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Charles Chew

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Posted 07 August 2004 - 09:12 AM

Hi,

Recently had some differences in opinion on the way a HACCP Plan should be structured given the HACCP knowledge that we know........but at the end of it, we concluded that we were both right and wrong.

Because HACCP does not currently have a SINGLE international audit standard (unlike ISO), every body does things differently which complicates matters. Auditors almost always have a field day and sometimes play "God" too.

We told ourselves, enough is enough. For those who are starting out on a new HACCP program, we suggest that you keep it VERY VERY simple. It not about what you know BUT rather about managing what you know. A true auditor will only audit to what you state in your plan. The more complicated your Haccp Plan is, the more complicated your audit will be and vice-versa.

Our advice is to avoid implementing complicated issues when they can be avoided like coming up with a Critical Limit of Microbilogical Standard of 5 log reduction when this is only a validation issue.

Some of the issues that were brought up in this forum sometimes frightens the wits out of me. I hope monitoring these " huge issues" will not drain the morale of the staff .........it can be really trying.

Regards
Charles Chew


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Simon

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Posted 08 August 2004 - 07:26 AM

You're Charles HACCP can be daunting. As a quality manager for a food packaging company I first heard of HACCP back in 1998, 3 years before BRC/IOP. At that time we had most of the prerequisite procedures in place but our system wasn't based on risk assessment, it was based on requirements borne out of customers audits.

Following the Food Safety Act 1990, UK food producers began to implement HACCP systems widely, and they were only too pleased to let us packaging folk in on the secret during audits. At one audit an auditor from a very large UK dairy spent about three hours trying to explain the intricacies of HACCP to me. I remember being completely baffled by P, M, C and CCP's and being totally put off. Little did I realise at the time the basic principles of the methodology are actually quite straightforward.

If HACCP is becoming a requirement in your industry either through customer pressure or regulatory, and you are feeling a little daunted, don't worry there's plenty of free, expert advice available right here on the forums. We may talk highbrow stuff from time to time but we are reasonably normal. (I fear I may have set myself up there).

Regards,
Simon


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Charles Chew

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Posted 09 August 2004 - 09:14 AM

Simon,

Daunting is an understatement for the novices but your past experience is an example of how a meaningful relationship with a practical and sensible food auditor can paint a totally different picture about HACCP.

Implementation is but a whole bunch of rubbish theory rendered useless without first understanding the applications let alone maintaining the system.

Charles Chew


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Charles Chew

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Posted 17 August 2004 - 07:26 AM

Hi,

I am surprised that the forum has not taken this subject beyond the importance behind keeping a HACCP Program lean and simple.

There are definitely a lot of issues on this topic which can be used to trim down the responsibility of unncessary documentations. Since, no serious discussions were made, lets throw in a couple of examples:

1. What would be your control criteria if you need to store (frozen product ) at a certain temperature prior to loading to a reefer? Is this process a CCP?..............

2. Would you set microbiological standards for your products?

Tip: A HACCP program is only a system that allows you to place controls over critical processes. The aim is NOT to achieve microbe-free products but one that ensures that all efforts had been made to make the product as safe as posibble.


CharlesChew


Edited by charleschew, 17 August 2004 - 07:27 AM.

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Simon

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Posted 17 August 2004 - 08:50 AM

‘Lean HACCP'

It's got a real nice ring to it - I'd get a patent on that one pretty quickly Charles.

Come on foodies get stuck into the HACCP discussions!

Regards,
Simon

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Charles.C

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Posted 20 August 2004 - 07:37 AM

Dear Charles Chew,
No.1
(No mention of product variety, intended usage etc. Assumed not high risk.)
Cold Room product core exit temp would hopefully be not > -18degC
Depends on product / packaging but typically, total lot transfer time into precooled 20foot container not > 30mins
Again depends on product / packaging but typical control temp. during transit not >-14degC, (or average with some tolerance depending on sampling etc) - shippping companies vary in my limited experience, at one time BC (before computers) I used to commonly see the certification 'visually hard-frozen', mostly it seemed to work ok.
Not a CCP, risk analysis for BCP (sensitive B area >> -14degC) would be of the form R = (very low) x (medium/serious), = not significant enough for CCP

No.2
Yes but I would never be brave enough (or foolhardy enough) to call them standards.

Not sure if this answer correlates to yr tip, feel free to pick to pieces.

Regards
Charles.C


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Charles.C


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Posted 20 August 2004 - 11:41 AM

Hi Charles

Yes, you can safely assume that any products that require to be stored frozen is at high risk when storage temperature is significantly severed. Lets assume the product to be forzen "fish fingers" packed in an inner box with corruggated cartons as secondary packaging shretched wrapped.

What do you think?
1. The reefer may be pre-cooled but the reefer door has be to be opened several times before its is fully loaded this would therefore subject the goods to external thermal heat hence the internal reefer temperature would drop severely each time the door is opened for loading. 30 minutes may be the recommended accumulated loading time BUT I wonder if the frequencies of loading should be seriously considered. Also wonder if the drop in the reefer temperature be severe enough to cause safety issues :uhm:

However, unless you are using a "special cooling system" that drops the temperature of the reefer container almost instantly each time you need to re-instate the reefer internal temperature (Think there is one known as Polar Cool from BP Group, UK), could there be an issue we should look at.

2. Lets say you are prepared to set Microbiological Limits instead of Standards (Charles, they mean the same, really), do you have a validation system that will prove that each single one of your packed product meets the microbiogical limit that you have set. Random test results will not do because random tests are meant confirm the validation of your process controls BUT here instead, you will need to prove your M. Limits of your products. How would you do that?

Charles, your comments, please

Regards
Charles Chew


Edited by charleschew, 20 August 2004 - 11:43 AM.

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Charles.C

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Posted 21 August 2004 - 08:58 AM

Dear Charles,

This is not exactly a small topic Charles, still I did ask for it so I won't complain. Not yet anyway.
I noted your cautious use of 'significant' in opening paragraph. Did you actually agree or otherwise regarding CCP status assuming fish finger product ?

No1
I fully agree with yr reservations regarding temperature swings however I can only offer from empirical experience that previous guidelines seem to work. Must admit I am not very knowledgeable on detailed reefer systems. Sorry. For products like you refer, I suspect the ultimate customer may often see more noticeable changed characteristics as a result of the final distribution / handling / preparation chain.

No.2
I confess I hate the word validation. If you search the meaning of (validation vs verification) in Google, prepare to be confused (at least I was/am).
I prefer micro.guidelines to standards. Alternatively I think Codex prefer 'microbiological criteria' (bit soft maybe) for reasons as given in their 'Food errgh Standards Programme.'

Yr question/s - it all depends, as usual.
I presume you mean safety related entities. Strictly one needs to split into (at least) zero- only / non-zero acceptable scenarios. (Ignored resampling options)
Extreme example / zero- only acceptable (ZA) - does canning ensure that every can is free of clostridium botulinum? Statistics guarantees no, even under best of adherence to procedure. Canning not really my field but I guess validation of process is statistical based on short / long term sampling results (epidemiological incidents). Validation of product same I would think, you cannot effectively sample at such low expected levels except for gross errors.
ZA frozen food - similar to above except sampling now has better chance depending on species / lab.resources etc but a single negative result not very statistically meaningful (unless you happen to be resampling from a positive detection, --> joy).

Non-zero acceptable -
As a chemist I still remember being shocked when I discovered the typical variabilities of bacterial estimates / sampling accuracy of foods (not only foods) / varied interpretations of bacterial numbers (welcome to the ecological world) (Hence some of my reservations re standards). Marginal failures are thus effectively promised by nature (not to mention the occasional outlier) and do not invalidate the system unless you observe 'too many' gross failures in my opinion. This is food, not a brick.
Where necessary to offer some limit, available published standards (and their reasoning) vary enormously from semi-sublime to semi-ridiculous. Study them. IMHO the most enlightened will usually be the most fair to the producer. Test their statistical applicability over successive lots and, if ok, be prepared to defend them. If not ok, change the process / raw material or keep looking.

I hope you have not thrown these queries out before in a different thread (jam story ?) and are now chuckling away.

Regards
Chales.C


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Charles.C


Charles Chew

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Posted 21 August 2004 - 10:57 AM

Hi Charles,

I think we are both doing this simply bacause we are in a forum. As we stand to be corrected in our contributions, participations from others could help all to look at these issues at different angles.

No. 1 - Refering to the reefer loading - I do not think this is a Critical Control Point for any products. I would look at this as merely a monitoring activity although it is undoubtedly an important monitoring section of the internal food chain. Products for distribution is often stored at sub-zero temperature and the transfer time / frequencies to reefer is generally not long enough for products to degradate and encourage re-proliferation of pathogens. (Outer cartons and inner packaging help to insulate). Consider the event of a refrigerated truck that breaks down during distribution, the product would most likely be pegged against tested "insulation tolerance" while further degradation beyond the tolerance level would subject the product to be investigated.............unles the obvious occured. (Products in a broken down refrigerated truck if well insulated and kept closed can be kept for quite some time. Need to get the figures if you need it)

On this, based on my experience with associates, the real issues behind temperature controls on reefer containers (cannot be controlled) and especially so, refrigerated trucks (can be internally controlled) is really about capital investment and maintenance costs in maintaining a cost-effective logistic supply chain. Everything assumed to be within control tolerance, temperatures do not drop to siginificantly low level fast enough under normal circumstance to be a threat. As such, it is only a monitoring activity and not a CCP.

No. 2 - Is an area where I would certainly want to keep lean and simple. Charles, it is very difficult to comply to M. Standards or Limits. Once we set our critical limit of our products to M. Std. we have to prove every single unit of our finished product to meet that standard that we have set.

Why don't we set the pH Critical Limit, Aw CL or the Temperature / Time CL and make the hazard plan around process control rather than through Microbiological Control. Our validation activities (that you hate most) is now kept lean. Laboratory tests on M. Parameters only need to prove 5 log pathogen reduction and specific pathogen tests under your test parameters be negative or between your tolerance or otherwise, further specific tests have to be conducted.

Yes, I agree that it is NOT possible to guarantee that canned foods are free from Clostridium Botulinum or others even with the best of controls. As a matter of fact, HACCP is not about "safe foods", rather it is about placing effective and valid controls along your critical points of your internal food chain to ensure that foods manufactured from your facility is deemed as safe as possible and within the expectations of your current food safety program.....otherwise, Charles, I would not have to deal with the problem I have on my Kraft Mayo Complaint.

So, I believe if there is a better way to manage our HACCP program, why not. Therefore, on a lean approach, I would certainly look at CL on process controls rather than M. Standards.

I recently have to deal with a beverage product that is not subject to heat temperature process. This would be a night mare if we were to deal with it using the M. Standard approach but we did not.

Charles, thanks for the issues raised. .......not chuckling away :thumbup:


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Charles Chew


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Charles.C

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Posted 22 August 2004 - 02:45 AM

Dear Charles,

Sorry sorry, didn't mean to raise the hackles. I really do agree safe food is a serious business. I have great respect for my stomach's well-being. I was rather trying to point out that some of these cross-functional terms are apt to mean different things to different people. For example, from my/yr posts we probably don't fully agree with the interpretation of validation as applied to bacterial limits but that's ok if we know what each other means.

Despite perhaps a little bias from being a producer, I stick by my opinion that microbiological numbers are frequently misused / misinterpreted for control purposes (particularly legal ones) for both low and high risk products.

Regarding the micro. I think we were maybe not quite talking about same objective. I thought you had asked me to make the case in support of validating (now you've got me using it!) microbiological controls for a low risk product (like fish fingers which requires complete cooking by consumer). My answer was designed to indicate not necessary (or, to put it more aggressively, to show the futility thereof). I probably confused the issue by talking about canning.
At least we seem to agree that low risk products shouldn't involve microbiological numbers. High risk is maybe a different story ?

BTW I wouldn't have touched your mayo either.

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Charles.C


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Charles Chew

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Posted 22 August 2004 - 03:08 PM

Charles,

Minus the little differences in opinion (which I honestly still do not know what it is), good to know that we are both on the same page on everything else.

Anyway, just to make life simple for all on the validaiton issue, I have posted I think either in this section or the "document exchange section" a great document that explains the differences between validation and verification

Charles, I will be away for a week Monday onwards and would not have access to a computer. We will touch base again, soon......because you have raised another BIG ISSUE....concerning abuses and the legality of HACCP documentations.

Regards
Charles Chew


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Posted 22 August 2004 - 08:18 PM

Hey guys, you lost me when the reefer pulled into the dock. :P

It has been very interesting following your tete-a-tete. Does the fact that I've found the conversation a little difficult to follow indicate my lack of knowledge or maybe in contrast to the title of this thread HACCP isn't quite so simple - possibly a bit of both.

Regards,
Simon


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Charles Chew

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Posted 23 August 2004 - 03:47 AM

Hi Simon,

The reefer has not pulled into the dock yet but thats the other problems when you have an electricity failure and the temperature is reaching "melting point".....but thats another chapter.

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CharlesChew


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Posted 23 August 2004 - 01:14 PM

Dear Simon / Charles Chew,

Difficult to follow indeed, this from a man who believes QM can be sexy.
How about a new thread, HACCP for the newly weds ?

Apologies for humour, I know this is serious and look forward to further chat Charles Chew.

Proposition : HACCP = GMP + Risk Analysis (for BCP at a minimum)

Do we think GMP is simple ? Risk Analysis ? Food Science ?

Well it's simpler than ISO anyway.

I really wish I could supply an instant template for generating any HACCP plan (never mind a lean one) but so far, inspiration fails me. One constant limitation is that a given product type can be so different to another. What we need is an ISO version of HACCP which will presumably then turn out like 9001.

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Charles.C


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Posted 23 August 2004 - 01:15 PM

Difficult to follow indeed, this from a man who believes QM can be sexy.
How about a new thread, HACCP for the newly weds ?

<{POST_SNAPBACK}>

:roflmao:

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Posted 24 August 2004 - 08:31 AM

What we need is an ISO version of HACCP which will presumably then turn out like 9001.


Hi Charles, actually we have an italian standard for HACCP coded as UNI 10854.
No added value though.

An ancient Chinese proverb teaches that the person who waits for a roast duck to fly into their mouth must wait a very long time.

Charles Chew

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Posted 27 August 2004 - 02:23 PM

actually we have an italian standard for HACCP coded as UNI 10854.  No added value though.


Dear Franco,

Each country who is a member of WTO establishes it's own food safety standards under the WHO/FAO's HACCP Principles guidelines & Codex RCP. There is no added value because it is designed to be a common harmonized standard which allows each WTO member country to recognise each others HACCP certification (which is aligned to a recognized accreditation body) on a country to country basis. Private CB that is aligned to AC is equally recognized.


Dear Charles,

I am back. The ISO version of HACCP is indeed ISO 22000 which is currently under discussion in this forum but it would remain a stand alone standard unless adopted under WTO for international trade. Otherwise, requirements would be, I believe, country specifics. Charles, if you need details on DIS 22K, pls let me have yr email address.

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Charles Chew

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Posted 28 August 2004 - 06:18 PM

Excuse me guys...Ummm

When I started with this HACCP thing in my previous employment, I learnt it would cost a lot of money to get it done. First, it was approximately US$1300 per head for a 3-day intensive course. Then, we have to upgrade all equipments, etc.
Anyway, my previous employer spent no less than US$37000 to get 25 certificates (renewable every 6 months) only for the contract food concession in a theme park.

Question: Does it mean the simpler the HACCP project is, the less money u will spend on it? :uhm:

Regards,
Paul....



Charles Chew

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Posted 29 August 2004 - 05:03 AM

my previous employer spent no less than US$37000 to get 25 certificates (renewable every 6 months) only for the contract food concession in a theme park.

Hi Bro,

Thats a lot of money yr previous employer is paying on a six-month renewable basis. I do not understand but suspect that it could be for the licenses that he is paying for. If not, the certificates must be subject to every six-month survellance audits......think the later sounds more real!

Anyway, why 25 certificates and what are these certificates for :uhm:

Does it mean the simpler the HACCP project is, the less money u will spend on it?

Sorry if I had misled you but what I really meant was if you keep your HACCP Plan and System lean and simple, it would be better managed, sustainable and be understood by all staff to play a coordinated role for future and continuous improvement.

Rather than having a beautifully detailed set-up with procedures for mundane validations (sorry, Charles) and massive verifications that get everyone on their nerves, the chance of having this system sustainable is slim UNLESS you have all the human resources and system MATURITY to deal with such levels of commitment which often takes years to reach, you would be better off to have a simple but well managed system.

COST of IMPLEMETING a HACCP SYSTEM-
That depends whether you are doing it with your team internally from scratch or whether a Consultant is engaged.

On the former, if the team has the resources and knowledge, why not. Otherwise, if yr. employee can afford it, you are better off with a Consultant.

On the latter, choosing the right consultant with an effective approach is essential to cut cost while, the quality and commitment of the Team is relevant to cutting down implementation time as well.

Bottom line is the cost of putting up a HACCP system is probably cheaper due to shorter implementation time on the assumption that quality and commitment is in place. Every system takes time to build to maturity and HACCP is not only NO different but essential and relevant.

I hope this answers yr. questions. If not, feel free to comment.

Regards
Charles CHew

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Charles Chew
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