8 replies to this topic

[Marzena]

Hello everyone :)

 

I'm working on a raw material risk assessment for our food manufacturing facility. We are ready to eat food manufacturing site using all types of raw materials - fresh vegetables, mayonnaise, spices, fresh and dried herbs, cooked proteins etc.

 

I'm looking for advice on interpretation for scoring and effective control measures.

Lot of people here have experience with conducting raw material risk assessments. I would appreciate any guidance or recommendations.

 

Risk assessment attached 

 

 

Thank you, 

Maja

Attached Files

•  Raw Material Risk Assesment MM.xlsx   22.62KB   29 downloads

Edited by Marzena, 28 August 2024 - 06:10 PM.

[Tony-C]

Hi Maja,

 

You seem to be thinking along the right lines with your probability and severity criteria.

 

Whilst I like the idea of the Total Risk Score, it wouldn’t work for me when you get scores of 9 for a risk category.

 

For example: Allergen content and potential contamination

Probability "High score=3"    

Regular issues with allergen cross-contamination, indicating inadequate controls. Multiple allergens on site, with a history of cross-contamination. High exposure to risk factors such as cross-contact with allergens. Weak preventive measures and allergen control systems.

Severity "High score=3"

High health risk, potentially causing severe allergic reactions and widespread recalls. High health risks, substantial financial loss, and serious regulatory implications. Requires immediate action.

Overall Score High 9 - High risk, immediate action or additional controls required

 

This for me would be some sort of knock-out.

 

But with your scoring system the food rating could score 1 x 1 = 1 for each other 7 risk categories and the Total Risk Score 16. Using your total risk score and risk classification system the Control Measures would be:

Completed supplier questionnaire and specifications retained on site. For non-food contact packaging- complete supplier questionnaire, signed packaging specification. For fresh produce supplies risk assessment questionnaire, pesticide test results, signed product specification                                                                                              

"Low risk material, no additional action required.

Routine monitoring and standard quality checks are sufficient.

Annual review of supplier/manufacturer/packer 3rd party accreditation."

 

I do think with some tweaking your system can work for you because most of the ground work is there.

 

Kind regards,

 

Tony

[Tony-C]

Hi Maja,

 

Just to add, you also need to factor in the nature and intended use of the material. When carrying out your assessment you will need prioritise materials that are likely to be a higher risk for example from higher risk to lower:

 

Final Ingredient - where any hazard present will be present in the final product

Raw Ingredient - where the hazard will removed by your process          

Contact Packaging    

Non-Contact Packaging

 

Kind regards,

 

Tony

 

[kingstudruler1]

At first glance, I loved it.   Then I didnt -  here are the reasons why.  

 

Since you mentioned 3.5.1.1, I  am assuming this is meant to comply with that clause.  However,  the goal of this clause it so evaluate the raw material.  You appear to be commingling the risk of the supplier and the raw material on the same form.   This is especially evident in the probability section when you mention things such as weak measures, strong measures, references to supplier, ect.   I would keep them seperate.  Simplfy the probabilty section.  

 

I do think that is great that you are also evaluating the risk of the supplier.   It would be possible for a raw material that would normally be considered low risk be supplied by a high risk supplier.   For instance, if  they had several non conformances, regualtory actions, recalls, etc they would would be monitored more frequently (3.5.1.3), not approved, or removed from approved status.   However,  BRCGS doesnt do the best job at communicating this need other than in 3.5.1.3.  You could include the risk of the supplier in 3.5.1.2 and 3.5.1.3.    You could assign a risk level to the ingredient like you are currently doing on this form.   Then assign a risk level to the supplier.   Finally, use those two factors determine the appropriate approval procedure (3.5.1.2).   

 

There is no need for control measures on the "hazard rating food tab".   Just use your risk matrix tab.   I would change "control measures" to "approval procedures"  It confused me at first.  

 

Good job, I can tell you put a lot of thought and effort into this.  

[kingstudruler1]

Hi Maja,

 

You seem to be thinking along the right lines with your probability and severity criteria.

 

Whilst I like the idea of the Total Risk Score, it wouldn’t work for me when you get scores of 9 for a risk category.

 

For example: Allergen content and potential contamination

Probability "High score=3"    

Regular issues with allergen cross-contamination, indicating inadequate controls. Multiple allergens on site, with a history of cross-contamination. High exposure to risk factors such as cross-contact with allergens. Weak preventive measures and allergen control systems.

Severity "High score=3"

High health risk, potentially causing severe allergic reactions and widespread recalls. High health risks, substantial financial loss, and serious regulatory implications. Requires immediate action.

Overall Score High 9 - High risk, immediate action or additional controls required

 

This for me would be some sort of knock-out.

 

But with your scoring system the food rating could score 1 x 1 = 1 for each other 7 risk categories and the Total Risk Score 16. Using your total risk score and risk classification system the Control Measures would be:

Completed supplier questionnaire and specifications retained on site. For non-food contact packaging- complete supplier questionnaire, signed packaging specification. For fresh produce supplies risk assessment questionnaire, pesticide test results, signed product specification                                                                                              

"Low risk material, no additional action required.

Routine monitoring and standard quality checks are sufficient.

Annual review of supplier/manufacturer/packer 3rd party accreditation."

 

I do think with some tweaking your system can work for you because most of the ground work is there.

 

Kind regards,

 

Tony

 

Hi Maja,

 

You seem to be thinking along the right lines with your probability and severity criteria.

 

Whilst I like the idea of the Total Risk Score, it wouldn’t work for me when you get scores of 9 for a risk category.

 

For example: Allergen content and potential contamination

Probability "High score=3"    

Regular issues with allergen cross-contamination, indicating inadequate controls. Multiple allergens on site, with a history of cross-contamination. High exposure to risk factors such as cross-contact with allergens. Weak preventive measures and allergen control systems.

Severity "High score=3"

High health risk, potentially causing severe allergic reactions and widespread recalls. High health risks, substantial financial loss, and serious regulatory implications. Requires immediate action.

Overall Score High 9 - High risk, immediate action or additional controls required

 

This for me would be some sort of knock-out.

 

But with your scoring system the food rating could score 1 x 1 = 1 for each other 7 risk categories and the Total Risk Score 16. Using your total risk score and risk classification system the Control Measures would be:

Completed supplier questionnaire and specifications retained on site. For non-food contact packaging- complete supplier questionnaire, signed packaging specification. For fresh produce supplies risk assessment questionnaire, pesticide test results, signed product specification                                                                                              

"Low risk material, no additional action required.

Routine monitoring and standard quality checks are sufficient.

Annual review of supplier/manufacturer/packer 3rd party accreditation."

 

I do think with some tweaking your system can work for you because most of the ground work is there.

 

Kind regards,

 

Tony

I missed this.   Do you think a score of "X" in any one category or a total score of "Y" total would work?  Then assign - not approved, high risk, medium risk, low risk.

[Marzena]

Hi Maja,

 

You seem to be thinking along the right lines with your probability and severity criteria.

 

Whilst I like the idea of the Total Risk Score, it wouldn’t work for me when you get scores of 9 for a risk category.

 

For example: Allergen content and potential contamination

Probability "High score=3"    

Regular issues with allergen cross-contamination, indicating inadequate controls. Multiple allergens on site, with a history of cross-contamination. High exposure to risk factors such as cross-contact with allergens. Weak preventive measures and allergen control systems.

Severity "High score=3"

High health risk, potentially causing severe allergic reactions and widespread recalls. High health risks, substantial financial loss, and serious regulatory implications. Requires immediate action.

Overall Score High 9 - High risk, immediate action or additional controls required

 

This for me would be some sort of knock-out.

 

But with your scoring system the food rating could score 1 x 1 = 1 for each other 7 risk categories and the Total Risk Score 16. Using your total risk score and risk classification system the Control Measures would be:

Completed supplier questionnaire and specifications retained on site. For non-food contact packaging- complete supplier questionnaire, signed packaging specification. For fresh produce supplies risk assessment questionnaire, pesticide test results, signed product specification                                                                                              

"Low risk material, no additional action required.

Routine monitoring and standard quality checks are sufficient.

Annual review of supplier/manufacturer/packer 3rd party accreditation."

 

I do think with some tweaking your system can work for you because most of the ground work is there.

 

Kind regards,

 

Tony

Hi Tony, 

 

I had some troubles with description  for allergen risk category as this should include allergen content and potential contamination, any suggestions?

You had mention in post "  Do you think a score of "X" in any one category or a total score of "Y" total would work?  Then assign - not approved, high risk, medium risk, low risk."  I' m sorry but I don't understand what did you mean by that.

 

Do you think it is a good idea to keep 3x3 matrix , or would be more beneficial to change to low medium and high and elaborate more on score interpretation? 

for example 

HAZARD RISK RATING FOREIGN BODY LOW-1  -unlikely to be present in raw material
 -no serious health implications MEDIUM-2  -possibly present
 -minor injury HIGH-3  -possibly to typically present in raw material
 -serious injury, death

[Marzena]

At first glance, I loved it.   Then I didnt -  here are the reasons why.  

 

Since you mentioned 3.5.1.1, I  am assuming this is meant to comply with that clause.  However,  the goal of this clause it so evaluate the raw material.  You appear to be commingling the risk of the supplier and the raw material on the same form.   This is especially evident in the probability section when you mention things such as weak measures, strong measures, references to supplier, ect.   I would keep them seperate.  Simplfy the probabilty section.  

 

I do think that is great that you are also evaluating the risk of the supplier.   It would be possible for a raw material that would normally be considered low risk be supplied by a high risk supplier.   For instance, if  they had several non conformances, regualtory actions, recalls, etc they would would be monitored more frequently (3.5.1.3), not approved, or removed from approved status.   However,  BRCGS doesnt do the best job at communicating this need other than in 3.5.1.3.  You could include the risk of the supplier in 3.5.1.2 and 3.5.1.3.    You could assign a risk level to the ingredient like you are currently doing on this form.   Then assign a risk level to the supplier.   Finally, use those two factors determine the appropriate approval procedure (3.5.1.2).   

 

There is no need for control measures on the "hazard rating food tab".   Just use your risk matrix tab.   I would change "control measures" to "approval procedures"  It confused me at first.  

 

Good job, I can tell you put a lot of thought and effort into this.  

Thanks a million for your comments, I agree with points you made above, sometimes it is hard to separate raw material risk assessment from supplier, things are more complicated when working with brokers  

[Tony-C]

Hi Tony, 

 

You had mention in post "  Do you think a score of "X" in any one category or a total score of "Y" total would work?  Then assign - not approved, high risk, medium risk, low risk."  I' m sorry but I don't understand what did you mean by that.

 

Hi Maja,

 

That was a post by kingstudruler1 so they will need to explain that one.

 

I'll come back to your other questions in the morning as getting late here.

 

Kind regards,

 

Tony

[Tony-C]

Hi Maja,

 

The criteria outlined in your raw material risk assessment are a good guide and don't really need to refer to suppliers at this stage but be used as a general risk assessment.

 

An appropriate scoring system is needed, you could use a similar scoring system to BRCGC certification grading criteria where you use your score as a guide but a single score of 9 would be regarded as major/critical and makes the raw material high risk. Grading A to E where a is low risk and E is very high risk.

 

Supplier approval and monitoring is all tied in with this so I wouldn’t worry too much about them being there in the control measures at the moment, they can move along and come under a column title 3.5.1.2 Supplier Approval and Monitoring and 3.5.1.3 Ongoing monitoring

 

* What does need to be added in are some aspects supplier assessment which will be largely based on your raw material assessment but will include other factors such as history of supply, location and any previous incidents regarding supply, non-conformances, rejections etc. From 3.5.1.1 Raw material risk assessment guidance:

Identification of the actual level of risk often requires the company to consider several factors; for example:

…

• nature of the supplier

• historical evidence of the supplier and raw material

• geographic origins (products from particular origins may carry a greater risk due to environmental conditions, because of more relaxed local legal requirements or a less developed food safety culture)

….

 

I have posted other relevant bits of guidance from BRCGS below.

 

3.5.1 Management of suppliers of raw materials and packaging

 

3.5.1.1 Raw material risk assessment

The aim of this clause is to ensure the potential risks to product safety, authenticity, legality and quality that could result from specific raw materials, have been identified, and where necessary mitigation measures put in place, for example, by adding controls into:

• supplier approval and purchasing processes

• goods receipt controls and product testing

• the food safety plan (HACCP) or specific parts of the food safety and quality management

systems.

 

3.5.1.2 Documented supplier approval and monitoring system

The acceptable methods of supplier approval will depend on the raw material and the risks associated with it (e.g. the output of clause 3.5.1.1). They will include one or more of the following activities:

- Certification to the relevant BRCGS Standard, ….; or another of the GFSI-benchmarked schemes… etc.

- A successful site audit covers at a minimum product safety, traceability, HACCP, product security and the food defence plan …. product authenticity and good manufacturing processes….etc.

- Where risk assessment (completed as part of this clause) indicates that a supplier is low

risk …. the completion of a supplier questionnaire with a focus on food safety and quality may be sufficient… etc.

 

3.5.1.3 Ongoing monitoring

As a guide, typical criteria may include:

• known risks associated with the raw material or supplier

• supplier approach to emerging concerns

• incidences of contamination or non-conforming raw materials

• quality of material supplied.

 

3.5.2 Raw material and packaging acceptance, monitoring and management procedures

 

3.5.2.1 The company shall have a procedure for the acceptance of raw materials and primary packaging on receipt based upon the risk assessment (clause 3.5.1.1).

 

Kind regards,

 

Tony