Dear Dinesh,
I agree wholeheartedly with Remi- combine both ISO systems into one system.
The emphasis of ISO 22 000 of the management of the HACCP system that has
been thoroughly risk assessed. And as Remi says if this is done correctly,
before you write your Pre-requisite programs. Standard operating procedures/
GMP work instructions, you can design many hazards out of the process.
In my time as an HACCP auditor and trainer I would say the most common
mistakes are:
- not quantifying the significance and likelihood within the risk
assessment process.
- not identifying your target pathogens and knowing what exact
steps will kill that organism
- not identifying the relevant toxin and knowing how it is not
produced during the process
- not knowing the species specific hazards for your seafood species
- not knowing the process specific hazards for your process
- not risk assessing the ingredients within the process (do you
really know the hazards from your ingredients ?)
- not risk assessing the inputs into the process- water/ packaging/
cleaning process/equipment design
- not understanding the difference between micro: contamination,
growth and survival- all of which occur at different points in the process
and have different control measures.
and astonishingly: not understanding what a CCP really is: the point at
which control is applied which is not always the point where the hazard
occurs.
And just because you have control measures in place that you consider are
infallible (wrong) that does not mean its not a CCP- in fact it most likely
is the CCP.
And I completely agree with Remi in that you need very effective training
for more than one team member with regard to all of the above areas. Most
HACCP training will not cover all of the above areas. And keep copies of
the training including: course material and course assessment.
Clare Winkel
Project Manager
IFQC: Seafood Certification Alliance
Head Office
Rivercourt Centre
Riverlane
Dundalk, Co.Louth
Ireland
Tel: +353 42 932 0912
Fax: +353 42 9386864
Mobile: +353 86 8576127
www.ifqc.ie
Official Co-Ordinators of the World Seafood Congress 2007 :
www.worldseafoodcongress07.com
_____
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On Behalf
Of Remi Michalowski
Sent: 18 September 2006 08:11
To: Fishpro Pvt Ltd
Cc: seafood@ucdavis.edu
Subject: Re: ISO 22 000
Hello Dinesh,
Good news: You are ISO 9001 certified ! So it won't be too difficult to go
to ISO 22000, as you have also HACCP running... You have already everything
to succeed !
I strongly recommend not to have two manuals. It is easier to manage...
Remember that the ISO 22K is not like HACCP, you do not start from the
process already existing but from the begining e.g. characterization of the
raw material and other inputs to your system, and the finished products,
then you define what you want to achieve.
Based on this, you perform a risk assessment where you determine the
necessary elements (control measures and effect) to manage the hazards. At
last, you make your procedures and process... This can even help you to
review your current flow process and improve it !
The main issues are
> To define CLEAR e.g. quantifiable and relevant policy and targets related
to food safety.
> You shall also be attentive about the Prerequisites Program - You need to
stress that it is the key stone of your program and clearly define what it
is, what are the elements... and to ensure a strong commitment for their
good operational conditions...
> To integrate the hazard / risk assessment, targets establishment and
control measures validation:
Please be aware that you need a tough job by collecting information (legal
and technical) but also to keep it in records (maybe through a ISO
document).
The validation of the control measures is based on specifying the effect on
the hazard and to prove it.
> Change the mentality on HACCP: it is not (and has never been) the miracle
solution.
You need to change the format of the CCP determination form to integrate the
PRP, oPRP and CCP into one document. This doc can be global to your
different lines, AS YOU DO NOT START FROM THE PROCESS STEPS BUT FROM THE
CONTROL MEASURES... then you can go more specifically to the different
processes.
Some people talk about "light" HACCP...Well, here, you come back to the
"true" HACCP: CCP is the step where you can dramatically eliminate the
hazard through your control, underlining a continuous control...
>Transition ISO 9001 / ISO 22K: Not a big deal, as they provide the
equivalents in their guidance for implementation.
Just be sure you define the external AND internal communication, as well as
the "Emergency Preparedness Response" such as initiating a mock recall or
some Incident Scenarios. Furthermore, define clearly what is an "incident"
for your company.
About product development / prod planning - Be sure that you integrate the
risk assessment into your procedure...
> Traceability - You can try to get the draft of the ISO 22005, but it is
not really valuable...
You can find more interesting guidance from the Net and do not believe the
people that say you have to implement RFID to meet ISO or EU requirements.
> Training of the people - Ensure the person in charge of the CCPs
monitoring are properly trained and aware of their responsibilities. As well
as the other people in the staff !! You need to prepare the members of the
food safety team to perfectly understand the different concepts from ISO
22K, such as oPRP... They shall be ready to answer the assessors !
I am sorry if I am not enough clear but it needs some time to go deeper, and
it would be better to see your process first.
Anyway, mainly the ISO 22000 follows the Codex guidelines for food hygiene.
You could also follow the Codex Code of Practice for fishery products as it
is referenced in the ISO.
I would recommend you to visit the ProCert website - www.procert.ch where
you can find some interesting documentation on ISO 22000 implementation.
Hope I could help you. If you need more support, do not hesitate to contact
me.
Kind regards,
Dipl. Ing. Remi Michalowski
Deputy General Manager IQA Food Processing
PT. Centralpertiwi Bahari - Lampung, Indonesia
HP + 62 815 4040 484
CPB - Integrated Shrimp Farming. "From Pond to Plate"
A CPP Company. Member of Charoen Pokphand Group
On Sep 18, 2006, at 1:17 PM, Fishpro Pvt Ltd wrote:
Dear Remi Michalowski,
Thank you very much for replying my inquiry.
Yes we are ISO 9000 certified and we used ISO 9000 for Food industries as
our reference when developing the system.
How you cope up the comments elements in both ISO 9000 and ISO 22 000? Do
you have one manual or two manuals?
Is it possible to have an outlook of your ISO 22 000 project if it is not
disturbing your confidentiality. (Not the manual but step wise activities
you have followed)
Look forward for your invaluable responses.
Thanking you
Regards
Dinesh Dhammika
Ensis Fishing Pvt Ltd,
Male
_____
size=2 width="100%" align=center tabindex=-1>
From: Remi Michalowski [mailto:remi.michalowski@cpp.co.id]
Sent: Monday, September 18, 2006 10:26 AM
To: Fishpro Pvt Ltd
Cc: seafood@ucdavis.edu
Subject: Re: ISO 22 000
Hi Dinesh,
If you are interested, we have started and passed the first step in August.
The second stage will occur in December 2006.
What do you want to know? Are you already ISO 9001?
Rgds.
Dipl. Ing. Remi Michalowski
Deputy General Manager IQA Food Processing
PT. Centralpertiwi Bahari - Lampung, Indonesia
HP + 62 815 4040 484
CPB - Integrated Shrimp Farming. "From Pond to Plate"
A CPP Company. Member of Charoen Pokphand Group
On Sep 18, 2006, at 11:50 AM, Fishpro Pvt Ltd wrote:
Hi,
We are planning to certify our new factory (EU approved Facility process
Tuna for EU, Asia pacific and Japan) under the ISO 22 000 and like to share
invaluable experiences on ISO 22 000 application in fish processing from all
over the globe.
Have a good day
Thanking you,
Dinesh Dhammika,
Quality Assurance Manager,
Ensis Fishing Pvt Ltd,
Male
Maldives
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