HACCP Form #4 Plant Schematic Question

Question - Our facility is two separate buildings (approx 180,000 sq ft) - but we have product piping to/from both buildings. Our product is liquor based, so very VERY low risk of any sort of micro or bacteria - and there isn't really a required pathway from raw to finished goods, as we have GMP throughout all our facility.   And within these buildings there is probably easily 25 miles of hardline piping running throughout, its a virtual liquor highway.

And the product moves from tank to tank depending on production needs, head space, blending, etc... so there is NO way I can say the wine all runs this one way, and my arrows to product flow would look like a child's scribble.

So what I had done was do a risk assessment on the traffic flow as well as the product flow and determined to have no restrictions of flow. And minimal risk of biological or physical hazards.

I do mark where we keep our allergens, chemicals, dry ingredients, employee enterance, bathrooms, incoming liquid location. Just not flow.  Does anyone else have a similiar product or layout, that you just can singly say product is a one way route.

During an internal audit it was found non conforming because I didn't have product / traffic flow directions, and I argued its impossible to indicate.

We are audited against Canada's FSEP requirements.  My BSI auditor has seen this form for the last 3 years, and its always been like this - the comment made by the internal auditor is wouldn't be okay by CFIA standards (but they have no idea - they are just happy to make a finding)

Thank you in advance for any assistance.

Hi Wine_QT,

I'm not intricately familiar with the CFIA requirements so forgive me if this isn't particularly helpful, but our site does have what sounds like a similar challenge in terms of flow/routing and how to define it (albeit on a smaller scale than yours).

If I understand correctly, Form 3 is the traditional HACCP process flow diagram, and Form 4 is more of an overall site and movement plan?

We have a few manifolds that are intentionally designed to be able to link various bits of the tank/blending systems in any order we choose, so there is no definitive "backward" or "forward" flow until you get to the final filling stage.
We use lines with two-way arrows that are colour-coded and link to the corresponding risk status / assessment parts. As the broad requirement of Form 4 seems to be around potential cross-contamination, and this approach could potentially satisfy that as you've clearly performed the relevant assessment and can demonstrate that it both adequately characterises the physical movement in the facility, and that there is no risk and/or they are suitably controlled.

Can't help with canada specifics. Bottled beverage plant here and have similar spaghetti piping. Our process flows are more schematic based instead of actually floowing pipes through the plant. never been a problem with the audit here. 

Ok, so I understand CFIA is good but your 3rd party audit doesn't like it?

It sounds like your auditor is confused if you're audit against FSEP only and it specifically says "flows" below...........so you need to put an ** in the legend of the plant schematic stating that ALL lines for food contact MAY run in EITHER direction

Form 3

3.2.3 Construct a process flow diagram and confirm its accuracy (Form 3) Flow diagram(s) shall be prepared for the product(s) or process categories covered by the HACCP plan. Flow diagrams shall provide a basis for evaluating the possible occurrence or introduction of and/or increase in food safety hazards. Flow diagrams shall be clear, accurate and sufficiently detailed. Flow diagrams shall, as appropriate, include: • The sequence and interaction of all steps in the operation from receiving to final shipping; • The introduction of ingredients and intermediate products into the process flow; • The introduction of product for reworking. The HACCP team shall verify the accuracy and completeness of the flow diagrams by on-site checking.

Form 4

3.2.4 Construct a plant schematic and confirm its accuracy (Form 4) A plant schematic shall be prepared for the products or process categories covered by the HACCP plan. Plant schematic provides a basis for evaluating potential areas of cross-contamination by pathogens, foreign materials, chemicals or allergens. Plant schematic shall be clear, accurate and sufficiently detailed. Plant schematic shall at least include: • The flows of raw products, ingredients and finished products; • The flows of packaging materials; • The employee traffic pattern throughout the establishment including change rooms, washrooms and lunchrooms; • The flows of the waste, inedible products, chemicals, and other non-food products that could cause cross-contamination; • The hand/boot washing and sanitizing installations.