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According to Article 5 Reg no 852/2004 what two criteria allow an FBO for flexibility based on HACCP based procedures
The nature and Size of the operation
What is the 'Nature'
The basis for a risk-based approach and depends on the activity of the FBO for example
When Applying HACCP based procedures its important to be flexible where appropriate taking into account the nature and size of the operation.
- Give examples of 'The Nature' for risk based approaches
- Hazard reducing / Eliminating step (Pasteurisation) at the end.... or not
- Food of animal origin... or not
- Temperature requirements at handling/storage... or not
What plays a crucial role in analysing the risk for 'Nature'
Hazard analysis
What is the 'Size'
Volume of production
- Linked proportionately to FBO's
- Reflected as a reduction in administrative burden
Are PRP's specific?
No
They are not specific for a given hazard and apply generally
Give examples of differences in risk which should be taken into account when applying PRP's flexibly
- Retail of pre-packages food Vs Retail including further handling of the food (eg Butcher)
- A complex processing system Vs a limited simple one such as storage/transport
What real life situation might this be applied to?
Cleaning and disinfection
- In a small butcher shop it might be very close to good hygiene kitchen practices
Control of water
- Can be negligible if community potable water is used, but should be extended if a business's own source is used or recycling takes place.
Her lecture is very waffly it Basically it means that the PRP's that are applied in these local business's are good enough to maintain a high standard but they're not like 100%.
Flexibility is alot based on smaller business's to lighten their burden.
Recital 15 of regulation 852/2004 states that procedures implemented based on HACCP principles should...
- Provide Flexibility in all situations like in small business's
- It is Necessary to recognise that in certain food businesses it is not possible to identify CCP's, and good hygienic practices can replace the monitoring of CCP's.
- Establishing Critical limits does not have to be fixed to a numerical value
What Prelim HACCP activities can be applied according to 852/2004 relating to being flexible?
- No permanent HACCP team
- One person responsible for FSMS
- Use of existing product info - labels, internet
- Simple flow diagram.
Give example of method to identify a hazard? (Using principle 1)
Simple decision tree
We now know that not in all cases are CCP's identified. In these cases based on the HACCP principles how should we proceed?
In these cases the application of procedures based on the HACCP principles is LIMITED to the FIRST PRINCIPLE to justify why no CCP's need to be considered and to DEMONSTRATE that CCP's are sufficient to control hazards.
When Identifying CCP's the process should be..
Flexible, considering the whole manufacturing process in order to avoid unnecessary CCP's
What is wrong with a 'Generic guide' on implementation of HACCP based procedures?
FBO's should be aware there are other hazards than those mentioned.
Generic HACCP guides may be appropriate For..
- Slaughterhouses
- Dairy establishments
- Business's applying standard food processing procedures such as canned food, freezing or quick freezing of food.
On what basis are Critical limits at CCPS be established?
Based on:
- Experience
- International documentation for certain operations eg canning food, for which international standards exist
- Guides to good practice
- Scientific Publications
- EU Legislation
When might CCP's not always imply a numerical value to be used? Give examples
Where monitoring procedures are based on visual observation
- Faecal contamination of carcasses in slaughterhouse
- Boiling temperature of liquid food
- Change of physical properties of food during processing
Monitoring in many cases can be a simple procedure. Give 3 examples of Simple monitoring
1) Regular visual verification of temp of cooling, freezing, heating facilities using thermometer
2) Visual observation of Correct De-hiding procedure where this has been a CCP for preventing carcass contam
3) Visual observation if food preparation submitted to heat treatment has correct physical properties
Documentation and records must be
Commensurate (Corresponding) to the nature and size of the food business
Simple Verification procedures may include..
- Physical audit
- Check on the monitoring records for corrective actions whenever non compliance has been recorded.