Hi Marshall,
Many Thks for above documents. A very elegant response to the, IMO, occasionally strangely worded FSMA haccp requirements. The text in cells S9, S30 looks particularly offbeat to me but “it is what it is”. ![:thumbup:](https://www.ifsqn.com/forum/public/style_emoticons/default/thumbup.gif)
A few mini-observations in the nice Excel –
(1) microscopic typos - “signuficantly” / cell AG1, Aereus in H225, H234, Monocytogenes everywhere. Noted
(2) I noted that FDA have taken haccp back to Codex origins by inserting “sig.minimize” in AG1. Apparently
(3) IMO the “x” in cell AG48 is placed in the logical selected position. But is therefore the term “finished product” referring to the received packaging rather than the process ending packed goods ? We verify each new lot of packaging at reciept, but also check the packaging on the production line as a double check.
(4) No specific examples of “typical” potential Biological contaminants in inputs are mentioned, eg Salmonella. Rather surprised FDA went (textually) along with cell S9 in Principle. (also seems sort of illogical in view of cell S189). I see your point, but with the sheer numbers of raw materials that we have, an inclusive list seems impracticable in the form. We have a complete HA of all raw materials, so that information could be found there, if asked.
(5) Legionella apparently does have a history of occurring in potable water. Interesting. That's what I found. How common, is another thing.
(6) I note the partial pragmatic acceptance to regard baking as a “CCP” I don't honestly think it is (at least for our products), but FDA expects companies to treat it as a Preventive Control IF there is the possibility of Salmonella in raw materials.
(7) Cell A280, column (2) does not include “….economic gain…” as stated. (I noted VA is cross-referenced in Word document). Correct. Complete VA for all raw materials is a separate document that can be referenced as needed.
(8) I deduce from, afai could see, a lack of mention in either document that you are not expected to possess any verification documentation that the City water is maintained potable ? (I recall a certain US piping disaster). I don't recall any specific FDA requirement/guidance on that point. However BRC requires it so we have the annual water report from the city on file.
Thks again.