specific example yet but the basis of using references such as Codex to validate CCPs and Critical Limits is illustrated by an extract from this link -

http://europe.ilsi.o...le/ILSIVali.pdf.

'To meet the objectives of validation it is necessary to critique (1) the supporting evidence used in the HACCP study and (2) the control measures, including monitoring and corrective actions.
1. Validation of the supporting evidence requires that evidence be provided to justify first the selection of the significant hazards and, second, the effectiveness of the proposed control measures.
Evidence supporting the selection of significant hazards may come from the scientific literature, trade associations, regulatory and legislative departments, historical data, professional bodies, or company knowledge. Evidence must be gathered for both the inclusion and the exclusion of all relevant hazards considered during the hazard analysis.
Supporting evidence is needed to show that the established target values and critical limits will adequately control the identified hazards to a level which meet company product safety requirements. This may be achieved using the same sources that were used for the selection of the hazards (see above) and by testing. Testing is the process by which proposals for control are positively tested for their effectiveness. Examples of testing include deliberate contamination, heat distribution and penetration tests, 100% incubation or inspection of production lots, and mathematical modelling of microbial growth.
2. Validation of the control measures is the reconciliation or cross-checking of the HAC'

Rgds / Charles.C