I am trying to create a FSMA/ HACCP combined plan that would work for GFSI (SQF) while still meeting FSMA requirements/ terminology. After spending some time on it, my brain now feels more confused than when I started! Can all you experts out there critique my attached current format, and provide feedback on whether you think it meets the requirements of both?
What we have grasped/ applied: PRPs are programs to minimize low risk hazards, Preventative Control to minimize significant hazards, And CCP to eliminate significant hazards. We’ve also decided that any step that does not have a PC can’t be a CCP.
I am struggling with a few things:
1) The risk significance of a step not aligning with FSMAs need for a preventative control. EX- Supply Chain PC: For chocolate, our SCPC is approved supplier/ and COAs upon receipt. For our flavorings (like mint oil) they are considered low risk for growth, however we currently still put them through our approved supplier program. In the plan, if Approved Supplier is a PC for chocolate, would that automatically make Approved supplier a PC for flavoring (or all other ingredients) since we apply it to it already? or would we now state that approved supplier is a PRP even though they are the same program doing the same thing?
2) When trying to apply a decision tree “Is the hazard managed by the prerequisite programmes?” is now a more difficult question- does it now incldue PCs? Does it still make sense/ need to use a decision tree?
Also any thoughts on the format/ general workings of the plan welcomed and appreciated! As background we are a chocolate based confectionary company (do not make chocolate in house), who flavors/ adds additions for each product. Primarily hand made, except for two manually controlled depositer. All our products have milk/ soy in them- only allergen in one is pretzel. We pack into pre-printed tins.
Thanks in advance!