Dear Charles
Thank you for your comments. Here are mine!
Dear dsherring,
Very interesting post. I assume that the ISO22k plan has been successfully audited?
Yes it has, but this was a secondary matter - the "icing on the cake". The main requirement among the senior management team was to realise food safety improvements and to generate a cohesive management system based on a recognised framework (improved food safety focus, efficiencies, communications etc.). Top management commitment!
You didn't mention if the company already had ISO9k2k? I guessed not. I half suspect that the "TOP MANAGEMENT" were simply in awe of the magic 3 letters whereas HACCP was something demanded by customers and getting the health authorities off their back all the time and therefore to be carried out at a minimum investment in staff and QA facilities. This is not unusual.
No, you guessed correctly Charles, they did not have a 9001 based system in operation.
My first reaction after reading the list was that something was seriously wrong regarding the HACCP System which pre-existed becoming involved with ISO22000. I can't see how points 1-5, 8 would not have been covered by a properly installed HACCP System.
1. A significant reduction in
metal contamination incidents/events, achieved as a result of enhancing their
HACCP process and using the conclusions from the
HACCP study to convince the senior management team to spend large sums of money in upgrading screens, sieves and
metal detection equipment.
But their
HACCP system had been based on Codex principles and had been approved by many regulatory (not certification) bodies. It suffered from the same flaws as many other
HACCP systems currently in place. It was not based on management system principles, it was owned by the food safety team only, it was not process based etc. .....
2. A greater and more widespread understanding of food safety issues across the company, through enhanced internal communication arrangements.
Internal communication is an area often not considered during audits and absent in many
HACCP "standards".
3. A widely understood and very well implemented corrective action process which actually prevents recurrence of food safety issues. (e.g. 5 Why technique is extensively used).
HACCP systems often prompt correction, not corrective action. Cause identification and elimination is often lacking from traditional
HACCP systems (and many
Quality Management Systems). ISO 22000 distinguishes between correction and corrective action.
4. A more effective change management system, that is preventive in nature and which interfaces very well with the
HACCP process.
The
HACCP system does not have to play "catch up" following changes to processes, products, materials etc.! This is now managed as one process that is part of a management system comprising many processes. It is not an activity-based event that the food safety team has to coordinate once they are made aware of the change, which is often some time after the change has taken place! Management controls are implemented that provide a prompt response (risk assessment) and review of existing control measures. Change management is often regarded as a weakness within
HACCP systems.
5. Enhanced focus on the "real" CCP's, enabling better control measure management. There is a clear distinction between
CCP's and OPRP's, backed up by a robust risk assessment and decision-making approach.
Previously too much reliance was placed on the Codex decision tree to generate
CCP's. This meant that a common sense and fact-based approach to decision-making was absent.
8. A control measure validation approach which gives confidence in the food safety controls implemented.
Too many assumptions had previously been made that existing control measures were effective, despite many process, plant and material changes over the years. The approach did not stand up to scrutiny. A disciplined approach towards validation has been introduced that gives the management team confidence and which has led to point 1 above. Again validation is widely reported as being a typical weakness within traditional
HACCP systems.
You don't mention the area of activity so speculation is difficult however I presume the original HACCP plan was successfully audited.
Only by regulators and not CB's. The organisation manufactures (microbiologically) low risk food products and the brand is globally well-known.
This should have included a detailed assessment of the validation of any CCPs.
Yes I agree, but historically there were no issues highlighted by regulatory authorities.
I think you are suggesting that ISO22k has now shown the audited HACCP plan was unsatisfactory.
Yes.
By the same auditor ?
No, by many auditors who, from what I gather, had no/little "management systems" understanding.
You refer to the newly determined "real" CCPs. Is it possible for you to clarify/example this comment ?
Yes - previously each
metal detector was treated as a
CCP regardless of where it was located in the process. In addition each detector had different sensitivities - i.e. they became more sensitive further "downstream". The last
metal detector was ultimately regarded as the 1
CCP. Also, goods inwards checking had not been regarded as a
CCP, i.e. to "control" chemical contaminants in raw materials that other "downstream" steps could not deal with.
It is certainly true that involvement with any ISO scheme immediately calls for a renovation of documentation related processes and an appropriately increased staffing ratio. Company refusal to provide for the latter can be quite effective in diminishing the presence of Quality Assurance on the production floor in my experience. This relates to your points 6,7 of course where this company seem to have a remarkably benevolent T.M. or excellent QA subversion techniques.
There was no increase in staffing and no paper mountain generated! The organisation wanted to learn from management systems best practice. "Food Safety Management" as distinct from "Food Safety Assurance" (akin to the difference between QM and QA).
Congratulations to QA either way!
Rather the Food Safety Team!
Please give some further feedback to this enterprising first post. I realise my post is a bit thin regarding specific ISO22k questions but other people will no doubt correct this balance.
Rgd / Charles.C