Continuing our guidance for those trying to upgrade their systems to be compliant with the new Issue 6 of the BRC Global Standard for Food Safety
The HACCP Plan
There is, on the whole, relatively little change in Issue 6 concerning the way that hazard analysis should be executed. Some of the same rules apply – assess hazard significance – you should use the principle of considering the credible probability of a hazard against the severity of outcome of that hazard to provide for a value for overall risk. The use of a simple mathematical matrix, something that has been seen in health and safety risk analysis for many years, can help. Especially if provided with real guidance as to what you mean by 1, or “Very Low Probability”, or 3 or “high degree of severity”. Don’t just wildly guess at this. Use historical information, industry data or experience of the HACCP Team.
What is different in this section (2.7.3) is that the Standard requires that where the control is achieved through existing pre-requisite programmes that you specifically state the pre-requisite (i.e. proper reference within the plan) and that you validate that pre-requisite. If you can’t validate cleaning and disinfection or control of suppliers of ingredients, materials and services as effective, then they can’t be the only control! It’s that simple. Make it easy – draw up a table of specified pre-requisite controls and add a column to show how you should validate. Depending on the control it could be through analytical data (e.g. swabs or water tests), servicing plans, certification or appropriateness of supplier (and this is not just food suppliers!), visual inspections and audits. There may be many more.
Critical Control Points
CCP’s should be defined, as they always have been, using a mixture of knowledge, common sense and tools such as the Codex Decision Tree. As a general rule of thumb, if a CCP cannot be assigned an reasonably easily measured critical limit or target, then check it again – is it a CCP? Or has a control point or pre-requisite crept in there?
As has always been the case, be specific in defining your monitoring system (who, when, using what and how), and your corrective action plan (how to bring the process under control, what to do with the product, how to stop it happening again). The key change now is the Standard’s requirement to assess any trends towards loss of control – a sensible step which means that action can be taken before you are writing off £100,000 or Euros of product.
Finally section 2.14 forms an easily understood list of when to review the HACCP Plan. But you are falling short of this new Standard if you don’t (re)validate any changes to the plan that you have made as a result of review. There’s that word again – validate.