S9.4 - Applying HACCP Assessment

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S9.4 - Applying HACCP


assessment

Version FR: 1 March 2021

gmpplus.org
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S9.4 - Support GMP+ FC 2020: Applying HACCP assessment

Index
1. INTRODUCTION ................................................................................................................................3

1.1. STRUCTURE HACCP GUIDELINE........................................................................................................................................3

2. HACCP SYSTEM REQUIREMENTS.....................................................................................................4

2.1. MANAGEMENT RESPONSIBILITIES.......................................................................................................................................4 2.1.1. Defining

quality policy .........................................................................................................................................4 2.1.2. Defining the scope of the HACCP


system .....................................................................................................5 2.1.3.

Tasks, responsibilities and authorisation (TRA)...........................................................................................5 2.1.4. Making resources

available................................................................................................................................5 2.1.5. Management assessment of the HACCP


system ........................................................................................5

3. HACCP BASED PLAN.........................................................................................................................6

3.1. PHASE 1: FORMING MULTI-DISCIPLINARY FEED SAFETY TEAM(S) AND VALIDATION TEAM(S) ..................................7 3.2.
PHASE 2: DESCRIPTION OF FEED........................................................................................................................................9 3.2.1.

Phase 2.1: Description of the end-product in charactaristics of end-products................................9 3.2.2. Phase 2.2: Description of
ingredients and processing aids.................................................................. 10 11
3.3. PHASE 3: DETERMINING THE INTENDED USE OF FEED 3.4. ..................................................................................................

PHASE 4: DETERMINE PROCESS INFORMATION............................................................................................................. 12 3.4.1. Phase 4.1:

Preparing flow diagrams ............................................................................................................ 12


Symbols ...............................................................................................................................................................................13

3.4.2. Phase 4.2: Preparing a floor plan..................................................................................................................


PHASE 5: TESTING PROCESS INFORMATION 14 .................................................................................................................. 15 3.5.

3.6. PHASE 6: DEFINE PREREQUISITE PROGRAMME .............................................................................................................. 16 3.7. PHASE


7: HAZARD ANALYSIS........................................................................................................................................... 17 3.7.1. Phase 7.1: Hazard

identification.................................................................................................................... 17 3.7.2. Phase 7.2: Risk


assessment.............................................................................................................................. 19 3.8. PHASE 8: DETERMINING CRITICAL

CONTROL POINTS (CCP’S).................................................................................... 21 3.8.1. Phase 8.1: Determining control

measure ................................................................................................... 21 3.8.2. Phase 8.2: Establishing critical control points


( CCP’s)......................................................................... 21 3.9. PHASE 9: DETERMINING FEED SAFETY LIMITS FOR
CCP’S............................................................................................ 24

3.10. PHASE 10: MONITORING CCPS................................................................................................................................. 25


3.11. PHASE 11: DETERMINING / CORRECTIONS AND CORRECTIVE ACTIONS................................................................. 26
3.12. PHASE 12: VALIDATION AND VERIFICATION ............................................................................................................. 27

3.12.1. Phase 12.1: Validation of the HACCP system ...................................................................................... 27 Phase 12.2: Verification
3.12.2. of the HACCP system .................................................................................... 28 PHASE 13: DOCUMENTATION AND
3.13. REGISTRATIONS................................................................................................ 30

APPENDIX 1 COMPLETING THE HAZARD ANALYSIS TABLE..............................................................31

APPENDIX 2 SUMMARY OVERVIEW OF CCP’S AND GENERAL CONTROL MEASURES ...................32

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1. Introduction

1.1. Structure HACCP Guideline

The HACCP guideline is intended to support GMP+ FSA certified companies (or companies
who which to) in setting up their in-company HACCP system. The guideline provides an
explanation of the HACCP principles in sections.

The HACCP requirements in the GMP+ standard are predominantly based on the
HACCP criteria as laid down in the Codex Alimentarius. Meanwhile, based on new in-sights (as
ISO22000), some changes and additions were included in the HACCP requirements.

The feed sector is already used to working with measures to ensure feed safety. The feed
regulations and the GMP+ Feed Safety Assurance module (GMP+ FSA) already cover a wide
range of quality requirements for feed. This concerns sector-wide measures. Company specific
situations cannot always be taken into account when preparing these measures.

Since the year 2000, the feed sector has taken the initiative of including the HACCP system in
the GMP+ Feed Safety Assurance module.

The scope of this guideline is to support in feed and food safety assurance. This guide-line is
intended specifically for the management and employees of companies within the feed sector
developing a company specific HACCP system. The manner in which HACCP is described in
current feed Regulations (in particular the EC Regulations 183/2005, (EC) Nr. 178/2002 and (EC)
Nr. 852/2004), the General Food Hygiene Guidelines recommended by Codex (CAP/RCP 1-1969,
Rev. 4-2003) and national and international requirements relating to HACCP management systems
(HACCP-NL and ISO 22000) served as a guideline in preparing this guideline.

For definitions and terminology please check F 0.2 Definition list.

Chapter 24 contains a further explanation of the requirements within the management’s scope of
responsibility. Chapter 3 is a phased plan for setting up a HACCP system. In preparing this
phased plan, the requirements as set out in current legislation or GMP+ FSA module have been
included as much as possible.

Every step of the HACCP process starts with an overview of which paragraphs in the normative
documents are applicable. Within the document the wording ‘must’ is used, this refers to the
HACCP principles that must be followed as described in the normative document.

Helpful tip :
This symbol signifies supplementary and specific attention for the relevant issue.

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2. HACCP system requirements


In order to successful implement a HACCP system, a fundament must be created to fully
support the involved employees. This support falls under the responsibility of top
management. This includes defining quality policy, defining the scope of the HACCP system,
determining tasks, responsibilities and authority, making resources available and management
assessment.

The quality policy, which forms part of the complete business policy, is the platform for the
management to record the organisation's goals in the area of feed safety. The management is
responsible for defining the quality policy by means of practicable objectives and communicating
these to the employees.

The scope and extent of the HACCP system should be indicated. Scope relates to the activities
that the company is responsible or accountable for. This can or will be broader than the scope
of the GMP+ certificate because also non-feed related activities, processes, products or
services, can have a negative impact on the feed safety and should be managed by the HACCP
system (R1.0 & 4.3).

Management should review requests of the Feed Safety Team(s) relating to resources and
facilities required for the creation, implementation and maintenance of the HACCP system and
make these resources available. The employees will be enabled to implement the HACCP
system and comply with work agreements by resources and facilities being made available by
the management. This may pertain to making control equipment available as well as making
personnel and time available in order to allow for inspections to be carried out.

When the entire HACCP system has been developed and implemented, the management must
ensure that the HACCP system is updated and revised if necessary.

For more information on top management responsibilities can be found in the document R
1.0 Feed Safety Management Systems Requirements.

2.1. Management responsibilities


Relating to feed safety, a number of requirements fall directly within the scope of
management responsibility.

2.1.1. Defining quality policy


The quality policy, which forms part of the complete business policy, is the platform for the
management to record the organisation’s goals in the area of food and feed safety. The
management is responsible for defining the quality policy by means of practicable objectives
and communicating these to the employees.
The quality policy should match customer expectations and it should convey that the
organisation is aware it is part of the food and feed chain.

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The management subsequently ensures that development and implementation of the HACCP system
progresses according to plan and is updated and adjusted as and when required.

R 1.0 Feed Safety Management Systems Requirements

2.1.2. Defining the scope of the HACCP system

R 1.0 Feed Safety Management Systems Requirements


§ 5.2. Feed safety policy

2.1.3. Tasks, responsibilities and authorisation (TRA)


When setting up a HACCP system, it is important to record the tasks, responsibilities and
authorisation of employees relating to food and feed safety.

This pertains to employees involved in the manufacturing process of the animal feed or
involved in control and monitoring of feed safety.

R 1.0 Feed Safety Management Systems Requirements


§ 5.3.1 Top management’s Responsibilities and Authorities §
5.3.2 Responsibilities of the Feed Safety Team Leader § 5.3.3
Responsibilities of the Validation Team § 5.3.4 Responsibilities
of all persons involved

2.1.4. Making resources available


Where corrective measures, verification procedures or customers indicate that operational
improvements are required, the organisation should review and assess these aspects and where
necessary make adequate resources available in order to guarantee feed safety.

The employees will be enabled to implement the HACCP system and comply with work
agreements by resources and facilities being made available by the management. This may
pertain to making control equipment available as well as making personnel and time available in
order to allow for inspections to be carried out.

R 1.0 Feed Safety Management Systems Requirements


§ 7.1. Resources

2.1.5. Management assessment of the HACCP system


The quality objectives, where necessary, may be further specified where possible. This will provide a
mechanism allowing for assessing the effectiveness of the HACCP system at regular intervals.

R 1.0 Feed Safety Management Systems Requirements

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3. HACCP Based plan


Hazard Analysis & Critical Control Points, HACCP, is a process control system relating to feed and food safety and
may be set up and applied in combination with other quality systems. The HACCP plan consists of the following
phases:

HACCP based plan


Phase 1 Forming multi-disciplinary Feed Safety Team(s) and
Validation Team(s)
Phase 2 Description of feed
Phase 3 Determining the intended use of feed
Phase 4 Determine process information
Phase 5 Testing process information
Phase 6 Define prerequisite programme
Phase 7 Principle 1 Hazard analysis
Phase 8 Principle 2 Determining critical control points (CCP’s)
Phase 9 Principle 3 Determining feed safety limits for CCP’s
Phase 10 Principle 4 Monitoring CCP’s
Phase 11 Principle 5 Determining corrections and corrective actions
Phase 12 Principle 6 Validation and verification
Phase 13 Principle 7 Documentation and registration

These phases will be described in detail in the following paragraphs.

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3.1. Phase 1: Forming multi-disciplinary Feed Safety Team(s)


and Validation Team(s)

R 1.0 Feed Safety Management Systems Requirements


§ 5.3.1 Top management's Responsibilities and Authorities
§ 5.3.2. Responsibilities of the Feed Safety Team leader §
5.3.3 Responsibilities of the Validation Team

As described in the standards, the management of the company is ultimately responsible for the
Feed Safety Management System of the company. Management must appoint Feed Safety
Team(s) and Validation Team(s). The management shall ensure that members of both the Feed
Safety and validation Teams will have adequate time and (if necessary) resources available for
setting up and implementing, respectively validating, the Feed safety Management System
including the HACCP system.

The Feed Safety Team is a team within the organisation that supervises setting up and
implementation of the HACCP system. In addition to implementation, the Feed Safety Team is
designated a role in updating and verification of the HACCP system. The HACCP system is
specific for each company.

The Validation Team is also a team within the organisation. The Validation Team’s aim is to
determine if the HACCP system as set up by the Feed Safety Team will perform as intended in
practice. This is referred to as validation (see phase 12).

Both large and small businesses are required to compose both a Feed Safety Team and a
Validation Team. The size of these teams depends on the organisation’s size as well as the
expertise of the team members. The implementation of a HACCP system requires technical
expertise as well as expertise in feed and food chemistry, toxicology, microbiology and quality
management. The more comprehensively these fields of expertise are represented in both teams,
the more complete the HACCP system can be expected to become.

Helpful tip :
If necessary, companies should deploy the services of qualified external experts.

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In addition to the various fields of expertise, team members should come from the various hierarchical levels
of the company. This should ensure that the HACCP system will be supported throughout the company.

The following fields of expertise may be represented in the Feed Safety and/or Vali-dation
Team:

a. Management representative: Decision-maker b. Process


expert: An employee responsible for, or closely involved in, the production
process (for example the production manager). This employee should have knowledge of the operating
methods on the production floor.
c. Quality coordinator, with insight into quality of ingredients and end-product, with
knowledge of microbiological, chemical and physical hazards relating to specific products / processes.

d. Production employee: an employee (for example production supervisor) with knowledge of the hygienic
status of the company, production spaces and installations. e. Other: Depending on the company’s activities,
i.e. if applicable, the following fields of
expertise should also be represented: Expert relating to purchasing, storage, forwarding, sales, nutritional
and agricultural issues.

Members of the Feed Safety Team may be a member of the Validation Team too. However, the Validation
Team must preferably also contain independent members who are not a member of the Feed Safety Team
in order to prevent influence: Select employees not directly involved in preparing the HACCP plan.

Helpful tip :
Companies with a limited number of employees (or companies without any staff) should hire external support for
the implementation and validation of their HACCP system (for examples suitable persons working within the sector
or external consultants).

Both the management representative and the quality coordinator within the Feed Safe-ty Team must
attend HACCP training or the team members must have attained a simi-lar level based on experience.

According to the standard, the company must record the members of both the Feed Safety and Validation
Teams as well as the fields of expertise of their team members in a document or add this to existing
documentation. The fields of expertise must be verifiable, for instance based on diplomas or demonstrable
work experience. If the required expertise is not available within a company, external experts may be involved
in the team’s activities. External expertise must also be recorded in the documentation.

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3.2. Phase 2: Description of feed


3.2.1. Phase 2.1: Description of the end-product in characteristics
of end-products

R 1.0 Feed Safety Management Systems Requirements


§ 8.5.1.2 Characteristics of end-products

TS 1.2 Purchase
TS 1.3 Product list
TS 1.4 Forbidden Products and Fuels
TS 1.5 Specific feed safety limits

Information regarding end-products is required in order to be able to correctly assess the


hazards that may occur during the manufacturing process or the type of hazards that the end
products (the feed) may entail to humans or animals. The HACP Feed Safety Team shall chart this
information based on characteristics of end-products of

Characteristics of end-products provide an initial indication of possible hazards. In addition to the


ingredients used (raw materials, additives) and nutritional values of the end product, other features
must be mentioned that may influence food and feed safety. This may relate to chemical, physical
and microbiological features (in the sense of polluting or undesirable substances) or the required
conditions for production, storage and transport. The feed safety limits from TS 1.5 must be taken
into account and included in the specification. The characteristics of the end-products must be
considered by the Feed Safety Team when setting up and implementing the company-specific
HACCP system.

In principle, each end-product must be described separately in a specification. For practical


reasons, creating product groups is allowed. However, the products must be classified into
groups in such a manner that differences in ingredients or processing steps do not lead to
additional hazards.

Characteristics of end-products can be prepared based on a so-called three- category system.


1. Generally applicable requirements and features for feed can be recorded once. These
features can then apply to all feed manufactured in a company. This applies, for example, to
Microbiological requirements, such as ‘salmonella not present in 25 grams’.
2. The same can be done for features similar for a certain animal species (often a product group).
3. Features specific to a product can be recorded at article level.

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3.2.2. Phase 2.2: Description of ingredients and processing aids

R 1.0 Feed Safety Management Systems Requirements §


8.5.1.1 Characteristics of ingredients

TS 1.2 Purchase
TS 1.3 Product list
TS 1.4 Forbidden Products and Fuels
TS 1.5 Specific feed safety limits

The requirements that apply to the end-product (for example feed safety limits of
contaminants) are partially determined by the ingredients and processing aids used. This includes
feed materials, premixes, additives and processing aids. Inspection of ingredients and processing aids
based on specifications is necessary.

The information relating to the ingredients and processing aids, and their growing/ harvesting/
mining process is required for the execution of the hazard identification of the company’s
manufacturing process (see phase 7 of the HACCP analysis).

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3.3. Phase 3: Determining the intended use of feed

R 1.0 Feed Safety Management Systems Requirements


§ 7.4.2 External communication § 7.4.3 Internal
Communication § 8.5.1.3 Intended use

TS 1.8 Labelling

Considering the target group(s) prevents hazards from being overlooked. This concerns hazards
to animals as well as hazards that may be incurred by the human customer of the animal products.

The characteristics of the end-product serve to record the target species of the feed. Not all feed are
(in their normal form) suitable to all animals. For example in the case of raw soy beans. Before being
used as an ingredient in piglet feed, these must be toasted in order to remove the harmful trypsin
inhibitor. Another example is that high copper levels in sheep feed have a toxic effect, whereas copper
must be added to the feed of many other animal species.

The characteristics of the end-product must also record the animal species, the age of the animal
and the instructions of use (including storage conditions). This may also be subject to varying
requirements.

The Feed Safety Team shall review how the feed is to be stored and used as in-tended without any
hazards to animal or public health occurring.

The information on the label must at least comply with the applicable feed legislation, but if improper
use of feed may lead to unsafe animal products, a (supplementary) set of instructions relating to
transport, storage, processing and feeding must be sup-plied with the relevant products.

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3.4. Phase 4: Determine process information


The Feed Safety Team shall prepare a comprehensive and up to date description of all
business processes in the form of flow diagrams and a floor plan.

3.4.1. Phase 4.1: Preparing flow diagrams

R 1.0 Feed Safety Management Systems Requirements


§ 8.5.1.4 Flow diagrams and description of Processes
§ 8.5.1.4.1 Preparing flow diagrams

The Feed Safety Team shall prepare a flow diagram of the production process for each
product (or product group). These flow diagrams must indicate the process phases to be
followed in order to create a certain end -product. The process diagram should also indicate the
ingredients, processing aids and auxiliary substances used and any by-products created by the
process.

Each process, production or processing phase must be indicated separately in the flow
diagrams. Hazards can be identified based on these company specific flow diagrams (see
phase 7 and further).

When preparing the flow diagrams, the following are key issues. a.
select a end-product or product group b. define the description of
the process (start - end) c. prepare simple, clear diagrams d. to
enhance clarity and overview, restrict the number of symbols e.
use uniform terminology for products and/or processes f. try to work
top down and left to right as much as possible g. prepare a core
process for the end-product or product group h. divide the core
process into sub-processes i. indicate the links between sub-processes
with start and end symbols j. indicate ingredients, processing aids,
auxiliary substances, semi-finished products, by products, end-products,
return flows and waste flows

A flow diagram may be subdivided into a core process and sub-processes. Defining a core
process may be useful if the process is complicated and includes many process phases and/or a
large number of inbound and outbound flows.
The key process phases of the production process are included in the core process diagram.
Each core process phase is specified in a sub-process diagram, where all process steps are
indicated separately.

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Symbols
Using the following symbols when preparing flow diagrams is recommended.

Symbol Explanation

Opening or closing symbol This symbol indicates the beginning and end of the process
diagram. If it is used as a start symbol, the name of the
relevant sub-process can be entered. If it is used as an end
symbol, the name of the next sub-process can be entered.
This shows how the various sub-processes are interlinked.

Core process phase This symbol indicates the main activities or actions within
a section of the process in the core (global) process
diagram. The core (global) process phases are described
in further detail in sub-process diagrams.

Process phase This symbol indicates an activity or action (a process phase).


Based on the process phases, the hazards are always
identified (see phase 7).

Product This symbol indicates a tangible product (for example an


ingredient, semi-end product or end product) or other tangible
matter (for example steam or air) that enters or exits the
process.

Connection symbol This symbol indicates that the specific product flow is shown
in detail in a different place in the process diagram. It is also
possible that the product flow is derived from a different place
in the production
process.

Indicating a letter or digit in the symbol can help distinguish the connections.

For a detailed example, please refer to the risk assessments as part of the Feed Support
Products on the website of GMP+ International.

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3.4.2. Phase 4.2: Preparing a floor plan


R 1.0 Feed Safety Management Systems Requirements
§ 8.5.1.4 Flow diagrams and description of Processes §
8.5.1.4.2 Preparing a floor plan

A floor plan of the company units offers support when systematically charting and verifying the
production processes.

A floor plan serves to indicate the company’s infrastructure. This concerns an over view of: a.
The various company units (for example production and storage) and personnel facilities. b.
Machines and equipment present (for example technical drawings of the conveyor
installations).
c. The routing of feed and ingredients through the company, of waste and of personnel in
order to make any cross-contamination points visible.

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3.5. Phase 5: Testing process information

R 1.0 Feed Safety Management Systems Requirements


§ 8.5.1.4.3 On-site conformation of Flow diagrams and Floor plan

After preparing process information (flow diagram and floor plan), these must be tested
against practice by the Feed Safety Team.

This ‘reality check’ entails for the Feed Safety Team to walk through the processes during
working hours on site (verification of the process diagram). If the same actions are carried out by
various persons and/or teams, it is important to test the flow diagrams against the working
methods of all these persons and/or teams - for example, does the night shift work in exactly the
same manner as the day shift?
If practice indicates that process phases were overlooked, the process flows
must be adjusted.

The accuracy of the lay-out of the floor plan must be checked and adjusted where needed.

Furthermore, when a process is updated or changed, the process must be retested to practice
and re-validated (see phase 12). The changes must also be implemented in the flow diagrams.

This test is intended in order to ensure that the further HACCP steps are followed with the
correct process information. If the process information and the observations in working
practice are matches, the teams may proceed with the next phase.

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3.6. Phase 6: Define prerequisite programme

R 1.0 Feed Safety Management Systems Requirements


§ 8.2 Prerequisite programmes (PRPs)

TS 1.1 Prerequisite programme

A minimum level for controlling feed safety must be applicable before implementing HACCP.
This basic level must be realised by determining and applying a prerequisite programme.
Prerequisite programmes create environmental and operating conditions required for delivery of
safe feed. The prerequisite programme is part of the GMP+ FSA module.

The prerequisite programme consists mainly of general control measures for controlling
general hazards. These include pest control plans, cleaning and sanitising plans, training plans and
buying procedures. These general control measures form a basis for effective application of the
hazard analysis for each feed company (Principle 1).

The prerequisite programme as included in the GMP+ FSA module is based on the
HACCP Certification Scheme Foodstuffs, the General Principles of Food Hygiene’ of the Codex
Alimentarius and the applicable feed legislation (Animal Feed Hygiene Regulation 183/2005).

The GMP+ certified company must check which elements in the prerequisite programme are
applicable to the company.

The GMP+ certified company must determine if the prerequisite programme is an adequate basis
for successful application of the HACCP principles. If this is not the case, the certified company
must specify and implement supplementary prerequisites.

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3.7. Phase 7: Hazard analysis

R 1.0 Feed Safety Management Systems Requirements


§ 8.5.2 Hazard analysis § 8.5.2.1 Hazard identification §
8.5.2.2 Risk Assessment

The hazard analysis consists of 2 components, the hazard identification (possible hazards) and risk
assessment (from possible hazard to realistic risk). Phase 7.1 further specifies hazard identification
and phase 7.2 further explains risk assessment.

3.7.1. Phase 7.1: Hazard identification

Based on the information collected until this moment (during phases 2 through 6) and the flow
diagrams, a list is prepared of the hazards that may realistically be expected in each phase of
the process. This activity is referred to as hazard identification and forms part of the hazard
analysis.

The Feed Safety Team determines the hazards for each process phase as comprehensively as
possible. Where necessary it is recommended to deploy external experts in these brainstorm
sessions in order to preclude incompleteness, as external people will notice things overlooked by
those working in a company every day.

Identified hazards are to be described. When defining the hazard, a brief description of the cause
and/or source/root cause of the hazard can be included. This makes deter-mining subsequent
control measures simpler (see phase 8).

A hazard can be described as a contamination of feed, or a condition leading to


contamination of feed, with possible negative implications for human or animal health.

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Type of Description Examples


hazard

Chemical Undesirable chemical substances that Undesirable Substances and


hazards may render the product unsafe for Products:
consumption. These may be present in Residues of pesticides, hormones,
the ingredients or contaminate the product antibiotics, heavy metals, environ
during production, for example due to mental pollution, mycotoxins, PCB’s,
carry-over. dioxins, cleaning agents, lubricants,
mineral oils etc.
Higher concentrations of desirable
substances may also form a hazard, Residues of additives and veterinary
making the product unsafe for medicinal products
consumption.
Processing aids

Biological degradation products

Criteria for fat fraction

Minerals and acid residues

Microbiological Pertaining to presence of undesirable Veterinary risks


hazards micro-organisms. The micro organisms (animal diseases)
may cause contamination or growth due
to their (natural) presence, making a Pathogenous organisms: Salmonella,
product unsafe for consumption. Enterobacteriaceae and Fungi (the latter
Consumption of the product may in such group as indicator organisms).
cases cause food infections or food
poisoning.
We can distinguish vegetative micro
organisms, toxigenous (toxin forming)
micro-organisms and spore-forming micro-
organisms.

Physical hazards Foreign bodies that may be present in Glass, plastic, metal parts, stones,
ingredients or may enter the product. bone, pieces of packaging

This makes the product unsafe for the


animal.

Helpful tip 1:
The hazard should be described in as much detail as possible. In the case of pathogens, the description should
indicate if it concerns for example salmonella or listeria. In the case of contamination with foreign particles, the
description should indicate if it concerns glass, plastic or metal for example. These details are also required for any
chemical contaminants.

This detailed description is desirable because various possibilities for monitoring and control
may be required. For example, metal may be separated by means of magnets, but this control

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measure would be ineffective for glass. This is why general terms such as ‘foreign bodies’
cannot be used.

As mentioned above, the information resulting from phases 2 through 6 (end-product and
ingredients specifications including intended use and process information, a list of possible
hazards must be prepared.

Helpful tip 2:
Generic risk assessments such as those recorded in the Feed Support Products may be used as a source of
information. These generic risk assessments describe any generic hazards per process phase.However, each
company should review which (additional) hazards would apply to their specific situation.

Other sources of information are the GMP+ International quality series with details on various
subjects, including a study into drying processes within the feed sector. These information
sources may be consulted on the website of GMP+ International.

Helpful tip 3:
The hazards as identified must be recorded per process phase, using the hazard analysis table. For an example
of such a table, see Appendix 1 of this guideline.

3.7.2. Phase 7.2: Risk assessment


Subsequently, the Feed Safety Team should determine which possible hazards as defined
under 7.1 are actually a risk. The term risk is defined by two elements: severity and likely
occurence of a potential hazard. The hazard must be of such a nature that eliminating or
reducing to an acceptable level is essential for manufacturing safe feed (severity and which
realistically could be expected to occur (likely occurence).

Severity is the effect on the target animal's health as well as the consequential damage for
humans when products of animal origin are consumed. Severity must be based on literature,
practical experience and/or experimental data etc., and is classified into three levels:

Severity Explanation

High Serious diseases, harmful effects and/or wounds, both occurring immediately and long-term effects,
possibly with fatal consequences.
Medium Substantial diseases, harmful effects and/or wounds, both occurring immediately and long-term
effects.
Low Minor diseases, harmful effects and/or wounds, not or hardly occurring, or only long-term effects after
extremely high doses.

Both the severity for the target animal as the severity (consequential damage) for humans must
be determined. The highest value is leading.

Helpful tip 1:

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The Fact Sheets undesirable substances and products may be used as a source of information. These can be
consulted on the website of GMP+ International.

Likely occurence is the chance of a hazard being present in the end-product at the time of
consumption by the target animal and/or human. Likely occurence is based on measurements,
observations or expectations of the company specific situation and may be classified in three
levels:

Likely occurence Explanation

Low theoretically possible, but hardly occurs in practice may occur, it has
Medium been known to occur with some frequency occurs frequently
High

Severity x Likely oocurence results in Risk, which may be classified in four levels:

Likely occurence of presence in product

Low Medium High 4

Severity of the ÿÿ
High 3 4

hazard Medium 2 3 4

Low 1 2 3

A company can ensure that likely occurrence of risk is reduced and controlled by
taking (control) measures. The next section provides more information about this.

If the risk assessment of the hazard results in 4, it does not involve a critical control
point (CCP). This determination will be made during the next phase in HACCP
analysis. This serves to determine if a risk actually concerns a CCP. However, the
company must realise that action is required for higher risks.

Helpful tip 2:
Risk assessment must be recorded for each process phase, including a brief motivation of the elements probability
and seriousness. This motivation serves to clarify the choice that the Feed Safety Team made using the hazard
analysis table. For an example of such a table, see Appendix 1 of this guideline.

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3.8. Phase 8: Determining critical control points (CCP’s)

R 1.0 Feed Safety Management Systems Requirements


§ 8.5.2.3 Establishing Critical Control Points (CCPs)

3.8.1. Phase 8.1: Determining control measure


After determining the risk category, the Feed Safety Team must determine which measures are
required at which part of the manufacturing process in order to control these risks, i.e. prevention or
reduction to an acceptable level. These measures are called control measures.

Classification into risk categories determines the control measures to be implemented. The
following may be discerned:

Risk category Control measures

1 No control measures required

2 No control measures required, but conclusion must be re-assessed


periodically during the annual verification audit.
3
Control measures required In general, control by means of general
control measures from the prerequisite programme will suffice.
4 Specific control measures are required, specifically developed in order to
control risk.

Control measures may vary from technical / technological solutions to organisational and/or
procedural measures.

Helpful tip :
Various control measures may be required in order to control a single determined risk. It is also possible for a single
control measure to control various risks.

3.8.2. Phase 8.2: Establishing critical control points ( CCP’s)


Subsequently, for each risk and associated control measure, the Feed Safety Team must assess if
this control measure is to be the last measure in the process for controlling the risk. If yes, that point
in the process is a critical control point (CCP).

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The assessment if a control measure relates to a critical control point should take place
systematically. One of the instruments to be used is the CCP decision tree. Each phase in the
manufacturing process with associated risk and control measure must be run through the CCP
decision tree.

1
None

Question 1
What type of control measure 2 None
(phase 8.1) is required ac
Are the relevant
cording t o the risk control measures and
assessment (phase have these been
7.2)? Prerequisite If required, prepare include in validatio
3 n verification
control
(Phase

4 Control measure

Question 2 Stop production


Are the relevant control change the process
measures present and have NO product and start wit h
t hese been implement ed?

YES

Question 3 I s
this cont rol measure
specifically intended for
eliminating this risk or reducing YES CCP
it t o an ac cept able level during this
process phase?

NO

Question 4 Will
the risk be eliminated or reduced to
NO CCP
an ac ceptable during one of the s
ubsequent process phases?

YES

N o CCP inc lude in validation and


verification procedures
(Phase 12)

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Measures related to critical control points (CCP’s) are classed as Control Measures. Control
measures may relate to (process) parameters that can be controlled in such a manner that
hazards relating to feed safety are prevented, eliminated or reduced to an acceptable, for
example time, temperature, humidity and pH.

Control measures must be supported by instructions or specifications, training and education.


Control measures must be monitored (see phase 10), accompanied by corrective measures
(see phase 11) and the control measures must be validated and verified (phase 12). These
obligations will be described in detail in the following phases.

Control measures not related to critical control points (CCP’s) are classed as Prerequisite
control measures. Prerequisite control measures are actions or activities that are often part
of the prerequisite programme, such as training of personnel, lay-out and interior of the company
premises, pest control and cleaning and sanitising programmes, purchasing, etc. In general,
these prerequisite control measures ensure and acceptable control level.

Prerequisite control measures must be validated in order to demonstrate adequate


performance of the prerequisite programme (see step 12.1). The prerequisite control
measures are approved after validation by the Feed Safety Team.

The effectiveness of controlling the identified hazard by means of prerequisite control


measures must be verified (see phase 12.2) by means of planned regular intervals.

Helpful tip :
Determining a critical control point (CCP) must be recorded. The hazard analysis table may be used for this
purpose. For an example of such a table, see Appendix 1 of this guideline.

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3.9. Phase 9: Determining feed safety limits for CCP’s


R 1.0 Feed Safety Management Systems Requirements
§ 8.5.3 CCP control § 8.5.3.1 Determine feed safety
limits for CCPs

TS 1.5 Specific feed safety limits

Based on the decision tree, the critical control points (CCP’s) within the process have been
determined. This concerns the (process) parameters (for example time and temperature) that can
be controlled to such an extent that risks are prevented, eliminated or reduced to an acceptable
level.

During this phase, the measuring values for these CCP’s where safe product can be delivered
must be determined. Within the GMP+ FSA module, these values are referred to as the rejection
limits. A rejection limit is a value indicating the line between acceptable and non acceptable
product. If this limit is exceeded, the product is not suitable for use as feed.

In order to limit the presence of risks as much as possible and prevent rejection of product, an
action limit can also be determined. An action limit for the relevant product or process parameter
is derived from the rejection limit and must be substantially lower. When this limit is exceeded, the
cause must be found and corrective measures must be implemented in order to either resolve or
limit the cause.

When determining the action and rejection limits relating to CCP’s, it is mandatory to comply with
requirements as set out in the relevant feed legislation and the GMP+ FSA scheme. In TS 1.5
Specific feed safety limits) of the GMP+ FSA scheme, these action and rejection limits are included
in an overview.

If action or rejection limits are not set out in legislation or the GMP+ FSA scheme, the feed
safety limits relating to the CCP’s must be set, supported and recorded based on internal
research.

Helpful tip :
See Appendix 2 for an example of a summary overview of a CCP.

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3.10. Phase 10: Monitoring CCPs

R 1.0 Feed Safety Management Systems Requirements §


8.5.3 CCP control § 8.5.3.2 Monitoring CCPs

TS 1.2 Purchase
TS 1.6 Sampling
TS 1.7 Monitoring

The feed company must prepare and implement a monitoring plan. Monitoring is measuring, analysing
and/or observing (visual supervision) of process parameters according to a plan in order to be able to
determine if a CCP is controlled.

Monitoring CCP’s may relate to continuous, semi-continuous or random sample measuring, depending
on the process phase and the nature of the (process) parameter to be measured.

The results of monitoring must be documented.

Helpful tip :
See Appendix 2 for an example of a summary overview of a CCP.

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3.11. Phase 11: Determining / corrections and corrective actions


R 1.0 Feed Safety Management Systems Requirements
§ 8.7 Control of Product and Process nonconformities
§ 8.7.1 Define corrections and Corrective actions §
8.7.2 Handling of potentially unsafe products

After determining the action and rejection limits and preparing a monitoring programme, the
company must determine which corrections and corrective actions must be carried out when a
limit is exceeded in spite of the measures. The safety of the end-product is then no longer
controlled.

Corrections
Corrections are actions to eliminate a detected nonconformity. A correction may be, for
example, reprocessing, further processing and/or elimination of the adverse consequences of
the nonconformity (such as disposal for other use or specific labelling).

Corrective actions
Corrective actions: eliminates the cause of a non conformity and prevents recurrence. These
actions ensures that the cause of the nonconformity is detected and eliminated and can
therefor not result again in an exceeded limit. Corrective actions can be, for example,
adjustments to equipment, adjusting the production process and/or choosing different
suppliers or country of origin of feed ingredients.

In the absence of continuous monitoring, corrections and corrective actions must relate to
the relevant lot from the previous measuring moment.

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3.12. Phase 12: Validation and verification


Before being implemented, the HACCP system must be assessed in order to ensure it can
perform as intended. This is referred to as validation. This is phase 12.1. Subsequently, the
HACCP system is implemented, whereupon the company must verify if it works as intended
within the operational environment. This is phase 12.2.

3.12.1. Phase 12.1: Validation of the HACCP system


R 1.0 Feed Safety Management Systems Requirements
§ 8.6 Validation & Verification § 8.6.1 Validation § 8.6.2
Verification

Before implementing the HACCP system, the company must determine if the HACCP system
can perform in the operating environment. The company must determine if the control measures
developed, including the cleaning programmes or the metal detectors present will be adequate
for controlling hazards. This is referred to as validation.

The following aspects must be assessed:


a. is the list of potential hazards based on sound scientific data and is it complete; b.
were the questions asked in order to test the impact of the risks answered based on
sound scientific data and technical knowledge;
c. are the control measures (both general and specific) sufficient to control the hazards; d. will
fluctuations within the features to be controlled (equivalent to process criteria) within the
recorded critical limit values have no impact on product safety; e. are the features and
methods used in order to monitor the control measures adequate; f. are corrective measures
adequate and will these prevent an unsafe product from being released and do these
demonstrate that the situation may be corrected immediately;

Each time the organisation implements changes that may have a negative impact on feed
safety, the assessment must be updated. Examples of changes are: a. new ingredients or new
products, the production conditions (company units and
buildings and the immediate surroundings of the company, cleaning programmes);
b. storage or transport conditions; c.
changes to the customer's use of the product; d. all
information indicating a new hazard relating to the product.

The validation must be conducted by the Validation Team. More information is included in
phase 1 Forming the Feed Safety Team and Validation Team.

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3.12.2. Phase 12.2: Verification of the HACCP system


R 1.0 Feed Safety Management Systems Requirements
§ 8.6 Validation & Verification § 8.6.1 Validation § 8.6.2
Verification

After the HACCP system has been set up, verification of (elements of) the system must
periodically (at least annually) take place. Verification is the use of additional information in
order to test if the system is still effective and used as it was in- tended. Verification is conducted
by the Feed Safety Team and the findings must be recorded in writing.

Verification of (elements of) a HACCP system must consist of:


a. Evaluation of the HACCP system and the recorded registrations.
This includes testing all specific control measures, deviations and corrective measures in
order to confirm implementation and effective control of critical control points (CCP’s).
Testing all general control measures in order to confirm implementation and
demonstrating effective control of related hazards.

b. Assessment of the prerequisite programme.


The Feed Safety Team must review if the prerequisite programme as prepared still
matches the actual situation.

c. Assessment of product analysis data.


Periodical testing of end -products on microbiological and chemical features is a way to
check if the HACCP system still works as intended. The end product specification must be
used. If analysis results do not comply with end- product specifications, corrective measures
must be taken.

d. Verification of the hazard analysis.


The flow diagrams, floor plan and hazard analysis specific to the company must be
reviewed as often as required. This enables the company to ensure if these still match
reality and if any new or additional hazards may occur pertaining to ingredients or the
production process. The Feed Safety Team shall record how frequent such a revision
should be conducted, but must at least be re viewed once per year and immediately after
new relevant information is avail- able.

This revision is relevant when:


1. a crisis / calamity has occurred or is suspected;
2. a report is issued by the Early Warning System;
3. news in the media is released; 4. hazard analyses
are updated at chain level; 5. other indications arise
(own sampling, databases); 6. changes are made to
the production process.

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It is possible that hazards remain denied or undetected for years. At the time where a
company has gained insight into the potential hazard, it must immediately be included in
the company specific HACCP plan. Not only external factors also results of internal sampling
of ingredients, end- products and/or results from databases can provide input to re-assess
and, if necessary, revise, the internal hazard analysis.

e. Assessing implementation of legislation and regulations


The Feed Safety Team must review if all actions are still in accordance with the applicable
legislation and regulations relating to food and feed safety. The Feed Safety Team must
also continuously remain up to date with any changes to legislation and regulations,
including: if there are any changes to the legal or GMP+ standards.
More information is included in chapter 3 of this guideline.

f. Assessment of personnel’s knowledge level


The Feed Safety Team must assess if the current personnel knowledge level relating to
feed and food safety and hygiene still comes up to required standards. If not, training is
required.

g. Internal audits
A large number of hazards are controlled by general procedures, regulations and
instructions. These procedures and instructions define many elements of the prerequisite
programme. An audit also aims to check compliance with procedures and instructions. In
particular verification of the prerequisite programme, which covers a large number of
general hazards, is vital for the system’s performance.

h. Analysis of complaints relating to food and feed safety of products.


Processing complaints within a HACCP system also provides information relating to the
HACCP system’s effectiveness.

The results of verification must be documented. The Feed Safety Team, which will continue
to play a role in maintenance of the system, must assess the verification results and submit
its findings to the management. The management shall use their findings in its own
management assessment as described in chapter 4.1.5.

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3.13. Phase 13: Documentation and registrations

R 1.0 Feed Safety Management Systems Requirements


§ 7.5 Documented information

All other sections of the scheme can also indicate the required documented information

Documentation plays a vital part in maintaining a process control system based on HACCP
principles. Documentation ensures the demonstrable presence of the HACCP system.
Documents also provide information to employees regarding the activities to be carried out and
agreements made within a company. The required documentation derived from the
implementation of HACCP can be included in the quality documentation as required by the
GMP+ standard.

The following documents can be considered as relevant document information related to the
HACCP system: a. Document Feed Safety Team (members and fields of expertise) b. Motivation
of HACCP analyses with support of choices made, for example:

Minutes of the Feed Safety Team meetings


c. End- product specifications or end-product group specifications; d.
Flow diagrams and a floor plan e. Prerequisite programme as applied
by the company f. Hazard analyses (tables) g. Determination and
description of CCP’s (in a table or overview and where required
supplemented by documentation h. Determining action and rejection limits i. Corrective
measures j. Description of validation and verification of the HACCP system

Registration
After implementation of the HACCP system, data are collected in various places that must be
registered. This concerns: a. Monitoring data of CCP’s and general control measures b.
Verification of CCP’s

c. Verification of the HACCP system by means of taking samples and sample analysis of
products
d. Verification of the hazard analysis
e. Internal audits f. Complaints analysis

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Appendix 1 Completing the hazard analysis table


When identifying hazards in each process phase and walking through the CCP decision tree, the hazard analysis table can be completed line by
line. This also ensures that the HACCP analysis has been demonstrably conducted (with documented evidence).

Please Note: The template below also applies to the company specific HACCP analysis. A different template should be used for completing the
hazard analysis in the context of the Risk Assessments as part of the Feed Support Products.

The hazards are identified for each For each hazard, A risk assessment is conducted for each The (control) Is the determined control measure This column should always contain a
process step in the flow diagram indicate in which of the three hazard. Probability x seriousness and the measures for risk class the last step in the process to control summary motivation of the elements
(phase 7) and entered into the hazard categories the hazard is resultant risk class are entered into the 3 or 4 are summarised the risk? This assessment must take place Likelyhood x severity. This motivation serves
analysis table. The columns Nr, classified (M: Microbiological, relevant columns. in this column. This may systematically. One of the instruments to be to clarify the choice that the HACCP made.
Process phase and Description of C Chemical, P Physical). used is the CCP decision tree. Each phase in Additionally, this information may be used for
Hazard are to be completed in the table concern measures the manufacturing process with associated subsequent verifications and also by later
line by line. that are part of the risk and control measure must be run through Feed Safety Team after their composition
prerequisite programme or the CCP decision tree. has changed. This way, the considerations
measures included remain accessible and available.
elsewhere in the GMP+ FC
Scheme.

This column must be completed if it concerns


a CCP.

(The questions below relate to the decision


tree)
Nr. Process Description of Cat. Likelyhood of Severity Risk Type of Reference Q1 Q2 Q3 Q4 CCP Motivation

phase hazard occurence measure

- - - -
C 2 2 2
1 Purchasing 1

M 2 3 4 4 NN CCP 1

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Appendix 2 Summary overview of CCP’s and general control measures


As is apparent from phases 9 through 10 of the phase plan, action and rejection limits, monitoring programmes and corrective actions must be
prepared for each CCP. In order to enhance clarity, this information can be entered in an overview for each CCP. This table may also contain a
reference to the required procedures, instructions and registration forms (documentation).

From the hazard analysis, it has become apparent that many general control measures (which are often part of the prerequisite programme) play an
essential role in reducing the hazard. It is recommended to summarise these control measures in a table as well. Where possible, indicate monitoring
frequency and corrective actions (this depends on the general control measure and will not be possible in all cases). Also report the required procedures,
instructions, registration forms and other documents.

• Reference to the GMP+ Feed Safety Assurance Scheme (process control)

Example of overview

CCP Description of Standards Monitoring Corrective actions after deviations Documentation


the
control measure

Action limit Rejection limit How Frequency Responsible Description of action Responsible

CCP 1 P

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At GMP+ International, we believe


everybody, no matter who they are
or where they live, should have
access to safe food.

GMP+ International
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2289 CL Rijswijk
The Netherlands

t. +31 (0)70 – 307 41 20 (Office)


+31 (0)70 – 307 41 44 (Help Desk)
It is. info@gmpplus.org

Disclaimer:

This publication was established for the purpose of providing information to interested parties
with respect to GMP+-standards. The publication will be updated regularly. GMP+ International
B.V. is not liable for any inaccuracies in this publication.

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