2.4.3.1 Food Safety Plan

Hi,

I'm the QA manager for a Spice Distribution company. We are a small business and our primary (and currently, sole) operation is to import spices from Asia and distribute them wholesale to food manufacturing companies domestically. We are looking to get SQF level II certified. The SQF modules applicable to us are Module 2 and Module 12. I'm very new to SQF, so I appreciate any advice, feedback, help, SAMPLES/TEMPLATES, anyone is willing to share with me.

I specifically have a question regarding standard 2.4.3.1 on the Food Safety Plan, which is a mandatory requirement. Is the Food Safety Plan essentially our HACCP plan? Can our HACCP Plan replace or serve as a sufficient fulfillment of this requirement or do I have to write an entirely separate document altogether? 

Furthermore, since we are a distribution facility alone for spices, we have no real identified CCPs, because all our risk factors are low or controlled for by our Prerequisite Programs. Therefore we have a HACCP program, but not necessarily a HACCP plan (according to the HACCP training I went to, there's a difference between the two, the latter involves CCPs while the former does not). However, it seems as there are some taboos in the industry against not having CCPs (which seems counter-intuitive to me, but that's another point), even though we really don't have one? Any thoughts on this?

Thanks

Hi Paxspices, I am a QA, albeit still somewhat green, at a Spice plant. We are certified level 2 currently and interested in moving up to level 3. In response to your question, I have to say, yes, 2.4.3 is, in fact, your HACCP Plan.

Sorry, I should have read the entire post before responding.

  In regards to your CCP query, Do you utilize a metal detector to ensure no foreign metals can be introduced? As a last point stopgap, as well as the only way to ensure this, it actually can be considered a CCP.

Hi paxspices,

From the SQF Glossary -

Food Safety Plan
A described in the SQF Code. It shall be prepared based on the HACCP Method, include process controls at control points in production to monitor product safety, identify deviations from control parameters and define corrections necessary to keep the process under control.

 

The above may be compared with the SQF Glossary definition of "HACCP Plan"

HACCP Plan  A document prepared in accordance with the HACCP method to ensure control of hazards which are significant for food safety in the segment of the food chain under consideration.

 

IMO, they are not quite the same (eg regarding  "control points", "significant". I am not a SQF user so I will defer to the latter to make the final decision.

(Auditing Guidance is also provided for this segment, although this is not binding on SQF Auditors)

With regard to yr query Plan / Program / zero CCP.  There are published differences in the interpretation of "HACCP Plan"  but  AFAIK,  SQF has these, IMO, unusually [for SQF] well-written, HACCP explanations/definitions -

HACCP Method  The implementation of pre-requisite programs and the application of HACCP principles in the logical sequence of the twelve steps as described in the current edition of the CODEX Alimentarius Commission Guidelines, or the current edition of the HACCP guidelines developed and managed by the NACMCF.  The SQF Code utilizes the HACCP method to control food safety hazards and other quality threats in the segment of the food chain under consideration.
HACCP Plan  A document prepared in accordance with the HACCP method to ensure control of hazards which are significant for food safety in the segment of the food chain under consideration.

 

From the above defs, it is IMO irrelevant if you have Zero or  >0 CCPs in yr HACCP Plan. This is a similar conclusion/consensus to that in this (general) parallel thread -

http://www.ifsqn.com...lan/#entry88123

Sorry, I should have read the entire post before responding.

  In regards to your CCP query, Do you utilize a metal detector to ensure no foreign metals can be introduced? As a last point stopgap, as well as the only way to ensure this, it actually can be considered a CCP.

Hi ehamilton,

Thank you so much for your response and help! No, we don't have any metal detectors because our bags already come packed and sealed. The sterilization and metal detection is done at our manufacturing plants in India, and the bags usually bear a stamp indicating as such. Our plants there are BRC and ISO FSSC 2200 certified. Furthermore, our prerequisite program requires that we have a COA for each lot we bring in. So that's why we identified no CCPs in our operations, especially because we don't really open our bags, unless we want to send samples or for re-testing...and in that case, we have a prerequisite program for how to handle that in a sanitary fashion (we still don't put it through any machines and it's done manually)...

Are you guys a spice manufacturing company or a do you primarily distribute as well? Would you recommend that we invest in metal detectors? 

Thanks again for your advice!

Hi paxspices,

 

From the SQF Glossary -

 

 

The above may be compared with the SQF Glossary definition of "HACCP Plan"

 

IMO, they are not quite the same (eg regarding  "control points", "significant". I am not a SQF user so I will defer to the latter to make the final decision.

(Auditing Guidance is also provided for this segment, although this is not binding on SQF Auditors)

 

With regard to yr query Plan / Program / zero CCP.  There are published differences in the interpretation of "HACCP Plan"  but  AFAIK,  SQF has these, IMO, unusually [for SQF] well-written, HACCP explanations/definitions -

 

 

From the above defs, it is IMO irrelevant if you have Zero or  >0 CCPs in yr HACCP Plan. This is a similar conclusion/consensus to that in this (general) parallel thread -

 

http://www.ifsqn.com...lan/#entry88123

 

Hi Charles,

Thank you so much for all the info and for going through the trouble of finding me the references to help answer my questions! I really appreciate it. I have been using, reading and marking up the SQF guidance document...but truth be told, I don't find it any less confusing (in fact, it probably confuses me more so)...for standard 2.4.3.1 though, when I was reading through the guidance document on that it seemed like it kept referencing HACCP and HACCP principles, so that's why I was wondering if it was basically the equivalent. I see your point though about where the two might differ. Although, on perhaps a more personal note that probably stems from some level of frustration, it makes me wonder why all these certifications even differ in these sort of seemingly minute details, when it seems like they're essentially asking the same thing? I feel like there needs to be a more efficient sort of standardization or overlap. That might be more on a philosophical level, and probably much easier said than done or even practical...but I don't know, it just all seems unnecessarily confusing.  

Hi ehamilton,

 

Thank you so much for your response and help! No, we don't have any metal detectors because our bags already come packed and sealed. The sterilization and metal detection is done at our manufacturing plants in India, and the bags usually bear a stamp indicating as such. Our plants there are BRC and ISO FSSC 2200 certified. Furthermore, our prerequisite program requires that we have a COA for each lot we bring in. So that's why we identified no CCPs in our operations, especially because we don't really open our bags, unless we want to send samples or for re-testing...and in that case, we have a prerequisite program for how to handle that in a sanitary fashion (we still don't put it through any machines and it's done manually)...

 

Are you guys a spice manufacturing company or a do you primarily distribute as well? Would you recommend that we invest in metal detectors? 

 

Thanks again for your advice!

Hi snethar,

     We are a spice blend manufacturer. In fact we procure quite a bit of raw ingredient from companies just like yours, and I concur with the confusion level inherent in deciphering the particulars from the generalities in the big picture. That's why I started another thread as well, to get more of an idea from those who have been there before.

     As far as investing in a metal detector, I don't know that I would go so far as to recommend it, as long as in your Supplier Verification Program all your potential hazards in this are addressed adequately. That, to my understanding, is almost solely in the eyes of the auditor when the time comes. Of course, include that potential in your Hazard Analysis.

     I agree with Charles C. on the irrelevance of a CCP, as long as every conceivable measure is in place to eliminate or reduce a potential hazard to acceptable limits. I don't believe you have to have one just for the sake of having one.

     I hope this helps some, and that you do all you are wishing in this area.

Hi snethar,

I specifically have a question regarding standard 2.4.3.1 on the Food Safety Plan, which is a mandatory requirement. Is the Food Safety Plan essentially our HACCP plan? Can our HACCP Plan replace or serve as a sufficient fulfillment of this requirement or do I have to write an entirely separate document altogether?

Following my post #4, i did a little back-searching and I agree that ehamilton's comment in post #2 is "spot-on" .

These quotes from SQF "experts"  are a few years old (ie SQF2000) but SQF is famed (notorious?) for rarely changing its spots   -

And yes, "to document a Food Safety Plan and that these documents be developed, validated, verified and maintained" means implementing a HACCP plan. Why SQF doesn't just say "HACCP" is beyond me.

 

http://www.ifsqn.com...lan/#entry42314

The Food Safety Plan is a HACCP Plan in plain English:

http://www.ifsqn.com...indpost&p=39420

Some analogous but more recent comments in these posts -

http://www.ifsqn.com...tes/#entry56654

http://www.ifsqn.com...elp/#entry65699

http://www.ifsqn.com...indpost&p=78638

It seems to me that BRC and SQF have at least one thing in common - they are both adept at disguising the actual objectives of many of their basic requirements.

One minor caveat to the above - I  think there is one instance here of an SQF user identifying  CPs on their  HACCP Flowchart  due the auditor's interpretation of  the Code's 2.4.3.1.v.  A HACCP Plan based on Codex could directly challenge such a request  IMO.

In response to your query, I agree with the others that your Food Safety Plan is indeed your HACCP plan, or at least the HACCP plan is the foundation for your Food Safety Plan, as well as your Pre-req programs.  

As for not having any CCP's, that is also acceptable.  If your pre-req's can cover all the risks and there is no point in the process that would be a "game-changer" then you are okay w/o a CCP as long  as you can show it is not necessary.  When HACCP first begun people believed you had to have CCP's and the more the better.  If you didn't ave at least one CCP how could you have a HACCP program?   But as time and use has shown, it is not necessary and sometimes can be a waste of time, money and products if something is considered a CCP when it is not. Think of all the downtime adn waste of products along with all the unnecessary documentation that would go along with an erroneous CCP.  So CCP's are not required as long as you can prove you have proper controls in place and can show you ship out a safe product.   

Thank you all!!! I really appreciate the time you've taken to provide me such detailed and thoughtful feedback. It really helped to clarify some of these nuances.

I think, for my part, where a lot of the confusion and frustrations stem from is trying to distinguish what needs to written down in words in a "policy" format, and what can serve as self-satisfactory evidence by just showing the auditor physically (not necessarily in reference to a Food Safety Plan, because I understand why that would need to be documented...but just in reference to certain other elements). I get that the whole principle behind SQF is "say what you do; do what you say; prove it" but to me, some of that principle lends itself to redundancy which can translate into inefficiency and frankly, impractical amounts of paperwork? Perhaps, I'm doing something wrong or misunderstanding something, and I don't mean to sound whiny, but I wonder if I'm the only one who may feel that way? Well either way, thanks for letting me share...

Hi snethar,

The fact is that, IMO, as illustrated by the threads in this forum, every Standard has its own white elephants, red herrings, and the brown stuff.

Sadly no-one seems capable of  producing an agreeably white composite.