Practical Realisation of The HACCP Plan
Practical Realisation of The HACCP Plan
Practical Realisation of The HACCP Plan
Ver 1.2
Practical realisation of
the HACCP plan
1
DOCUMENT HISTORY
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Tabe of contents
1. INTRODUCTION .......................................................................................................................4
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AT-04: Practical realization of the HACCP plan
1. Introduction
The examples presented in this document are for illustration purposes only. They should not be used in
analyzing the hazards of the processes present in the company or for the used, stored, transported,
produced and/or traded animal feed in the company.
The references, included in item 3 of this document, are a major source of information as regards the hazard
analysis to be performed by the company:
• For the animal feed
• For each step of the developed processes
There may, at the level of certain sectors, exist a generic approach, providing a hazard analysis for animal
feed.
As for the processes concerned, Annexes have been developed containing HACCP plans, for many activities.
They have been added as subsections (AT-04-01 and next) to this document.
Any overall consulted evaluations, must be reviewed, and adapted according to the processes implemented
in the company.
Any deviation, in the individual assessment of a hazard occurring at sector based level, should be motivated
and described in detail, as regards the company’s hazard analysis.
The definitions of the most commonly used terms, included in this annex, can be found in document ‘AC-00:
Introduction’.
An HACCP-study is a mandatory requirement, involving all companies active in the animal feed sector. For
companies, producing, trading or distributing animal feed, such a study is necessary. This has consequences
for companies who, at first sight are not subject to this obligation (e.g. producers of agro fuels, putting their
by-products on the market, such as DDGS, glycerol, etc.).
This animal feed may also present some hazards (e.g. mycotoxins in DDGS).
One should consider document AT-04 and its subsections as a tool for the companies. A working method
with examples has been proposed. If the company wishes to do so, they may deviate from this and choose
another method.
At the level of Regulation (EC) No. 183/2005 (Art 6), only the concept ‘Critical Control Point’ (CCP) is taken
into consideration. The proposed method however, uses multiple assessment scores (see point 2.9 of this
document), whereby the term ‘Point of Attention’ is also used. However, ‘Point of Attention’ is not applied in
Regulation (EC) No. 183/2005, and is therefore inherent to the proposed method.
One should therefore be aware that the HACCP-analysis of a company or sector, provided motivation, may
differ from this document and its subsections.
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2. How to make an HACCP-PLAN?
2.1. Context
In the context of the realization of the HACCP-plan (more specifically, item 3 in ‘AC-01: General Provisions’)
and the drafting of product specifications, it is necessary to identify various hazards that could occur in
animal feed that has been received, stored, transported, produced and/or traded by the company.
The process, applied by the company itself, could also be a source of a hazard/ hazards.
It might be possible that:
- hazards, present in used products, are enhanced through the activity (e.g. sorting with valorization
of meal waste) ;
- hazards, present in used products, are eliminated through the activity, or reduced to an acceptable
level (e.g. sorting with elimination of meal waste) ;
- new hazards created by the company (e.g. cross-contamination through use of a part of the
installation, without prior emptying, contamination induced by heating at an inadequate
temperature).
The question is whether or not these hazards are presenting a real threat in the context of food safety and
animal health.
2.2. HACCP-principles
In view of setting up a complete HACCP-plan, you should approach your own company with its developed
activities as objectively as possible.
Don’t assume that a hazard will only occur at your neighbors. Don’t be blinded by daily routine either. Even
if your company is doing very well, there is always room for improvement or change. It is also quite possible
that you never give much thought to a particular problem in relation to foods safety. In view of the
structured application of the 7 HACCP-principles we suggest you apply the methods here below.
1
Cfr. Regulation (EC) No. 183/2005 of the European Parliament and of the Council of 12/01/2005 laying down requirements for feed
hygiene
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1.Establish an HACCP team
In order to obtain the most objective vision, it is better to have several individuals present for reflection
purposes. For this reason an HACCP-team should be composed. This team will bring every HACCP-study to a
successful end.
This team must consist of at least two persons. One must also ensure that this team has sufficient
knowledge:
- in the technical field;
- as regards the actual processes, applied within the company.
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This team must also be able to take decisions. Certain proposals which they will be required to make, might
involve investments or modifications of the working methods. The opinion of the company management is
hereby crucial.
The company management will approve the activities of the team. They must also support the team in their
work.
The company will register the composition of the HACCP-team. This composition could change over time. All
expertise is not necessarily required, upon handling the different cases.
The working method applied by the team is included in a general document. A procedure may perfectly
serve this purpose.
VSC
For a VSC (e.g. composed of one person) it is difficult to form a team.
In order to address this problem , the person responsible for the VSC will, at regular intervals, exchange
ideas with other persons (in family circle, with colleagues, a service of a professional federation, etc.) to
confirm or refute each step of his HACCP-plan.
The subsections “HACCP-plans” to this document, is designed as a tool, to facilitate the implementation of
this plan.
You need to define where your study will start and where it will end.
For a production, the study generally starts from the moment you receive the animal feed (whether
physically or not) until the moment, when you transfer the product to your customer.
For trade, the study generally starts from the moment you receive the animal feed (whether physically or
not) until it is sold to your customer.
For other services such as transportation or storage for third parties, the study will start as soon as you
receive the instruction, until he moment you have completed the service performance (e.g. delivery).
Companies that purchase, produce and/or trade animal feed must have a good knowledge of this feed.
The following information is useful in order to perform an HACCP-analysis:
- Name of the product (possible trade name);
- Composition;
- Origin (for purchase outside of Belgium);
- Intended use for the sale (animal feed for the professional (farmer) or for the individual, feed for pet
animals, etc.);
- Storage life;
- Packaging;
- Labeling;
- Conditions for receipt (upon purchase);
- Storage and transport conditions (purchase and sale).
It is best to collect the information available both in the company (for purchase/sale and for the productions)
as well as outside the company (suppliers, literature, professional associations, etc.).
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You can also add the main hazards associated with this animal feed (see below).
You can group this information together into a data sheet (e.g. with the specifications of the purchased and
sold products).
You can also categorize the products with similar characteristics. Instead of treating
Poultry feed one by one for example, you can group them into a single data sheet “Poultry feed”.
In order to visualize the process realized in your company a graphical representation is necessary.
Indeed a picture is worth a thousand words.
Examples of diagrams (also called “Flowcharts”) are given in the subsections of the HACCP plan “activities”.
These plans are to be adapted to your company, but they are a good working basis.
When the diagram has been drawn up by the HACCP-team, verification on-site site is necessary.
For production one must especially pay attention to the flows that might have been forgotten, such as return
flows, addition of steam or water, sieve residues, processing aids, etc.
A hazard is defined as a biological, chemical or physical ‘pollution’ in the product, which may have a harmful
effect on the health of humans animals or plants.
Generally 3 types of hazards have been identified:
Chemical hazards: undesirable substances that can render the product dangerous for human or
animal health. The hazards might already have been present at the time of purchase. They could be
of a natural origin (e.g. attached to the plant from which the feed originates) or of an artificial origin
(e.g. result of contamination from outside sources).
The chemical hazards can also appear during the process itself, for example following the use of a
processing aid, lubricant leakage or leaky pipes.
(Micro) biological hazards: the undesired presence of micro-organisms that can cause a
contamination or a detrimental development rendering the product unsafe for consumption. The
contamination could be present at the time of purchase or may develop during the process.
Physical hazards: This type of hazard is caused by the presence of foreign bodies such as glass,
metal, packing, grains or seeds that are not indigenous to the feed material, etc. It can be present
in the purchased product or it can appear during the course of the process.
The presence of one of the above mentioned hazards is strongly influenced by the various processes the
product has undergone prior to purchase or during its passage in your company.
One should particularly consider, the circumstances as regards cultivation, harvest, storage, production and
transport, which the animal feed has undergone, should be taken into consideration. Consultation of the
HACCP-plans concerning the processes (see for instance the subsection: mineral extraction, production of
animal fat, food industry) can help you to determine the conditions encountered by the product.
Based on a careful study of the legislation in force for the sector (see ‘AT-01: Legislation’) one can usually
determine the general hazards to which the activity and the products are exposed.
Either by product (purchased or transferred to your customer) and/or per process step, you must identify
potential hazards present. These hazards are listed one by one. In order to systematize the task, the HACCP-
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team can rely on the checklist presented in table 1 here below. The hazards can be subdivided in detail
(DON, ochratoxin, zearalenone, etc.) or even grouped (remaining mycotoxins).
Salmonella
Enterobacteriaceae
Other bacteria
(Micro)biological
Moulds
Viral contaminants
Other micro-organisms
Aflatoxin B1
Other mycotoxins (DON, ZEA,
FUM, B1 and B2, OTA)
Pesticide residues
Heavy metals
Chemical Anti nutritional factors
Dioxins
PCB’s
Biogenic amines
Other chemical pollution
(e.g. solvents)
GMO-contamination
Botanical impurities
Insects
Physical Presence of meat meal
Other foreign objects (metal
parts, rests of packaging, stone
chippings, soil, etc.)
Table 1: Hazard examples
Service providers who do not own the animal feed they transship, transport or store, should identify the
hazards for their own work steps only.
When you have listed the hazards, you can also continue your research by applying the method of the “5 M’s
”.
With this very simple method you can go through the possible origins of these hazards. It suffices to wonder
whether the identified hazards could be originating from:
- Material (= the purchased, loaded, transported, stored, manufactured or sold product);
- Milieu (= the surroundings, i.e. transport or storage duration, the installations, the climatic
circumstances, as well as the location of the company;
- Manpower (= persons involved in the company and/or come in contact with the product);
- the method (= the established procedures and instructions as well as the documents used);
- Means (= mainly the equipment or means of transport).
Table 2 shows the method of the 5M, generally applied to the animal feed sector.
This is a suggestion. The company is free to use other methods. The goal is to obtain an inventory as
extensive as possible of potential hazards.
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Once the different hazards have been listed and included in a recapitulating table, the company’s HACCP-
team will perform a hazard evaluation.
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Nature Origin of the hazard
Control Aggravating
of the Hazard Means/
Material Milieu Manpower Method measures factors
hazard Equipment
(Micro) Moulds - product - inadequate - poor use of - lack of - inappropriate - maintenance - moist product
Biological remainder installations equipment control storage and/or and cleaning - humidity, high
- moist or - long term - non-compliance - non- transport of the temperature
contaminated storage with the compliance compartment installations - inadequate
product instructions (i.e. with the (i.e. sealing) - compliance cleaning
cleaning) contractual with frequency
requirements contractual - duration of
or requirements transport and
incomplete (receipt/ parking
requirements dispatch) - Storage duration
- absence of - control too long or
traceability (before inappropriate
loading, on collection
receipt, frequency
during - Product
storage, etc.) microbiologically
- rotation of very perishable
the stocks
Bacteria - Product - inadequate - poor use of - lack of - Inadequate - maintenance - moist product
remainder installations equipment control storage space and cleaning - humidity,
- moist or - long term - non-compliance - non- and/ or of the increased
contaminated storage with the compliance transportation installations ambient
product instructions with the - System of - compliance temperature
- contamination contractual maintaining the with the - inadequate
through staff requirements temperature contractual cleaning
or defective or requirements frequency
incomplete incorrectly (receipt/ - extended
requirements adjusted - dispatch) transport and
- absence of - in case of - control parking time
traceability production: (before - storage duration
- in case of inadequate loading, upon too long or
production: equipment (i.e. receipt, inappropriate
inadequate temperature) during frequency of
treatment storage, etc.) collection
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Nature Origin of the hazard
Control Aggravating
of the Hazard Means/
Material Milieu Manpower Method measures factors
hazard Equipment
(acidification, - rotation of - microbiologically
thermal the stocks very perishable
treatment, - calibration of product
etc) the - in case of
monitoring production:
system (t°, inadequate
pH or other treatment
process
parameters)
- personnel
training
Mycotoxins - product - inadequate - poor use of - lack of - inappropriate - maintenance - humidity,
remainder installations equipment control storage and/or and cleaning increased
- moist or - long term - non-compliance - non- transport space of the ambient
contaminated storage with the compliance (i.e. sealing) installations temperature
product instructions (i.e. with the - compliance - Storage duration
cleaning) contractual with the too long or
requirements contractual inappropriate
or requirements collection
incomplete (receipt/ frequency
requirements dispatch) - inadequate
- absence of - control cleaning
traceability (before frequency
loading, upon - in case of
receipt, production:
during inadequate
storage, etc.) formula of the
- rotation of ‘finished product’
the stocks (in function of
the target
animal)
Insects and mites - product - inadequate Not applicable - lack of Not applicable - maintenance - humidity,
remainder installations control and cleaning increased
- contaminated - (close - non- of ambient
product surroundings compliance installations temperature
) with the - compliance - Storage duration
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Nature Origin of the hazard
Control Aggravating
of the Hazard Means/
Material Milieu Manpower Method measures factors
hazard Equipment
contractual with the too long or
requirements contractual inappropriate
or requirements frequency of
incomplete (receipt/ collection
requirements dispatch)
- absence of
traceability
Birds and rodents (dead - Product - inadequate Not applicable - lack of - facilities or - maintenance - poor general
bodies and macroscopic remainder installations control vehicles and cleaning hygiene
traces) - contaminated - close - non- available of the - inadequate pest
product surroundings compliance (openings, installations control
with the fences, canvas, - compliance
contractual etc.) with the
requirements contractual
or requirements
incomplete (receipt/
requirements dispatch)
- absence of
traceability
In case of conversion of - Category 1 Not applicable Not applicable - lack of Not applicable - compliance
category 3 material and/or category control with the
(rendering of fats): 2 material in (presence contractual
category 3 coloring requirements
Prion (TSE)
material which agent) (purchase
contamination through is collected or - non- contract)
infection germ purchased compliance - collection
with the with
contractual dedicated
requirements transport
or
incomplete
requirements
- absence of
traceability
Animal protein - product - inadequate - poor use of - lack of - inappropriate - maintenance - presence of flows
remainder installations equipment control storage and/or and cleaning with and without
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Nature Origin of the hazard
Control Aggravating
of the Hazard Means/
Material Milieu Manpower Method measures factors
hazard Equipment
- containing - poor use of - non- transport space of the animal protein at
animal protein separation compliance (separation of installations the same site
- contaminated principle with the the equipment - compliance - in case of
product contractual / vehicles) with the production:
requirements contractual inappropriate
or requirements production
incomplete (receipt/ sequence
requirements dispatch)
- absence of
traceability
- poor
separation
between the
flows with
and without
animal
protein
Products with GMO’s - product - inadequate Not applicable - non- - inappropriate - purchase - presence of flows
remainder installations compliance storage and/or specifications with and without
- contaminated with the transport space - maintenance GMO at the same
product contractual (separation of and cleaning site
requirements the equipment of the - in case of
or / vehicles) installations production:
incomplete - compliance inadequate
requirements with the production
- absence of contractual sequence
traceability requirements
(receipt/
dispatch)
Chemical cross-contamination : - product - inadequate - poor use of - non- - Concept of - maintenance - poor
product remainder remainder installations equipment compliance installation and cleaning management of
(animal feed or other) - non-compliance with the of the return flows
with the cleaning installations - if production:
recently transported,
instructions (i.e. procedures - training of poor knowledge
handled and/or cleaning) - absence of staff of the level of
stored - in case of traceability - if production: cross-
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Nature Origin of the hazard
Control Aggravating
of the Hazard Means/
Material Milieu Manpower Method measures factors
hazard Equipment
production: regular contamination of
non-compliance testing for the installation
with the cross-
instructions for contaminatio
use (i.e. n
dosage) of an - if
animal feed production :
establishment
of a
production
sequence
Product flow - product poorly Not applicable - poor use of - non- - unsuitable - training of
transported or stored attached during equipment compliance equipment staff
simultaneously transport (vehicle and with the - compliance
- transport, accessories, contractual with the
transshipment equipment for requirements contractual
or storage of loading and or requirements
damaged unloading, etc.) incomplete
products requirements
- absence of
traceability
If production : Not applicable Not applicable - poor use of Not applicable - concept of the - training of - poor knowledge
increased level of an equipment installation staff of the level of
authorized substance, - non-compliance - calibration of - regular cross-
with the the dosage calibration of contamination of
of an undesirable
requirements installation the dosage the installation
substance or of an (i.e. dosage or installations
additive or medication production
(in case of medicated sequence)
premixtures), by - non-compliance
inappropriate dosage or with the user’s
formulation manual or with
the
requirements
for the
authorization of
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Nature Origin of the hazard
Control Aggravating
of the Hazard Means/
Material Milieu Manpower Method measures factors
hazard Equipment
additives, or
with the
veterinary
prescription in
case of
medicated
premixture
Processing aids - product Not applicable - non-compliance - non- Not applicable - purchase
remainder with the compliance specifications
instructions (i.e. with the - formulation
dosage) contractual - training of
requirements staff
or - compliance
incomplete with the
requirements contractual
- absence of requirements
traceability
In case of food - presence of a Not applicable - Non-compliance - Non- Not applicable - purchase - on site use of
industry: Food additives Food additive with the compliance specifications Food additives
(not authorized instructions (i.e. with the - formulation not allowed in
in FEED) in separation) procedures - separation/ FEED
animal feed for sorting of the
- increased level separation products that
of FEED additive - absence of are revalued
(i.e. vitamins traceability in animal
and/or trace feed
elements in - training of
“enriched” staff
foodstuffs for - compliance
human with the
consumption) contractual
requirements
Undesirable substances - product - inadequate - poor use of the - Non- - unfit transport - Control of the - if production:
/ prohibited materials remainder installations equipment compliance and/or storage stocks inadequate
(i.e. packaging remains) - natural - surroundings - Non-compliance with the space - Rotation of formula of the
presence in the with the procedures the stocks ‘finished product’
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Nature Origin of the hazard
Control Aggravating
of the Hazard Means/
Material Milieu Manpower Method measures factors
hazard Equipment
animal feed instructions (i.e. for cleaning - Training of (in function of
- if production: cleaning) or storage staff the target
presence of - non- - compliance animal)
processing aids compliance with the
- in case of with the contractual
production: contractual requirements
presence in the requirements (receipt/
reagents or dispatch)
incomplete
requirements
- absence of
traceability
Pesticide residues - product Not applicable - poor use of the - non- - application - maintenance
(including rodenticide) remainder equipment compliance system of un- and cleaning
- contaminated - Non-compliance with the calibrated or of
product with the contractual defective installations
instructions requirements pesticides - personnel
(withholding or training
period, dosage, incomplete - compliance
etc) requirements with the
- absence of contractual
traceability requirements
Residues of detergents/ - Detergent or Not applicable - Insufficient - Non- - Facilities - purchase
disinfectant disinfectant not cleaning and compliance and/or specifications
authorized for rinsing with the unsuitable (detergent/
contact with - Non-compliance cleaning vehicles (slope, disinfectant
animal feed with the procedures accumulation, allowed for
instructions etc.) contact with
(instructions for animal feed)
use, dosage, - maintenance
etc.) and cleaning
of the
installations
- personnel
training
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Nature Origin of the hazard
Control Aggravating
of the Hazard Means/
Material Milieu Manpower Method measures factors
hazard Equipment
Oil and lubricants - « non Feed Not applicable - poor handling Not applicable - poor design of - purchase - lack of
Grade » oil or lubrication specifications maintenance
lubricant points - maintenance
- accidental and cleaning
presence in oils of the
and/or fats installations
intended for - use of « Feed
animal feed grade » oils
or lubricants
(if existing)
hydrocarbons from - presence in Not applicable - poor handling Not applicable - loss of fuel - maintenance
equipment for loading animal feed and cleaning
and unloading of equipment
for loading
and
unloading
Liquids from - « non Feed Not applicable - poor handling Not applicable - loss of liquids - use of “ Feed - lack of
installations Grade » liquid for heating or Grade “ maintenance
cooling liquids
- maintenance
and cleaning
of the
installations
Water (liquid or steam) - insufficient - Installations - poor handling Not applicable - inadequate - maintenance
quality of the or vehicles installations and cleaning
used water for not protected and/or vehicles of the
the intended against bad (type of tubes, installations
purpose weather etc.) - Control of the
conditions used water
- (surround- (quality
dings – adjusted to
submerged the intended
area) purpose)
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Nature Origin of the hazard
Control Aggravating
of the Hazard Means/
Material Milieu Manpower Method measures factors
hazard Equipment
Physical Foreign objects - presence in the - inadequate - poor use of the - lack of - inappropriate - maintenance
product installations installation control installations and cleaning
- insufficient - non- and/or vehicles of the
cleaning compliance installations
- contamination with the - compliance
through staff contractual with the
(personal requirements contractual
belongings, or requirements
etc.) incomplete (receipt/
requirements dispatch)
- absence of - specific aids
traceability (i.e.
magnets)
- personnel
training
Mixing of two (or more) - possibility of Not applicable - poor use of the - non- - inappropriate - training of
products contact installations compliance installations staff
between and/or vehicles with the and/or vehicles - compliance
products with contractual with the
different requirements contractual
characteristics or requirements
incomplete
requirements
- absence of
traceability
- non-
compliance
with the
sequence of
production,
storage,
transshipme
nt or
transport
Table 2 : Example of the application of the 5M method Nature of the hazard
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2.9. Evaluation of each hazard
When evaluating an animal feed or a process step, one must, for each previously identified hazard ask
the following question:
- For the examined step or animal feed, what is the risk that an identified hazard occurs to such
extent that it threatens the food safety of the consumer and/or animal health?
When it comes to animal feed leaving the company, one might also ask whether a specific standard or
action threshold is likely to be exceeded. It all comes down to evaluation and control.
There are several methods available for the evaluation, a ranking of all hazards, minimally based on:
The gravity corresponding to the impact of the hazard on food safety for consumers and the
health of the animals;
The frequency of the hazard.
It is also possible to consider a third evaluation parameter, namely the detect ability of the hazard.
The probability of detection (or non-detection) of the hazard is hereby taken into account. This
parameter is very important since it allows the motivation of some estimations and adopted measures.
The estimation of the severity is generally based on a literature study (see items “references”) the
existence of a possible standard and on the assembled expertise of the company, while the frequency
is determined by data from the company itself (monitoring) and/or based on the collected data within
the sector.
Seriousness
Average
Frequency Low (1) High (3)
(2)
occurred”, or “there are
“the hazard has already
repeatedly”
occurred”
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Its use is very simple. The HACCP-team determines the frequency and the severity of the examined
hazard. The hazard is evaluated by multiplying the two factors, i.e. the probability that the examined
hazard will actually have a negative impact on the examined process step or product.
This concerns only one of the existing methods. The various references listed in this Annex allow the
HACCP-team to choose a method.
After evaluation, and depending on the obtained score, it will be determined whether this concerns a
Point of Attention (PA) or a Critical Control Point (CCP).
If using table 3 as a basis, a score 3 or 4 represents a PA and a score 6 or 9 represents a CCP or, in
opposite case, it does not concern a non-pertinent hazard .
Hazard
Freq.
Risk
Cat.
Motivation
description
The team will motivate and retain its decision. In this way, upon re-verifying the HACCP-plan,
they will be able to retrieve previously performed analysis and make adjustments if necessary.
By taking measures during a later step (i.e. a properly maintained metal detector at the load
line) the company will be able to eliminate risks formed by ferrous metal particles and will be
able to guaranty a safe final product (decreased frequency).
Example no. 2: Evaluation of hazards in a product upon purchase and reception
The HACCP-team identifies the hazard « presence of heavy metals (in particular cadmium) » in
zinc sulphate. This natural presence is a hazard of a chemical nature. One must of course
evaluate the case where the norm is exceeded.
This hazard was identified following an investigation of the type HACCP-plans (i.e. in this case
“mineral excavation”) but also based on the alert signal, etc.
The HACCP-team judges it should dissociate the purchases with and the purchases without
certificate.
Risico
Gevaren-
Ernst
Freq
Cat
Motivering
omschrijving
Presence of heavy
metals (in zinc Frequency: already occurred (RASFF-
2
6
sulphate) (purchase notifications in 2006)
C 2 3 -
without certificate, or Seriousness: significant consequence for human
CCP
with a certificate which or animal health
is not identifiable by
21 AT04_v1.2
lot)
Presence of heavy
metals (in zinc 3 Frequency: theoretical
sulphate) (purchase 1 3 - Seriousness: significant consequence for human
with certificate PA or animal health
identifiable by lot)
The team will motivate and document its decision. This way, when re-verifying its evaluation,
the earlier analysis will easily be retrieved and adjusted if necessary.
The following tables 4A; 4B, and 4C provide an overview of examples of potential CCP’s and PA’s
(with the exception of GMO’s) for some feed materials, used in the different sectors. It concerns non
exhaustive tables which should solely be considered as a tool. The determination of CCP’s and PA’s
depends on the company specific risk analysis. This analysis should be performed for all used,
produced or commercialized feed materials.
Certain professional associations have proceeded with a hazard evaluation at sector based level.
These assessments are of a more general nature, than those performed by a company at individual
level.
Example:
A company, receiving certain guarantees from a privileged supplier, may consider a specific hazard as
irrelevant, whereas purchase of that same product may, at sector based level, be considered as a
CCP.
Moreover, each sector is likely to assess a same danger for a same animal feed in a different way.
This is easily explained by the fact that each sector assesses the presence of a hazard in function of
its own activities.
Example:
Belgian cereal collectors will not consider aflatoxin B1 in corn in their hazard analysis, as they don’t
commercialize this type of product. But the compound feed sector will take this parameter into
consideration if the origin of the corn is unknown, or if it relates to corn originating from regions
where this mycotoxin has regularly been detected.
For illustration purposes, the following tables 4A, 4B and 4C have included a few examples.
Specifically intended for certain sectors.
The hazard analysis may be performed per product at individual level, or per group of products. In the
context of the identification of the hazards, it is necessary to define this group clearly, by using clear
and relevant distinguishing criteria. Do not lose sight of this aspect of the HACCP-study, when you
elaborate the potential groups.
Example 1:
You could define a group « cereals » regrouping all forage cereals which you use.
You could also split them according to species: cereals , winter barley, triticale, etc.
You could also use the origin in order to determine the group (origin does not necessarily relate to
one or more countries). It could also relate to a zone where e.g. cultivation conditions are the same).
22 AT04_v1.2
The criterion “supplier” may also be relevant: e.g. cereals originating from a trading establishment,
and cereals (primary products) supplied directly by the manufacturer. Indeed in the first case, there
may have been additional controls and/or operations.
When considering the hazard « mycotoxines » for cereal supplies, by a primary producer (farmer), a
difference should be made between deliveries during harvest, and those outside this period. Indeed,
storage at the farm may have been the source of development of ‘storage’ mycotoxins, other than
‘field’ mycotoxins, which are present during harvest.
Measures to be taken may therefore be different depending on the hazard analysis.
Example 2:
Knowledge of the process is also a parameter that may influence the formation of a Group.
Fats of animal origin e.g. may be divided in groups according to the process from which they originate
(e.g. there is a difference between fat originating from the manufacturing of gelatin with possible use
of hydrochloric acid therefore dioxin formation cannot be excluded, and fats derived from other
processes in which no hydrochloric acid has not been used).
If the production process of the fat is unknown (origin unknown), the product cannot be classified
with certainty, therefore the hazard assessment providing the highest security the most must be
chosen.
23 AT04_v1.2
Feed material CCP PA
Dioxins and dioxin-like PCBs
Fish oil -
PCB
Table4B: examples of CCP and PA upon production of animal fats and oils
24 AT04_v1.2
Feed material CCP PA
Aflatoxin B1
Corn products (European Continent) Other mycotoxins (ZEA, FUM B1 and
B2)
Other mycotoxins (ZEA, FUM B1 en
Corn products (North American Continent) Aflatoxin B1
B2)
Corn products (origins other than from the Other mycotoxins (ZEA, FUM B1 en
Aflatoxin B1
European or North American Continent) B2)
Corn feed meal (North American Other mycotoxins (ZEA, FUM B1 and
Aflatoxin B1
Continent)) B2)
Corn feed meal (origins other than from the Other mycotoxins (ZEA, FUM B1 and
Aflatoxin B1
European or North American Continent) B2)
Milk powder Melamine (origin China)
Milocorn, milo, sorghum, Aflatoxin B1
Palm kernel, extracted
Aflatoxin B1
Palm kernel, expeller
Peeling (oats, barley) Other mycotoxins (DON, OTA, ZEA)
Vegetable fats and oils Dioxins and dioxin-like PCBs
Fatty acids of vegetable origin Dioxins and dioxin-like PCBs
Aflatoxin B1
Bran Other mycotoxins (DON, OTA, ZEA)
Pesticides
Other mycotoxins (rye ergot)
Rye
Pesticides
Soya beans Salmonella
Soya bean hulls Pesticides
Soya beans, extracted Salmonella
Other mycotoxins (DON, OTA, ZEA)
Wheat- spelt
Pesticides
Other mycotoxins (DON, OTA, ZEA)
Wheat by-products
Pesticides
Other mycotoxins (DON, OTA, ZEA)
Wheat gluten
Pesticides
Other mycotoxins (DON, OTA, ZEA)
Triticale
Pesticides
Vinasses, yeast (agro-fuels) Antibiotics
Salmonella Heavy metals (As, Cd, Pb, Hg)
Fish meal Dioxins and dioxin-like PCBs Biogenic amines
PCB Animal meal
Dioxins and dioxin-like
PCBs
Fish oil
PCB
Table 4C: examples of CCP and PA upon purchase of feed materials by the sector of compound feed
manufacturers
Anti nutritional factors may also be evaluated. These are naturally occurring components of certain
feed materials, which, if they exceed a certain value, their use might be compromised. It is up to the
company to define an acceptable limit, e.g. in function of the target animal for whom the finished
product is intended, or in function of an existing standard.
25 AT04_v1.2
It should be noted that a Legal standard (e.g. gossypol content in feed) should always be respected in
both, purchase and sale. Dilution must never be considered as a control measure for an undesirable
substance for which there exists a legally defined maximum (see ‘AT-01: Legislation’ Directive
2002/32/EC).
Table 6 provides an overview of examples as regards CCP en PA (with exception of GMOs) for a
number of additives.
Pesticides
Sensory additives (a and b)
Dioxins and dioxin-like PCBs
Table 7 provides an overview of examples as regards CCP and PA (with exception of MGOs) which
might occur during the production of compound feed.
These examples should be refined by the company and/or the sector in function of:
- The type of compound feed (e.g. complete compound, complementary feed);
- The target animal (food producing animals, fur animals, pet animals);
- The situation of the target animal and consequently its needs and sensitivities (maintenance,
periods of growth, pregnancy or nursing);
- The formulation/composition of the feed (presence of certain ingredients whether or not in
large quantities);
- The implemented processes (all-mash, grinding, molder, extrusion, etc.).
These examples stem from a very general approach. A completely different evaluation may be
performed, based on the practice, with significant variations from one company to the next.
26 AT04_v1.2
Compound feed CCP PA
Aflatoxin B1
Compound feed for ruminants Other mycotoxins (DON, OTA,
ZEA, FUM B1 and B2, HT2 en T2)
Other mycotoxins (DON, OTA,
Compound feed for pig
ZEA, FUM B1 and B2, HT2 en T2)
Other mycotoxins (DON, OTA,
Compound feed for poultry ZEA, FUM B1 and B2, HT2 en T2)
Salmonella
Compound feed for cats and dogs Salmonella
Heavy metals (As, Cd, Pb, Hg) and
Mineral premixtures
fluorine
Following this assessment, and depending on the identified hazards, several action opportunities are
available.
According to the example given in Table 4, the reactions are being based on the obtained score.
In this case the following actions are applicable:
The company’s HACCP-team will draw up an overview table of the hazard analysis for the process as
well as those for each animal feed. The team can make use of table 5 for example, or of another
equivalent document.
Now that the CCP’s and the PA’s for each step or animal feed are known, you must, determine for
each of these CCP’s and PA’s the following:
- The critical limits that cannot be exceeded for this step or for this animal feed;
27 AT04_v1.2
- The (potential) action thresholds.
It is not always easy to determine these critical limits or action thresholds. Nevertheless you will need
to determine the critical limit or action threshold yourself each time the step requires it.
Some of these limits or thresholds are determined by law (i.e. levels of undesirable substances).
Consultation of document ‘AT-03: Table of norms, action thresholds and notification limits’ in this
sense can help. Other critical limits can be determined contractually in the relation
“supplier/customer” (buyer/seller).
Finally, in many other cases you will need to determine the limits and action thresholds in function of
your own working methods or according to the client’s wishes.
- The exceeding of a temperature of which you think should not have been exceeded (i.e.
preservation of a feed material such as liquid dairy by-products);
- The exceeding of a moisture level (i.e. moisture content for a stock of cereals);
- A pH which is not reached, whilst such an acidity would guarantee the microbiological quality
of the product;
- The presence (or absence) of a parameter (i.e. the presence of such a parameter upon
receipt equals a refusal or an adoption of additional measures).
Let’s recapitulate:
- Now you know the points of « risk » (concerning food safety) of your company and of the
animal feed you buy and place on the market.
- You know the limit under which you must keep certain points of your process and certain
levels in your animal feed.
Conclusion: as a result you need to set up a control of the PA’s and the CCP’s.
When you are in possession of animal feed (legal owner) and want to place it on the market, you
must control it. This specific control is the object of document ‘AT-05: Monitoring’.
For this control the company determines the parameters for control as well as the frequency of
control. Depending on the type of installation a continuous control (such as for temperature, flow rate
or pH for instance) or a periodical control is conceivable.
The detectors of certain installations are equipped with alarm systems that are triggered when
exceeding the limits or thresholds. Such systems are not mandatory, but may obviously contribute to
the control of the hazards.
Examples
- After a manual addition you have installed a system (restarting of the installation,
confirmation) that gives you the assurance that the addition actually took place;
28 AT04_v1.2
- At regular intervals (to be determined by yourself based according to your use) you control
the quantities of manually added products that remain in stock;
- You systematically (or randomly, according to a frequency determined by yourself) apply a
control (which varies according to the animal feed in question) upon receipt;
- You control (according to a frequency determined by yourself, i.e. once a day) the
temperature upon exit of a cooler (or dryer);
- You control once a day the pH of your finished products;
- During storage of cereals you control their temperature regularly (i.e. once/week).
The HACCP-team will help to determine the most appropriate corrective action to be taken. Often the
company has already introduced various measures. However it is possible that some of them will need
to be adjusted.
Examples
- You notice that on the product sheet a manual addition was not entered. You block this
production. You conduct an internal investigation. Several actions can be taken:
o The addition took place but was not registered. The product can continue the
process;
o The addition did not take place. In function of the actual composition the product can
still continue the process, be reoriented or be destroyed.
- You have come to realize that the quantities of processing aids (or additives or another
product) that are actually in stock are not consistent with the quantities expected. You
conduct an internal investigation. Several actions can be taken:
o It concerns a registration problem. With correction the quantities match;
o Quantities don’t match. A quantity larger (smaller) than expected was used. You must
perform additional controls on the concerned animal feed to check whether they
should not be considered as non-compliant products.
- During a control on receipt you are not able to establish a link (traceability) between a batch
and an accompanying certificate of analysis. The presence of a valid certificate of analysis is a
parameter that you have imposed upon receipt of the animal feed. Several actions can be
taken:
o You refuse this batch of animal feed;
o You block the batch and perform the necessary analyses yourself in order to obtain
the guarantees which you have requested by means of the certificate.
Your supplier’s evaluation must take this incident also into consideration.
- You check the temperature daily upon leaving the dryer. With a temperature higher than the
one recommended by the manufacturer you run the risk that the product will be damaged
(due to heat), or initiate the phenomena of condensation which is higher in comparison to
what you would have expected at consequent steps. In extreme cases undesirables
substances can be formed. Most installations are equipped with automatic probes that stop
the drying as soon as the temperature is too high (fire protection). Your control reveals a
temperature higher than the one you had recommended. In order to fix this you must reduce
29 AT04_v1.2
the time of duration in the dryer. You evaluate the production that may have been subject to
this temperature increase (subsequent condensation, product characteristics, presence of
undesirable substances, etc.).
- Twice a day you control the pH of your finished products. During a control you notice that the
pH is higher than the maximum value (critical limit) which you had established. You block the
product. Several actions can be taken:
o You correct the pH (i.e. addition of acid) and the product can continue the process;
o You consider the product as non-conform and treat you treat it as such.
- You notice an increase in temperature in a batch of cereals. You ventilate the product in order
to lower the temperature and evaluate the impact this heating had on the animal feed.
The work of the HACCP-team could result in changes to some of the working methods. It is important
to have all of this written down on paper or in digital format so that the transmission of information in
the company is optimal.
A procedure also mentions the way in which the HACCP team has worked and how the HACCP plan
has been achieved. This procedure must contain all the steps.
The procedures and working instructions must mention the following (or make reference to a
document (i.e. table) mentioning this):
- The critical limits and/or action thresholds;
- The actions to be taken in the event of exceeding these limits and thresholds.
We have now almost reached the end of the HACCP-plan, we will have it reviewed in its entirety to
make sure everything works and links with other parts of the autocontrol system are correctly made.
The consistency between the application “on paper” and the application “on the field” should be
checked as well.
The HACCP-team will review all the work done. They will confirm the control by indicating it on the
documents (i.e. with indication “Review on … (date)”).
Your HACCP-plan should be reviewed on a regular basis, and at least once per year. It must be
reviewed every time you make changes to your process. After all, any changes in conditions could
affect the previous conclusions of the risk analysis.
It is important to plan the review. It should reflect the review date specified in the HACCP-study (see
previous point) or should intervene during any change of the process.
During this review the HACCP-team will also take into account the complaints and non-conformities
registered. Based on this they will especially verify the risk analysis, revalidate the critical limits and
evaluate the application on the field.
In order to facilitate the work, this review of the HACCP-plan can be part of the internal audit or take
place just before that. In case of an amendment, the review must occur before and during changes in
the installation.
30 AT04_v1.2
The conclusions of this review are being evaluated during evaluation of the system by the
management.
If you want to invest in a new line, it is recommended to take the HACCP-principles into account right
from the start.
You obviously dispose of an HACCP-study for the new line. The HACCP-plan of the company should be
reviewed at that time.
31 AT04_v1.2
1 2 3 4 5 6 7 8 9
Considered
Hazard PA or Motivation &
product or Control measures Related documents
description CCP reference to literature
step
Risk
Cat
β
α
γ
Legend:
Column 1: Name of the animal feed or the process step that is being evaluated
Column 2: Accurate description of the hazard discovered for this product or this step, taking into account the specificities of the company
Column 3: One of the hazard categories in which the hazard is classified (physical, chemical or (micro)biological)
Columns 4: Factors used for the risk evaluation (such as: frequency of the hazard appearance, seriousness 2 or , possibly, detectability 3)
Column 5: Numerical score, resulting from the risk evaluation 4
Column 6: Classification based on the evaluation, in PA or in CCP
Column 7: Motivation based on which the HACCP-team has performed the evaluation. If applicable, the source of information which was consulted is mentioned here
Column 8: Measures that are existing, strengthened or implemented following the evaluation, in order to control the hazard (in order to eliminate it or to reduce it to an
acceptable level)
Column 9: Reference to the documentary system of the company (a document that is existing, modified or implemented following the evaluation, allowing control of the hazard)
Table 5 : Example of an overview table for the risk analysis of a process or animal feed
2
The seriousness corresponds to the consequences of the hazard for the human and animal food safety.
3
« detectability » should be interpreted as the probability of (non-)detection of the risk. The HACCP-team can evaluate the risk (its criticality) differently depending on whether it concerns a visible
hazard, which is the object of systematic controls, or on the contrary it is an invisible hazard that is the object of punctual controls (i.e. chemical contamination).
4
In the literature the risk indicator R can also be defined as the « criticality ». This criticality is the product of the scores assigned to the frequency, the seriousness and, possibly, the detectability
(in case this factor was deemed relevant by the HACCP-team and is used for the risk evaluation).
32 AT04_v1.2
3. References and short bibliography
This document and the subsections (HACCP-plans) were elaborated by the OVOCOM-secretariat,
presented to the involved sectors and evaluated in a working group.
The information in the references below can lay the foundations of the risk analysis that the HACCP-
team has to perform for the company. They will of course not remove the responsibility from the
company to take into account her own specificity.
Scientific Committee of the FASFC Terminology of hazard and risk assessment according to the Codex
Alimentarius [online]. FASFC. Brussels
- FASFC (Federal Agency for the Safety of the Food Chain) – Scientific Committee: Advice[online].
Available at http://www.favv-afsca.fgov.be/scientific committe/advice/
- BEMEFA (Profession Association for compound feed producers) – Hazard analysis raw materials
[online]. Available at http://www.bemefa.be/RiskAnalysisIngredients.aspx (password and login
required)
- FEDIOL – Library: Risk Analysis [online]. Available at http://www.fediol.org/5/index9.php
- GMP+INTERNATIONAL - Feed Safety Database [online]. Available
athttp://fsd.gmpplus.org/fsd/page/1/home.aspx (password and login required)
- Product Board for Margarins, Fats and Oils – MVO/EFPRA risk analyses (animal fats) [online].
Available at:
http://www.mvo.nl/Kernactiviteiten/KwaliteitenVoedselveiligheid/RiskAnalyses/MVOEFPRA/tabid/
502/language/nl-NL/Default.aspx
3.2. Works
- AFFSA - Principaux risques sanitaires identifiés. In: Rapport du groupe de travail « alimentation
animale et sécurité sanitaire des aliments » [online]. AFFSA. Parijs. (2000) pp 112-154. Available
at http://lesrapports.ladocumentationfrancaise.fr/BRP/004001815/0000.pdf
- Arvalis & FFCAT – Séchage des grains en organisme stockeur – Guide pratique. FFCAT
(actuellement Coop de France – Métiers du grain). Paris. (2003) 137 p.
- Scientific Committe of the FASFC –Terminology of hazard and risk assessment according to
the Codex alimentarius [online]. FASCS. Brussels. (2005) 46 p. Available at http://www.favv-
afsca.be/wetenschappelijkcomite/publicaties/terminologie.asp
- Centre de recherche sur les céréales - Protection des céréales, des oléagineux et des
légumineuses à grain entreposés à la ferme contre les insectes, les acariens et les moisissures
[online]. Centre de recherche sur les céréales. Winnipeg (Manitoba) Canada. (2001) 58 p.
Beschikbaar onder (ook in Engels) http://grainscanada.gc.ca/storage-entrepose/aafc-aac/pfsg-
pgef-fra.htm
- Coop de France – Nutrition animale & SNIA - Guide de bonnes pratiques de la fabrication
d’aliments composés pour animaux. Coop de France & SNIA. Parijs. (2008) 68 p.
- FAMI-QS – Annex 11: Guidance on risk assessment in production. In: Community Guide to
Good Practice For Feed Additive and Premixture Operators [online]. Fami-QS. Brussel. (2007) pp
72-111. Available at
http://ec.europa.eu/food/food/animalnutrition/feedhygiene/guide_goodpractice_en.htm
- FEDIAF – Guide to Good Practice for the Manufacture of Safe Pet Foods [online]. FEDIAF
(Fédération Européenne de l'Industrie des Aliments pour Animaux Familiers). Brusselq. (2010) 66
p. Available at
http://ec.europa.eu/food/food/animalnutrition/feedhygiene/guide_goodpractice_en.htm
33 AT04_v1.2
- FEFAC – Community guide to good practice for the EU industrial compound feed and
premixtures manufacturing sector for food-producing animals - European Feed Manufacturers
Guide [online]. FEFAC (Fédération Européenne des Fabricants d'Aliments Composés). Brussel.
(2007) 59 p. Beschikbaar onder
http://ec.europa.eu/food/food/animalnutrition/feedhygiene/guide_good practice_en.htm
- FFCAT – Guide Collecte/Stockage – Hygiène et sécurité sanitaire – Référentiel technique. FFCAT
(tegenwoordig Coop de France – Métiers du grain). Paris. (2003) 102 p.
- Institut Technique des Céréales et des Fourrages (ITCF) & FFCAT – Le Guide du chef de
silo – Les bonnes pratiques du stockage des grains. FFCAT (tegenwoordig Coop de France –
Métiers du grain). Parijs. (1995) 71 p.
- Unité de Technologie des IAA (FSAGx) –Stockage des céréales à la ferme ou en organismes
de collecte / mise en place d’un système de gestion de la qualité. FSAGx. Gembloux. 122 p.
- SAV - HACCP – Transport, storage and food distribution. SAV (currently Transport & Logistiek
Vlaanderen). Gent. 69 p.
3.3. Standards
4. Annexes
Document AT-04 has been supplemented with 11 sub-sections. They approach one by one the
processes already existing within a number of animal feed sectors.
34 AT04_v1.2
No. Title Process
Storage, mechanical separation, production of
AT-04-06 Production of vegetable oil crude oil, refining, storage (of end products),
mixing, transshipping, loading
Collection/reception, mechanical reduction,
thermal process, chemical extraction, mechanical
AT-04-07 Production of fats of animal origin
separation/filtration, storage of end products,
transshipment, loading
Exploration of mining areas, mining, enrichment,
AT-04-08 Mining of minerals handling, mixings, storage of finished products,
transshipment, loading
Purification of feed materials, synthesize,
purification of desirable substance, drying,
AT-04-09 Production of additives
mixing, dilution, finishing, storage of finished
products, transshipment and loading
Transshipment, formulation, dosing, mixing,
AT-04-10 Production of premixtures storage of finished products, transshipment and
loading
Transshipment, formulation, dosing, mixing,
pellettizing, cooling, molder, sieving, coating,
AT-04-11 Production of compound feed
storage of finished products, transshipment and
loading
35 AT04_v1.2