8 replies to this topic

[Angus]

Hello,

Is it common practice for HACCP analysis to cover process steps only, with the incoming goods grouped as one step being addressed by PRP -> RMS & QC testing regime? Just thinking of a factory that produces a number of products with common RMs.

Thx, in anticipation
Toni

[GMO]

I have started to see more and more of incoming goods risks being considered. Failure to do this in some form (whether you chose to have it as part of your HACCP plan) can lead to disaster. One time we were launching a new product which contained raw, ready to eat ingredients. Due to how busy the factory was, I was told to leave that project to my boss. Unfortunately, the boss didn't consider the risk of ingredients so we had herbs which were not meant to be ready to eat going into a ready to eat product! I discovered this just in time; however, this meant the costing was wrong on the product.

The other thing to think about is the supplier isn't necessarily checking the hazards for you. If you use creme fraiche as part of a cooked sauce, you won't be as worried about the micro as if you were using it in a salad dressing. The supplier doesn't necessarily know what you are using their products for.

I wouldn't assess all ingredients separately, I'd group them, e.g. washed vegetables, dirty vegetables, raw chicken. You can then assess easily what the hazards are, whether there are any special cases (e.g. celery allergen or higher risk of bones in chicken thighs) and use this as a basis for the supplier specification going forward. It will also help you to decide whether you need to positive release any ingredients coming into the factory based on results. It would then be really useful for auditors to know the expectations from the supplier in this hazard analysis, preferably before you launch but at least during routine audits.

I would start this with new product launches and gradually backdate if you can.

[Angus]

GMO,

Thx so much for your comments. My question is theoretical - just trying to clarify my thoughts.

Taking into account your comments, do you think the following would be acceptable (for ingredient risk assessment) from a HACCP pt of view:

1)RMS (internal not supplier) with our requirements covering phys, chem & micro criteria & QC testing regime

2)RMS include list of all Finished Products in which they are used ( so must met requirements for most risky product/process) (this pt would be confid)

3)RMS reviewed by relevent "experts" ie micro, chem, process, prodn.

So in HACCP Plan you would simply have to "tick the box" that all ingredients have gone down this review path.

Thx
Toni

[GMO]

I don't quite know what you mean (what is RMS?) but I would say the biggest control for all raw materials is your supplier and if necessary they should provide a certificate of analysis which is checked prior to use if you identify the risk is high enough. Obviously once the ingredient arrives, you need to check packaging integrity and pallet for lack of damage (physical) and keep the product stored in undamaged packaging. Also consider storage of allergens (e.g. in labelled bays with identified utensils etc) but after that any chemical or micro testing should only be as a verification exercise.

I've never thought of going as far as listing what products an ingredient is used in; if you have a computerised recipe system, that would be quite easy and useful. It's probably a really good idea to do if you're doing a thorough HACCP review.

Any HACCP process should be decided upon by relevant experts. I don't understand that.

[Angus]

GMO,

Thx again for your feedback.
RMS -> Raw Material Specification (internal)

Toni

[GMO]

Thanks Toni. Obviously having a dumb moment! I wouldn't worry about putting what an ingredient is used in on the raw material spec because you would normally need your supplier and you to sign it and as you launch new products, they will forever be getting out of date. I'd just retrospectively look at it during a HACCP meeting, as you said, you could do the prep first and highlight the most risky products but then going forward, I'd look at each new process in turn and highlight any concerns.

[Charles.C]

Dear Toni,

As stated in the original post, the most convenient option will relate to the number of individual plans involved. It also relates to the complexity of mixed ingredients including things like spices, antioxidants etc. Personally I always preferred to detail the ingredients at the beginning of each haccp plan (somewhat similar to the many examples on the cfia website). However I do agree it can become laborious for, say, >10 plans. The possibility for creating a master list of specs as you mention with subsequent use of cross-references will depend on the exact situation and raw materials IMO. I think also that most auditors will expect a reasonably accessible layout so as to avoid too much “hunting” around the side lines.
(A similar difficulty arises with the question of allergens in raw materials. Some haccp’ers prefer to set this as a one-time prerequisite procedure for raw materials control while others treat it within the individual plans.)
Hopefully, although haccp presentations often require considerable initial thinking, the basic steps soon become relatively routine unless you are working with complicated and/or high risk scenarios.
Some of these issues are considered in the two, quite detailed, examples of (general) haccp manuals below -

 haccp_manual_material_1.pdf   1.12MB   281 downloads
 haccp_manual_material_2_.pdf   1.89MB   209 downloads
 haccp__dutch__animal_feed_manual.pdf   1.59MB   109 downloads


Rgds / Charles.C

[Angus]

Thx GMO & Charles C.
I look forward to future "cyber-chatting".

The attachments look like they contain alot of valuable info,thx Charles C.

Have a nice wkend!
Toni

[walabies]

What I humbly think is that if your RM that will have adverse effects on your Finished product, (no post processing that could eliminate the hazards), it should be your CCP and some solution to take out the hazards. COA from supplier is good but it isn't foolprove.