Hazard Identification, have we done it right?

Hi  All 

I am in need of a little review of our hazard analysis. I have reviewed it following taking over from a previous self taught person running their own business and have got myself in a little state of confusion. 

Attached is the HACCP plan, when it comes to looking at the hazards I don't feel that it's right. For example we have chemical segregation in place as a pre requisite. So my question is, does chemical contamination or contamination from employees eg hair need to be considered as a hazard if we wearing and enforcing PPE procedures? Or if chemical is locked away and washed off following usage, does it still get considered as a hazard?

Would really appreciate any feedback on the hazard analysis from any angle too. 

Thanks in advance :) 

Hi Laura

Perhaps your predecessor missed the risk assessment stage?.... if this hasn't been done it misses the relative risk of ANY contamination, so, for example a hair in the food isn't as life threatening as a nail or piece of glass?...

This might be of some use as a starting point?.

Understanding The Difference Between PRP, OPRP & CCP (safefood360.com)

Good luck 

Thank you, so to confirm things relating to the pre requisite eg chemical control, Hair control/ PPE are not expected to be listed as a hazard against a step. Eg chemical residue wouldn't be deemed a hazard in a chiller!?

Thanks 

Hi Laura982,

When developing your HACCP System you identify your hazards first then assess them to decide which ones are significant. You identify your hazards then may decide in the assessment stage that they are not significant based on the PRPs/GMPs you have in place.

The post above by LesleySR is partially correct in that a nail or piece of glass could be significant hazards due to the possibility of the harm they could cause. Hair is an undesirable in terms of a foreign body and likely to cause a complaint but is likely to have Staphylococcus aureus present which could grow and produce a toxin and this could be a more significant hazard depending on your product which is why we conduct specific HACCP System development rather than using a template.

Kind regards,

Tony

Dear Laura,

There is no attachment. So we can not review it.

Hi Laura

Well yes & no, because ALL hazards are considered at EACH step during the initial stage when building your HACCP plan.

Example of MyHACCP Study - Honey and Lemon Yoghurt (food.gov.uk)

You then go through the risk assessment for each of these hazards at each relevant step (frequency x severity x relevance) to determine the level of risk each hazard presents at each manufacturing step, and detail what controls are already in place, eg. pest control, supplier assurance, handwashing, PPE etc. which might mitigate against these hazards.

You will then determine which steps are CCPs, unless you have a very complicated process you probably have maximum four?.

Thank you all, now attached 

Where is your hazard analysis?   The HA has to be completed BEFORE you do a risk analysis   for example, you've listed out micro in the water, but have justified it by having a municipal source ----what about your own water lines?  they could become contaminated---you have not listed that as a hazard, and therefore no steps have been listed to control said hazards

You've mentioned using a calibrated thermometer, but zero mention of a calibration program.......

Back to the drawing board for your plan I think--it's full of holes

This is a great tool to help you along----it's a bit cumbersome, but its a tool worth the time

https://active.inspe...introe.aspx?i=1

:)

I don't want to repeat what was said already but bear in mind to add 

- radiological hazard (for example - Radiological contamination of raw materials or packaging by processing near nuclear plants, growing products in soils contaminated with radioactive materials. Processing plants being in radon-high areas) 

- Malicious and/or Fraudulent (for example - Potential for malicious contamination of raw materials by manufacturers of RM, processors, handlers or suppliers, or during transit from one supply chain link to another. Malicious contamination most commonly include contamination with allergens, chemicals or foreign bodies. Lack of delivery paperwork proving product status) 

Example attached :)

When you have a control measure or a PRP to address a hazard, it's good to record it in the HA and take credit for the risk mitigation program you're using to control it.  So in my HA's I do cite employees as potential FM when working with exposed product and then call out my GMP's require smocks and hairnets as the controlling PRP.