Last time we covered the extra requirements (over Issue 5) for section 1 – Senior Management Commitment
This time we shall start to look at the BRC Global Standards Global Food Standard Issue 6 section on HACCP. The mandatory requirements have been expanded somewhat over Issue 5. We going to start with the revised clauses on managing the pre-requisite programmes, a change that brings the Standard in keeping with the level of detail given to pre-requisites in ISO 22000.
In summary section 2 on HACCP, in Issue 6, places a greater emphasis on the implementation and validation of the pre-requisite programmes. It states that the pre-requisite control measures must be clearly documented and included in the development and review of the HACCP programme. So what does this mean in practice?
Well it is correct practice anyway to identify and implement pre-requisite controls to ensure that the HACCP Plan will be effective. What is a pre-requisite programme?
I like to think of it as a “site-wide” or “covering all process steps” control, as opposed to a process specific control. Now thinking of some examples becomes easy:
- Pest control is a site wide control – the management of pests is crucial over all areas of the factory and loss of control could affect any process step.
- Cleaning and sanitation falls under the same definition – it’s no good concentrating on some areas and leaving others dirty – the potential for cross contamination from these dirty areas renders the HACCP plan ineffective. The list goes on of course in much the same way including (but not exclusively):
- Staff training
- Personal hygiene rules
That is quite different to a process specific control. These exert control at one or few places in the overall process. Think for instance of:
- Pasteurisation at a pasteuriser
- Metal detection
- A thermal processing step applied to food
- A specific packaging gas mixture used at a packaging machine
- A delibrate “at process” check such as a specific goods in quality and temperature check following a defined instruction.
These are only a few but I hope that it clears up the difference between a prerequisite control and what is not a pre-requisite control.
Issue 6 of the BRC Global Standards Global Food Safety Standard requires that:-
- You document clearly the pre-requisites. This means a proper cross reference ( perhaps a separate table ) within the HACCP Plan showing which pre-requisite controls manage which site-wide potential hazards. Include references to SOP numbers or Quality Manual pages.
- You validate these pre-requisites and include them in HACCP development and review. You should be able to manage this through an internal audit programme. But beware that validate means “check that they are effective at reducing the hazard” – constant pest issues recorded means that the pest control programme cannot be validated as effective and thus will put at risk the HACCP Plan. Cleaning and sanitation can be validated by visual checks and a programme or rapid or conventional microbiological swabs – this is scientific and ultimately tells us we’re doing a good job. But just swabbing one area all the time doesn’t validate!
- And your HACCP review audit or meeting checklist (yes it should be this formal) should require an examination of your pre-requisite programmes. Are they effective or do we need to do more?
Next time we’ll move on to the HACCP system itself……..