18 replies to this topic

[ektezcan]

Dear friends,

I'm a new member from Turkey. My friend advised me this forum and I'm glad to be part of the group.
I'm a food engineer and working in a flour mill and want to make some revision about CCP's because we have 11 CCP. In my opinion it is too much and some of them must be part of prerequisite programs but it is hard to persuade some of HACCP team member.Marked in red CCP in our HACCP Plan are which I want to cancel. Can you please check HACCP plan and share with me your opinion and experiences.

Thaks and best regards,

Elif

[Abdul Qudoos]

Dear friends,

I'm a new member from Turkey. My friend advised me this forum and I'm glad to be part of the group.
I'm a food engineer and working in a flour mill and want to make some revision about CCP's because we have 11 CCP. In my opinion it is too much and some of them must be part of prerequisite programs but it is hard to persuade some of HACCP team member.Marked in red CCP in our HACCP Plan are which I want to cancel. Can you please check HACCP plan and share with me your opinion and experiences.

Thaks and best regards,

Elif

Greetings to the Forum,


Is your flour mill is HACCP certified or ISO 22000:2005 certified?, please let us know. So that i can highlight my opinions.

I m unable to open the attachment... can you re-attach once again, (some error happened)

Thanks for replying,

[Simon]

The reason the attachment is missing is because we restored the site from 03 September and the post was made after this time.

[adobrosielska]

I try to help you, even though i didn't saw your HACCP plan. I work in polish mill and we have only two CCP. First one is in the beginning, it's a point where we take the grain and make the all the analysis which help us to decide if the grain is ok. The second one is at the end It's the last sieve and last magnet. We make sure that there is no particle of metal and other dirt. It's enough according to us and I can say that we have ISO 9001 and 22000 certified for few years.
I don't have our HACCP plan in english so if there any other question about its details, I'll try to answer.
Best regards

[Tony-C]

Dear friends,

I'm a new member from Turkey. My friend advised me this forum and I'm glad to be part of the group.
I'm a food engineer and working in a flour mill and want to make some revision about CCP's because we have 11 CCP. In my opinion it is too much and some of them must be part of prerequisite programs but it is hard to persuade some of HACCP team member.Marked in red CCP in our HACCP Plan are which I want to cancel. Can you please check HACCP plan and share with me your opinion and experiences.

Thaks and best regards,

Elif

Hi Elif

I've had a quick look at your HACCP plan and believe that things like cleaning, storage and loading should come under prerequisite or operational prerequisite programmes.

The other thing I noticed is that you have pesticides as a CCP in your raw material acceptance but you only test this once a year so it cannot be a CCP.
It can be a CCP if your controls are to purchase from approved suppliers to agreed specifications and your verification is your pesticide analysis.

Regards,

Tony

[adobrosielska]

Dear Tony-C
As I wrote before I work in mill. And we have in our CCP pesticide, micotoxins and heavy metals. Our auditors think it's ok because we define the frequency as twice a year. I must admit I tried to treat those parameters as PRP but I wasn't able to defend my decision in little fight with auditors My opinion was that we aren't able to check all the grain deliveries. They said they accept it as CCP when it's written we check the mycotoxins level twice a year in grain which we store. Every country has its own habits
Elif maybe you could upload your HACCP plan once more? It would be really helpful in this discussion.
Best regards

[Tony-C]

Dear Tony-C
As I wrote before I work in mill. And we have in our CCP pesticide, micotoxins and heavy metals. Our auditors think it's ok because we define the frequency as twice a year. I must admit I tried to treat those parameters as PRP but I wasn't able to defend my decision in little fight with auditors My opinion was that we aren't able to check all the grain deliveries. They said they accept it as CCP when it's written we check the mycotoxins level twice a year in grain which we store. Every country has its own habits
Elif maybe you could upload your HACCP plan once more? It would be really helpful in this discussion.
Best regards

Hi There

Thanks for your reply

Critical Control Point (CCP) is a point, step or procedure at which controls can be applied and a food safety hazard can be prevented, eliminated or reduced to acceptable (critical) levels.

I don't see this as applying controls. What is your corrective action if it is outside of acceptable limits? Withdraw 6 months product?

As I said before it could possibly be interpreted as a CCP if the controls are supplier assurance related.

Regards,

Tony

[ektezcan]

Dear my friends;

Sorry my late reply, I couldn't access forum page before ( Thanks everybody for their valuable reply. The company which I'm working for , has two different wheat flour mill plant.One of them, the older one , has both ISO 9001 and HACCP system. The other was opened few month ago and hasn't got any Quality System certificaiton.I appointed to implementation of ISO 22000 to this new mill. Because of this I'm very stressed and confused .Next days may be I need more help about this topic.
With regard to my first mail, I tried to upload plan again but I'm not successful ( File's space is more than limit .Because of this I divided plan two part and attached it saparetly.

Thanks and grateful to Tony, Adobrosielska,Simon, Abdul Qudoos about for their sharings and looking forward more
Best Regards...

Elif

Attached Files

•  CCP2.doc   42.5KB   572 downloads
•  CCP_1.doc   42KB   525 downloads

[Tony-C]

Hi Elif

There are a few more problems with your HACCP plan to add to the ones I posted earlier.

From your plan:

CCP no, Parameter followed and type of risk under control
PHYSICAL CONTAMINATION ON FLOUR PACKAGING - CCP 7-F
Parameter:
1. Contamınation to product due to spilling of metal pieces 2. Dead areas of device getting lumpy and contamination of this material to the product 3. Flour and dust contamination to the environment due to getting dusty 4. Paint spilling form scale and contamination to the product

Critical Limits and Tolerances (sub-, upper limits)
Must not be present.

(Method, Analysis Name and Follow-up Frequency, Measurement Place and Responsible)
* Cleaning and maintenance of packaging equipments are performed according to Annual Maintenance Plan and Hygiene Directions.
* At frequency in annual maintenance plan
* By production unit .
Packaging materials are kept in packages in a clean area.

Corrective Actions and Responsible Person in Production Line and Product of limit value is exceeded:
For activity in CCP: Verification regulation, frequency and responsible
Regulation for Follow-Up:
Process is stopped.
Maintenance or Cleaning are performed.

Effectiveness of system is verified through internal audits by Quality Assurance and Hygiene Assistant Manager every 6 months.

Regulation / Document Name
PM/ 8.2 ve PM/7.5

HACCP Kayıtları
Cleaning and Maintenance Plans, Cleaning, Maintenance Forms

You have a control measure but no monitoring procedure.

Regards,

Tony

[SSJB]

If your CCP monitoring is so infrequent (twice yearly in soe of them as you say above!) then surely these cannot be CCP's? By the time any monitoring was to alert you to a problem, it would be too late. The monitoring frequency needs to be aligned with your product release timings so that you are not looking at a mass recall!

We have a flour mill as part of our group, and we have 2 CCP's. Screening and metal detection.

There are extensive prerequisites in place for grain intake, pest control, cleaning, pesticides, mycotoxins....the list goes on...

Our auditors are always arguing that sites have too many CCP's listed and across out group we have just reduced ours from around 11 per site, to just 2 or 3 per site, with the others being dealt with as prereq's, QCP's or ECP's.

[Charles.C]

Dear Adobrosielska,

Every country has its own habits

Maybe it would be preferable to say -

Every auditor has its own (bad) habits (unless there is a consensus of course)

@ elif - as per Tony-C,

I don't see this as applying controls. What is your corrective action if it is outside of acceptable limits? Withdraw 6 months product?

I am equally interested to hear the auditor's response to that one. "Force Majeur" perhaps

Rgds / Charles.C

[Abdul Qudoos]

Dear my friends;

Sorry my late reply, I couldn't access forum page before ( Thanks everybody for their valuable reply. The company which I'm working for , has two different wheat flour mill plant.One of them, the older one , has both ISO 9001 and HACCP system. The other was opened few month ago and hasn't got any Quality System certificaiton.I appointed to implementation of ISO 22000 to this new mill. Because of this I'm very stressed and confused .Next days may be I need more help about this topic.
With regard to my first mail, I tried to upload plan again but I'm not successful ( File's space is more than limit .Because of this I divided plan two part and attached it saparetly.

Thanks and grateful to Tony, Adobrosielska,Simon, Abdul Qudoos about for their sharings and looking forward more
Best Regards...

Elif

Greetings & thanks for resending the information,

Sorry for the delayed response...

Again its depends upon you how you handle the auditors - convince him/her

My highlights are:

• CCP 1-K & CCP 1-B you may combine to make 1 as this is Raw material acceptance and its related to Quality check, only lab analysis required. - CCP 1
• CCP 2-B is a Cleaning and Sanitation, maintenance of equipment this is purely PRP, inspection, monitoring and observation required - No CCP
• CCP 3-F is a Metal Detector required CCP - CCP 2
• CCP 4-F Sieve control (hazard - physical contamination) may required CCP - CCP 3
• CCP 7-F again a Cleaning and Sanitation program - PRP - Inspection, monitoring and observation required. - No CCP
• CCP 8-B Storing may considered as OPRP (if you are implementing ISO 22000)
• CCP 9-k Loading and Vehicle control - PRP - Inspection, monitoring and observation required.

Note: Validation is required for the above CCPs if you are implementing ISO 22000:2005.

[Tony-C]

CCP 1-K & CCP 1-B you may combine to make 1 as this is Raw material acceptance and its related to Quality check, only lab analysis required. - CCP 1

Really ? How are RAW MATERIAL ACCEPTANCE (WHEAT) CCP 1-K Parameter:Finding fuel, pesticide and manure pieces in raw material hazards controlled?

Regards,

Tony

[Abdul Qudoos]

Really ? How are [/b]RAW MATERIAL ACCEPTANCE (WHEAT) CCP 1-K Parameter:Finding fuel, pesticide and manure pieces in raw material hazards controlled?

Regards,

Tony

Upon receiving the quality person will check the quality of RM by physical and chemical analysis:
Finding fuel - ACOT
Pesticide - if they have GC-MS or HPLC
manure pieces - Seiving /mesh

Thanks Tony for highlightning

[Sujit]

Dear Elif & list,



I would like to share my experience with the forum. It is the same as SSJB from UK has written. We have the same CCP's.

Under screening we have destoner, separator and scourer as CCP's. Final CCP is metal detector.

Our first CCP is Moisture controller unit, where water is added to condition the wheat for 24 hours. Mould growth is possible due to excess water addition

The unit calculates the exact water volume needed to obtain the the required final product moisture.

Destoner is for separation of stones from wheat. Separator for separation of straw, gunny bag threads, foreign matter.

Scourer for the removal of loose impurities (dust, sand, hulls) sticking to wheat kernel

Magnet to remove ferrous material, metal objects like nails, wires, screws during cleaning and before grinding.



You can make the HACCP plan look simple by just mentioning the CCP, Hazard, then Action level, Critical limit, Monitoring ( what, how, when and who), Corrective action and Records.

Have a column for the above.



Hope you find the above helpful.



Kind regards,



Sujit Meledath

[MRios]

Dear Elif,
I also work at a flour mill. The whole milling process is based heavily on sieving, in order to have an adequate particle size, while also removing as much bran as possible. So, at least in regards to physical contaminants, you´re covered by the cleaning process: scourers, separator, pneumatic removal of light contaminants, magnets which are there mostly for the sake of not ruining the rest of the equipment, but likewise a great aid in regards to food safety. Then, flour has to pass 100% through a 180 micron mesh. I would start looking after the sieving part. Your mill probably has a turbosifter before packaging, maybe a magnet. These would probably be your PCCs.
Turbosifters have openings that are 2 mm in diameter, so they reject anything larger. According to the US FDA, physical contaminants must not be between 7 and 25 mm.

Microbiology would probably not be an issue, since humidity should be under 14.5% for flour. Although millers would like to have more humidity for a better yield, this also means that flour gets stickier and would cause certain pieces of equipment to clog up.

As for chemicals, like pesticides, I agree that you should control it by having certified providers, since it is very costly to test every grain lot. How often have you found fuel in your grain? Is this usual in your country? If that were the case, you do need to have a way of dealing with the contaminated grain, so you would have to test for this much more often.

Hope this helps.

[ektezcan]

Dear my friends;

After a long break I've just found a chance to check my question's replies. Thanks to every member who shares their experiences and opinions with me. Every reply is very important and valuable for me. All of them are usefull information for me. I'm very grateful to you.

I made a new risk analysis for our new mill within the context of ISO 22000 implimentation project.We determine control sieve, last magnet which is on the top of control sieve and storing as CCP.Raw material acceptance is defined as PRP because we make quality control analyses for very party raw material acceptance.

I want to ask a question about magnet and control sieve critical limit. Can anybody give me information about these point? For example for control sieve what should I say critical limit or for magnet how can I check it and what should critical limit be?

MrRios asked the frequency of fuel contamination to raw material. Nearly " never" I haven't seen this contamination for two years working period.
And last one more question ; if storing conditions are not adequate mould growth can be accured and it causes health hazard and after storing there is not any process to eliminate this hazard.In this situation storing couldn't be a CPP ????
Again, thanks to everybody about their sharings.

Kind regards,

Elif

[MRios]

Sieving as a CCP

There's the link to a thread about sieving as a CCP which has lots of information and valuable input from many IFSQN members.

As for storage conditions, these should be controlled as part of your GMPs, so would not be considered as a CCP.

[MRios]

Sieving as a CCP

There's the link to a thread about sieving as a CCP which has lots of information and valuable input from many IFSQN members.

As for storage conditions, these should be controlled as part of your GMPs, so would not be considered as a CCP.