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Clause 2.6
From: Ingredients18
10:03AM 9 April 2019
Any examples of "any other hazards mandated by the customer or relevant regulatory authority"? How can these generate a food safet hazzard?
From: Ben
10:00AM 12 April 2019
In response to a minor NC at our very first A&B audit at the start of Issue 1, we ended up including "documentation" as a new class of hazard - the auditor's view was that absence of critical paperwork for import was potentially a hazard in that it could have an implication on the legal status of imported ingredients.
Unfortunately the Interpretation Guide doesn't give a great deal of useful extra information in this area!

From: Ingredients18
10:27AM 12 April 2019
Thanks for the comment. Interesting- how does 'legal status' make the ingredient unsafe? It may change it's commercial value or its legality to use but does that make it unsafe? Anybody else got any views? I also noted the lack of guidance in the Interpretation Guide and our auditor did not offer any examples.
From: Ben
1:30PM 18 April 2019
Our experience has been that the auditors' interpretation of the nature of "hazards" in this section of the standard is significantly broader than those strictly concerned with food safety. This seems to have been relatively consistent across the four audits we've had since Issue 1 launched, and the result has been a "HACCP" plan that is far broader than true food safety in the style of actual Codex HACCP.  In addition to the usual chemical/physical/micro hazard categories, we now also have microbiological quality (i.e. spoilage rather than pathogenic),  physical quality (primarily packaging / transport damage), and Documentation (the import docs, phytosanitary certs, Organic CoIs etc as mentioned in my original comment).
It's without doubt a peculiar corruption (sorry, I think I meant "evolution") of HACCP, but the standard is of course broader than food - it's intended to also cover packaging materials and consumer goods too.