BRC Food Packaging, Issue 6 - 2.2.6: HARA Assessing New Hazards

Hi All,

I'm currently trying to redevelop my HACCP plan and include the new hazards Issue 6 is requiring me to identify. 

2.2.6 - The HARA team shall identify and record all potential product safety hazards that are reasonably expected to occur at each step in relation to the product and process. The hazards considered shall include, where relevant: 

• Microbiological hazards
• Chemical Contamination
• Potential for unintended migration of substances from the packaging material into food or other hygiene-sensitive products
• Foreign Objects
• Potential problems arising from the use of recycled materials
• Foreseeable misuse by the consumer
• defects critical to consumer safety
• hazards that may have impact on the functional integrity and performance of the final product in use
• potential for malicious intervention 
• potential for raw material fraud

I'm trying to figure out how to address each hazard versus my current HACCP format.

Am I headed the right direction (see attached template for Receiving and Storage of Raw materials) 

I addressed each new hazard under Biological, then Chemical, then Physical. 

Am I overthinking it? Should each be its own hazard in its own?

thanks,

DNQAMGR

Hello there,

The HACCP plan I inherited was first put together for an annual AIB inspection and listed only the three hazards (chemical, biological, physical).  When my company moved forward with certification to the BRC standard, I did a complete overhaul.  Instead of listing all 9 hazards from issue 5 (and now 10 for issue 6) for every process step (we have 70+), I created a document in which I break down the 9/10 hazards into the 3 groups (chem/bio/phys) as best as I could, so as to not make our actual hazard analysis more of a brute than it already is.  On the same document I left a caveat for a few (like issues related to functional integrity) that in the absence of it as a line item, the team assessed no risk and would only add it for the steps where a possible risk existed.  Our auditor for the past few years was ok with this though we usually had to speak to it a bit to show that we had put enough thought into each of the 9 hazards.  This summer we'll see if a new auditor is ok with this as well!

Hope this helps.

This looks like it addresses the specific hazards called out in 2.2.6. Since it's capped with "Where relevant", no action is needed if there is no risk associated with that specific hazard. You could list the "class" of hazard then mark those with "no risk identified" or "not applicable" as needed. As long as you give your reason for no hazard present it proves the assessment was performed. You want to identify any and all risks possible even if the occurrence or severity are very low. So you did the Hazard analysis now you need to analyze each hazard identified in your HACCP plan and risk assessment. Ours are pretty much the same. You should have all the hazards identified, just determine the risks. This whole addition has been a little confusing to me too. You are basically just copying part of your HACCP plan and formatting it a little differently. In your HACCP plan, following the steps, you have to do a risk analysis of each identified hazard right? So you should have done a risk assessment when completing the HACCP plan(s). Our all show the progression through the "risks associated" with the steps in the process. Hope this doesn;t make it more confusing but, honestly, there's already a lot of confusion built into the code.

Hi All,

I appreciate both your help, and it seems I'm over thinking it. 

You are both right about the new required defined hazards being applicable or not applicable for each process step I have. 

I'll address the new hazards as it is applicable and risk associated to my process. 

thanks again!

DN

Hi... 

This is my first post.. Wanted to know if someone can help with list of risk analysis to be made for BRC Packaging issue 6. Or may be list of clause against which risk analysis is required. 

Thanks in advance ......

I could list the risk analysis required to below list. 

• 2.1 Hazard and risk analysis – product safety
• 3.3.4 product lifetime for record retention
• 3.4.3 statement of compliance review frequency
• 3.4.5 specification review frequency
• 3.5.1 internal audit frequency
• 3.5.5 GMP inspection frequency
• 3.7 supplier approval and monitoring
• 3.8 vulnerability assessment
• 3.9.2 outsourced/subcontracted processes
• 3.10 approval and monitoring of service suppliers
• 3.13.1 traceability (where traceability can’t be focused down to a small batch)
• 3.13.4 what constitutes an incident
• 4.1.1 local activities and site location
• 4.1.3 building fabrication to prioritise actions
• 4.2.4 glass windows to determine if is protection needed
• 4.2.5 glass items to determine protection requirements
• 4.2.6 elevated walkways
• 4.2.8 ventilation
• 4.3.1 water
• 4.3.2 product contact steam, ice, air and gas
• 4.4 threat assessment
• 4.5.2 product process flow
• 4.6.2 new equipment maintenance
• 4.7.4 maintenance activity
• 4.8 hygiene and housekeeping tasks, methods and frequency
• 4.8.5 environmental monitoring
• 4.9.1 glass, brittle plastics, ceramics and similar materials
• 4.9.3.2 biological control
• 4.10 waste movement and flow
• 4.10.2 process waste
• 4.11.2 pest management scope and frequency
• 4.11.6 infestations
• 4.11.7 following an infestation
• 5.1.2 product trials
• 5.3.1 printed packaging
• 5.4 quality and integrity hazard analysis
• 5.5.2 measuring devices accuracy, calibration and corrective action
• 5.6 product inspection
• 5.8 incoming goods inspection
• 5.9 storage
• 5.10.2 transportation of materials
• 6.1 agency training verification
• 6.2 personal hygiene
• 6.3 staff facilities
• 6.4 medical screening
• 6.5 protective clothing

Help needed to verify and mention if any risk analysis can be combined

Thanks in advance .....

If one doesn't mind generating an encyclopedic hazard analysis, direct copying of the Code's list of "necessities" is presumably "unattackable"  in an audit.

But, JFI, here is a, IMO, rather neat example of a, previously posted, condensed-type hazard analysis format for the somewhat simpler world of  BRC Packaging ver 3.  Uses same basic ideas as in Post 2 although BRC's expansionist thinking has currently succeeded in making a mountain out of a molehill. (The details in example applied to a specific, relatively low-tech scenario rather than a sophisticated setup).

BRC Packaging ver 3, Hazard_Analysis.doc   74KB   671 downloads

PS - In addition to the above structured Hazard Analysis,  procedures and controls exist which have been designed to address non specific hazards resulting from the operation, building, raw materials and staff. These are defined as Pre-Requisite Programmes

(IIRC the appearance of pests in hazard analysis was a result of a specific, local, environmental difficulty).

PPS - just for clarity, here is the risk matrix -

BRC packaging ver 3, risk matrix.doc   32KB   645 downloads

Thank you for the example. This was similar to how I pictured it, though it philosophically reverses the templates we received from AIB, albeit many, many years ago. In the templates used to build my site's HACCP plan, each step had every hazard group listed (use to be 3, now 9) which made it clunky.

Nick

Crikey Charles, you do trawl the archives!

Ref. the original post, what type of products do you make?

Crikey Charles, you do trawl the archives!

 

Ref. the original post, what type of products do you make?

Hi Foodworker,

Just saw yr Post.

Thks for the (?)compliment !

I suspect the example referred was one of yr own many elegant presentations so I apologize for omitting the source.

The archives are one tool in the constant battle against Reinventing the Wheel. :smile: Can sometimes be a two-edged sword though, eg hindering innovations.

Regretfully I have little experience in Packaging Production, mainly in Seafood.