BRC Global Standards Issue 6 Guidance – Part 3 – HACCP
Following our last post we continue our guidance on implementing a BRC Global Standards Global Standard Issue 6 compliant HACCP Plan.
Section 2.3 Describing the Product
I’m often asked about the “point” of this, in a HACCP Plan. The answer is simple. It makes the HACCP Team consider the impact of the attributes of the product on the credible food safety hazards. For example:-
A product with near neutral pH, much available water (Aw 0.95 or more), packaged in normal atmosphere packaging will be prone to rapid microbial spoilage, or worse, the growth of pathogens and the formation potentially of bacterial toxins.
A product with low pH (acidic), or very low available water (<0.95), and that is vacuum packed or tinned, represents a much lower risk of microbial growth and consequent microbial spoilage.
And so describing the product or groups of products helps to ensure that the hazard analysis which will follow is appropriate – that is – credible hazards are not missed and unlikely hazards are not considered unnecessarily.
Section 2.4 Intended use
Defining the target customer identifies whether the food is likely to be eaten by those who may be more prone to food poisoning or food borne disease. It is important to identify if, for instance, your products are targeted to consumers in hospitals, care homes or infants.
Then look at intended use of the product. If you target the elderly consumer and your product is ready to eat (straight out of the pack) then you potentially have some more credible microbial hazards than if the product is intended to be cooked and you do not target those who may be less healthy. Again, as for section 2.3, this provides you with information about how you should consider the credibility of hazards within the hazard analysis.
2.5 Flow Diagram and 2.6 verifying flow diagram
Almost certainly the auditors will be looking for a lot more detail that demonstrates that the HACCP Team understand where and how the processing steps interact and where those processes occur within the factory / food unit. This requirement is, to a degree, visited again in clause 4.3.1 (Lay-out) which we’ll cover later.
We need to know whether a process step in one particular area of the premises gives rise to more hazards compared to it being situated in another area. Hence the BRC Global Standards requirement to consider the option of covering a plan of the premises and equipment lay-out when producing the flow diagram. Then add in: waste routes; utilities introduction; water, gas, compressed air or steam inputs; packaging inputs, delay steps, rework steps, processing aid inputs, and so on.
Again this is the way in which the HACCP Team, in performing the hazard analysis will not forget to consider all credible hazards perhaps arising from sources that they wouldn’t have thought of were the flow diagram not to be detailed enough.
And then don’t forget to verify the flow diagram. Really do have the team walk the line, talk to operators, consult plans, take into account shift patterns etc. Once satisfied get everyone to sign and date the flow diagram. You can create an nice little verification table somewhere in the corner for this if you value tidiness of course.
Next time – we’ll look at hazard analysis, managing CCP’s and HACCP review.
The BRC Global Standards Global Standard for Food Safety is clear in Issue 6 – it wants processors to truly manage their food safety using their HACCP plan. The key word here is “manage”. This is a live document that should be at the forefront of the minds of all operators, shift leaders, managers and directors. Not just the HACCP Team.
If you think this is getting a bit tricky and you would value some expert input, you know where we are!
Richard Mallett
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