Haccp 1 Approach

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    PEOPLE

    SYSTEMHARDWARE PRODUCT

    Four Legs Of the Sound QUALITY SYSTEM

    Delighted

    CUSTOMER

    &

    Empowered

    EMPLOYEE

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    Physical Hazards

    The agent causes

    physical damage to the

    consumer. (broken

    teeth, cuts, internal

    injury)

    Can occur during manufacture due to physical hazards such asglass, metal, packaging residues, etc. Unstructured or lumpy product can constitute a foreign matter

    hazard

    Promotional items can become serious foreign matter hazards

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    Biological Hazards The action of a biological

    agent harms the consumer Infection or Intoxication

    Mostly bacteria

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    Microbes are very small

    World population is

    5.5 BILLION

    i.e. 5 500 000 000

    1 cup

    of yoghurt contains

    22 X this number!

    i.e. 120 000 000 000

    separate living

    organisms.

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    Bacteria Replicate

    Division times are typically ~20 min in the

    lab

    So, bacteria can go from 1 cell108 cells in

    18 hr!

    This way:

    1 -> 2 -> 4 -> ->-> -> ->8 16 32 64 128 ->-> 256 512

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    Play Movie

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    Chemical Hazards

    Chemical agents which may

    have a toxic effect in

    consumers.

    These are not normally

    expected to be found in the

    product. (contaminants)

    Can occur from ingredients that are out ofspecifications

    Excess addition of minor ingredients

    Contamination from cleaning/disinfection

    chemical residues

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    Allergens

    Food allergy is an immunological reaction to a food

    protein which is a normal constituent of a particular food.

    Fatalities due to allergens are rare and consumers who are

    aware they suffer from food allergy are careful when

    purchasing foods.

    The vast majority of incidents with regard to death fromanaphylaxis are due to food service and

    catering/restaurants, and not from industrially produced

    consumer goods.

    The WHO has produced a general list and companies havedeveloped their Allergen policies.

    Some ingredients may potentially cause serious allergicreactions in sensitive consumers eg eggs, some fishes,peanut, milk( protein) and so on....Sensitivities may varydepending on target population

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    What is it ?

    Tool for management of consumer safety in

    the food industry

    Based on an engineering tool FMEA

    Focuses most attention on critical areas

    HACCP =

    Risk-based

    QualityAssuranceApproach

    +

    Validated bySelective

    Application ofQuality ControlTechniques

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    Identifying potential food safetyproblems

    Determining how and where thesecan be controlled or prevented

    Describing what to do and trainingthe personnel

    Implementation and recording

    he HACCP ConceptMove from QC

    to QA through

    HACCP

    STEP-6

    60 units/lot

    25g/unit of 250g

    10 tons

    Homogeneous

    distribution ofSalmonella

    Lots with 800 unitscontaining Salmonellaare accepted with 30 %probability

    End-product testing...

    Sampling scheme:

    Examined:

    Lot size:

    Assumption:

    Confidence:

    Traditional endproduct testing can

    never guarantee

    products free from

    contamination

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    Codex- 7 Principles

    Conduct a hazard analysis

    Determine CCPs

    Establish critical limits

    Establish CCP monitoring

    Establish corrective action plan

    Verification Plan Documentation

    These principles do not themselves contain enough detail or

    structure to enable the production of a useful HACCP plan...

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    Codex- Tasks

    0. Define terms of reference

    1. Assemble team

    2. Describe product

    3. Describe intended use

    4. Construct flow diagram5. Verify flow-diagram

    6. Identify hazards and preventive measures

    7. Identify CCPs

    8. Set critical limits and target values9. Assign monitoring of CCPs

    10. Define corrective actions

    11. Validation and Verification

    12. Documentation

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    Definitions

    HazardAn agent*, or condition, with the potential to

    cause an adverse health effect * Allergen, Biological,Chemical, Physical

    RiskThe likelihood that a hazardous situation will

    occur

    Critical Control PointA step at which control can be applied (and is

    essential), to prevent or eliminate a consumer

    safety hazard or reduce it to an acceptable

    level.

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    Terms of Reference (1) Define what will be covered in this study

    List the hazards that will be considered

    Be realistic and reasonable

    Cover all four hazard groups (allergens, biological, chemicaland physical) or explain why you dont

    Make it specific (e.g. under chemical: lubricants, cleaning andsanitisation materials, cooling liquids, pesticides in rawmaterials, pesticides used on site, heavy metals in rawmaterials, etc)

    Define the scope of the study (start & end)

    Farm to fork List any related HACCP studies

    Will you do a study for every product, or will you group?

    List Pre-requisite Programmes / Systems

    Training, pest control, personal hygiene, SEAC approval, plant

    sanitation, .

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    Select the Team

    Chairman/Sourcing

    Unit Head

    Technical Secretary

    Microbiologist**

    Production

    Engineer

    Chemist

    QA

    ** for HACCP studies

    on Micro hazard

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    Product Description and intended

    use It is important that product and its use are clearly defined

    Mention storage conditions and shelf-life

    Repeat the information given to consumers on thepackaging- What do we tell people to do ?

    Consider known or likely abuse- What do we know

    people might realistically do ?

    Mention target consumer group and any special needs

    (e.g. Diabetic, High-cholesterol sufferers, Children,

    Hospital patients)

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    Flow Diagram

    Provides the framework for hazard analysis Must be process based, and confined to

    production processes within the scope given

    in the Terms of Reference. Do not forget rework!

    Keep it simple

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    Flow Diagram Verification

    Check that your work is accurate

    Introduces non-local experts to your plant

    Often overlooked

    Eg water lines,

    side processing,

    mobile storage

    tanks etc

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    Identify Hazards and Controls

    What can go wrong ? What can you DO to prevent it ?

    This step applies both to HACCP anddHACCP

    Dont forget:

    Cleaning

    Shift Changes

    Breakdowns, Stoppages,

    TPM

    Training

    Holiday periods

    Rework

    Why do we need to be clear about

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    Why do we need to be clear about

    the hazards

    Hazards need to be defined very clearly as otherwise the

    preventive measure may not be effective. For example, when the hazard only mentions contamination it will lead

    to assumptions being made as it can mean

    Contamination from dirty hands of workers

    Contamination from the factory environment

    Contamination from lubricants

    Contamination with residues from cleaning liquids

    Preventive measures for the different hazards can be as follows: Hand wash facilities & work instructions & training

    Factory design & cleaning & training

    SHE approval & preventive maintenance & training

    Cleaning instructions & validation & SHE approval & training

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    CCP vs DCP

    Design Control Point:

    A step where the study of a conceptual line design, process design

    or plans and layouts identified a hazard and where there is a need

    for the hazard to be prevented, eliminated or reduced. DCPs will be

    identified prior to HACCP studies during development/clearance of

    proposed product/process designs.

    Critical Control Point:

    A step at which control can be applied (and is essential), to prevent or

    eliminate a food safety hazard or reduce it to an acceptable level.

    Specific to a

    factory or aprocess line

    Generic for a

    category

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    Start:

    Do control measures exist ?

    Yes

    NoIs control at this step necessary for

    safety ?No

    Yes

    Not a CCP:

    STOP

    Modify step, process or

    product

    Could contamination with identified hazards occur in excess of

    acceptable levels, or could these increase to unacceptable levels ?

    Will a subsequent step eliminate identified hazards or

    reduce likely occurrence to an acceptable level ?

    Yes

    No

    Yes

    No

    Yes

    No

    Not a CCP:

    STOP

    CCP: STOP

    CCP: STOP

    Not a CCP:

    STOP

    Is the step specifically designed to eliminate or reduce the

    likely occurrence of a hazard to an acceptable level ?

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    Reality Check !

    Ensure that after determining each CCP that

    there is consensus within the team.

    Are your CCPs sensible ?

    Have you determined CCP/QCP/DCP

    correctly ?

    Did you include DCPs from dHACCP study

    or GMP?

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    Critical Limit

    A value which separates the acceptable

    condition, from the unacceptable.

    Usually absolute or derived from science

    Note

    Critical limits are defined in dHACCP stage

    already

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    Target Value

    The value which has been proven bypractical experience to deliver the desired

    condition.

    Accounts for offset and variation !

    Note

    Target values are defined in operational

    HACCP! Not in dHACCP!!

    M it i

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    Monitoring

    Must directly measure the CL/TV parameter

    Must be able to detect loss of control

    Should be able of detecting trends towards

    loss of control

    In dHACCP monitoring options for the

    factory are only PROPOSED!

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    Corrective Action

    A clear statement to the responsible person about what must be done when

    the CCP is out of control

    It can make reference to other procedures if necessary- but these must be

    well known and understood by all

    Remember there are always two components

    1. Protect consumer safety: what will be done with the products that are

    potentially unsafe?

    2. Process control: what should be done to bring the process back incontrol?

    Preventive actions are not part of HACCP but are to be addressed in the

    quality management system (non-conformance management)

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    Validation

    Obtaining evidence that the HACCP plan iseffective.

    Are we doing the right things ?

    Can we justify what we plan to do ?A critique of evidence supporting the study

    Preventative measures, Critical Limits / Target

    Values, Monitoring, Corrective actions

    How were the Terms of Reference constructed?

    Based on what?

    Are acceptable (written) procedures in place.

    Check references

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    Verification Verification is the application of methods, procedures, tests

    and other evaluations in addition to monitoring (and at alower frequency) to determine compliance with the

    HACCP plan.

    Trend analysis can be very powerful when applied to:

    CCP monitoring data & corrective action data

    Line test data

    End-product testing (this is NOT monitoring)

    Complaints (consumer and customer)

    Hygiene test results

    Increases in blocking, reworked or destroyed products

    to spot deviation from our expectations

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    Limitations

    HACCP cannot patch gaps in basic systems e.g. GMP conformance, calibration, maintenance,

    training, safe design of products

    HACCP cannot prevent all possible causes

    of consumer harm

    Quality of the HACCP study depends of

    quality of inputs and quality of

    implementation

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    HACCP Implementation issues

    UKC Oct 11

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    Good Manufacturing Practice - GMP

    Design Control Points - DCPs

    HACCP

    Ensure GMP / GHP before embarking on HACCP

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    Bridge gaps in Hardware / Infrastructure

    and Implementation of GHP / GMP

    Pest Proofing

    Food Handling Area

    Building / Roof / Wall / Floor

    drain

    Storage and handlingfacilities

    Laboratory

    Personnel Hygiene

    Infrastructure

    Hygiene Station at entrance

    Change room

    Toilet

    PPE

    Handling of lubricants /

    cleaning aids / chemicals etc.

    Process robustness

    (pasteurisation, handling

    of preservatives etc.)

    Water management

    Air

    Valves

    Pumps

    Pipeline / fittings

    Heat Exchangers/Vessels Generic CCPs

    Cleaning & Disinfection

    Rework Handling

    Offline Processing

    Plant & Building Infrastructure Manufacturing Hygiene & Design

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    Food Handling

    Area must be

    Pest Proof

    Hygienic Vessel Design

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    Hygienic Vessel Design

    Sloping Manifold

    Angled Instrument

    Ground Smooth

    Short

    Manway

    Trap in Vent

    Probe

    Baffles

    Welded

    Single Outlet at lowest point

    Shaft

    Seal

    Spray

    Balls

    Dished Ends

    Weld Seams

    Hygienic CouplingsFor Agitator Blades

    To Shaft

    RIGHT HYGIRNIC DESIGN OF PLANT & EQIPTS

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    Eliminate other

    possibilities ofContamination

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    HAZARD ANALYSIS CRITICAL CONTROL POINT ANALYSIS REPORT

    D TreeProcess Step Hazards PreventativeMeasures Q1 Q2 Q3 Q4

    CCP Critical TargetLimit Value

    MonitoringProcedures

    CorrectiveActions

    Receipt ofRM/PM

    Black specs,Foreignmatter

    QC of materialbefore unloadingthe material

    Y Y CCP-1

    NoContamination

    NoContamination

    Checking ofevery lot ofRM/PM anduse only if itpasses

    Rejection ofConsignment

    Unloading ofLiquidRM/Blending& Storage

    Foreignmattercontamination

    Strainers providedin theunloading/transferpumps

    Tanks are coveredErs

    * SS Lining to DFAstorage tank fromtop side

    * Magnetic strainersto transfer lines

    Y Y CCP-2

    No FM NO FM Checking ofblend beforetransfer to Panroom

    Checkcondition ofseive

    Hazard Analysis of Critical ControlPoint - Foreign Matter

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    HAZARD ANALYSIS CRITICAL CONTROL POINT ANALYSIS REPORT

    D TreeProcess Step Hazards PreventativeMeasures Q1 Q2 Q3 Q4

    CCP CriticalTargetLimitValue

    MonitoringProcedures

    CorrectiveActions

    BLS No hazardscontributing toblackspecs/Foreign

    matterSoap transferto receivingPan

    Open pans Soap from scrap

    pan added toreceiving pan

    Pan lining

    Covering of all thesoap pans

    Strainers providedin the soap lines

    DCP

    Scrap additionin scrap pan

    Foreign mattercontaminationthrough scrapaddition

    Sorting of scrapbefore adding toreceiving pan

    Y Y CCP-3 NOFM

    NO FM VisualInspection/sorting

    Resorting/eject

    T/S Crutching

    Open manhole Contamination

    while unloading ofcodex/EDTA inday tank

    Contaminatedadditives added tocrutcher

    Oil leakage fromgearbox

    Manholes coveredStrainers providedto Codex/EDTATanks

    Regular preventiveMaintenance ofCrutcher gear box.

    N N GMP

    Hazard Analysis of Critical ControlPoint - Foreign Matter (Cont.)

    AFTER HACCP

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    CCP CONDITION OF SIEVE MESHHAZARD TEARING OF SIEVE MESHWHO CHECKS MIXER TEAMWHAT TO CHECK CONDITION OF SIEVE MESHHOW TO CHECK VISUAL CHECKTARGET VALUE SIEVE MESH SHOULD BE INTACT

    WITHOUT ANY DAMAGECRITICAL LIMITS SIEVE MESH SHOULD BE INTACT

    WITHOUT ANY DAMAGEFREQUENCY OF CHECK ONCE A SHIFTWHERE TO RECORD MIXER LOG BOOKWHOM TO INFORM INCASE OF DEVIATION SHIFT OFFICERPREVENTIVE MEASURE TO CHANGE THE SIEVE MESH BY NEW ONE.

    Modified Sieve t o prevent ing ress of

    foreign m ateria l even when t he mesh

    screen is torn

    20# sreen

    Anti bl ind rings

    8# screen

    Perforated sheet w ith

    20 mm dia

    perforations

    Normal Sieve

    20# screen

    Anti blind rings

    Perforated sheet with 20

    mm dia perforations

    Review&

    further

    Improvethe

    Hardware

    AFTER HACCP

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    LEARNINGS : HACCP

    Restore the basic condition of Plant & equipment - AM step 1 &2

    Address the DCPs first

    Make the shopfloor Pest Proof as part of GMP implementation

    One day inhouse training capsule to everyone by QA

    Active participation by QA as HACCP Team member

    Designate QA manager / officer as Consumer Safety Manager

    with responsibility of HACCP implementation

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    LEARNINGS : HACCP

    Any Change in Process / Product / Equipment should triggerHACCP Review

    Visual Display Boards at Workplace means Thousand Words

    Involve operators while designing CCP monitoring Sheets

    Include QCCP & CCP Trend Monitoring in monthly

    Factory Review

    Above all Top mgt commitment & build in Key Tasks;

    use OPLs for workers training/appreciation

    Always focus on results after HACCP impl &

    review effectiveness of implementation

    REVIEW OF HACCP PLAN

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    REVIEW OF HACCP PLAN

    Review HACCP in case of any of thefollowing changes:

    Change in RM or Product formulation

    Change in Process

    Change in packaging, storage and

    Distribution system

    Receipt of market feedback.

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    T H A N K Y O U