NSF Supplier Assurance Audit - Missed Radiological Hazard
Hello,
We recently went through our yearly NSF Supplier Assurance Audit. This year the standard had changed and now they require the following:
The standard in NSF 2.1 states that
- The HACCP team shall prepare a list of all the hazards (chemical, physical, biological, radiological or other) that may be reasonably expected to occur at each step, from raw material receipt, processing, manufacture, storage and distribution until the point of consumption. Evaluation shall include all ingredients, equipment, processing steps and packaging materials.
We are not required to be compliant with FSMA so had not assessed this.
The Preventative Controls for Human Food regulation defines hazard as any biological, chemical ( including radiological) or physical agent that has the potential to cause illness or injury. Chemical hazards include food allergens, mycotoxins, toxic chemicals, radiological agents etc.
I have read through some other posts on this and I see that radio logical is included under chemical. The way the NSF standard reads it sounds like it is to be pulled out ( its own column) and assessed at each step.
I am just wondering if there is anyone else who has gone through this audit and how did you approach the radiological hazard?
When I updated my plan to be FSMA compliant, I put a note in the plan that says that chemical hazards include allergens and radiological hazards. I know that doesn't really make sense but the auditors accepted it.
When I updated my plan to be FSMA compliant, I put a note in the plan that says that chemical hazards include allergens and radiological hazards. I know that doesn't really make sense but the auditors accepted it.
I was wondering if that would be acceptable or not. It seems like the easiest thing to do. Good to know it worked for you!
Did you put the note onto your hazard assessments page?
I have like a text description of the whole program and a part of it says something like 'In compliance with requirements, a hazard analysis was conducted on all ingredients and packaging as well as each process step. Threats addressed include physical, chemical, including allergen and radiological, and biological.
Then in the actual hazard analysis excel spreadsheet portion at the top it says P = physical C = chemical (including radiological and allergen), B = biological and then in the table I have a box for P, C, and B for each step / item