Correct my hazard analysis plan for Salt table industry

Dear friend 

i hope if you correct my hazard analysis for salt table industry

attached flow chart and HA

we have only one CCP (add of cynide) 

could you correct me if we have another CCP point 

ISO 22000 requires that when you come to Clause 7.4.3 Hazard assessment onwards you will need to decide if control measures for a hazard fall into the category of needing to be controlled through operational PRP(s) or by the HACCP plan.
Clause 7.4.4 Selection and assessment of control measures elaborates further:
The selection and categorization shall be carried out using a logical approach that includes assessments with regard to the following:
a) its effect on identified food safety hazards relative to the strictness applied;
b) its feasibility for monitoring (e.g. ability to be monitored in a timely manner to enable immediate corrections);
c) its place within the system relative to other control measures;
d) the likelihood of failure in the functioning of a control measure or significant processing variability;
e) the severity of the consequence(s) in the case of failure in its functioning;
f) whether the control measure is specifically established and applied to eliminate or significantly reduce the level of hazard(s);
g) synergistic effects (i.e. interaction that occurs between two or more measures resulting in their combined effect being higher than the sum of their individual effects).
Control measures categorized as belonging to the HACCP plan shall be implemented in accordance with 7.6. Other control measures shall be implemented as operational PRPs according to 7.5.

It isn't clear if you have considered these requirements in conducting your assessment.

It seems that you have decided that everything that is less than 6 is an OPRP and to me it seems that you have too many OPRPs and the lower risk (say scores of 3 or less) could be controlled by PRPs, for example storage.
 

Regards,

Tony

Dear msh3egy,

As an extension of the comments in previous post, I would like to see yr justification  for the decision process implemented in the last column. Do you have a link to the Procedure used ?

I should add that a similar but more discriminating approach (eg a  risk matrix)  was recently posted in another thread here. It may well be that this basic, 1-step, approach is being considered acceptable in yr auditorial locality but i would like to see the justification of such within the context of ISO22000/FSSC22000.

Rgds / Charles.C

PS - i am curious, but rather nervous to ask why you would add CYANIDE to the salt  ?

(added later - PPS) - not familiar with yr process but offhand I rather agree with later post #5 inasmuch as  all the typical hazards in yr process steps theoretically look to be controllable via appropriate PRPs, maybe with the exception of  "grinding". But I have no idea of yr GMP level / Product Specification.

It's more than likely sodium ferrocyanide (E535)  rather than cyanide gas!

Hello Msh3egy,

Salt does not support microbial growth, hence the only concern for your salt refining is toxic metals like mercury, lead, arsenic and heavy metals like copper,iron, etc should be of concern, impurities, and water insoluble matter and limits of ca, mg and sulphates and anti-caking agents and sodium chloride content as per your regulatory requirements of table salt.

Salt is also being iodated (40 mg/kg), hence microbial growth will not occur.

Moisture content is another factor to be considered from the caking point of view.

You should follow good manufacturing practices in your salt processing and water can be potable or brine water from sea of good quality.

The only CCP will be your Metal Detector

 Attached Some files-

Dear Sushil,

How about contamination / survival ?. I noticed the production process appears to be a "natural" one. (cf peanuts).

eg -

http://wiki.answers....ted_by_bacteria

I don't know / couldn't find the answer myself, not nit-picking. :smile:

Rgds / Charles.C

As you are receving this salt from rocks,you have to do heavy metal test once a supplier in a year.you have to mentions CCP and OPRP in process flow chart.Hazard that conrol in your further process can not be CCP .

For more guide line your are not defining the CCP limits and OPRP Limits.