What about labelling?
Surely this should be a CCP or OPRP?
Regards,
Tony
Dear Tony,
What would you consider a hazard in the labelling stage?
I haven´t thought of something in there.
FSSM
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Posted 19 February 2010 - 04:38 PM
Well,
Here it goes, some people in the forum (in other topics) said that spoiling would happen before pathogens start growing, I´m not sure about that. Also, I couldn´t find information about the correct process of time and temperature to cool fruits and vegetables, just statements that mantaining a certain temperature was important.
RTU_vegetables_selection_and_classification_of_CM.xls 28KB
465 downloads
Regards,
FSSM
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Posted 20 February 2010 - 12:46 AM
Dear Tony,
What would you consider a hazard in the labelling stage?
I haven´t thought of something in there.
FSSM
Edited by Tony-C, 20 February 2010 - 12:47 AM.
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Posted 20 February 2010 - 04:44 AM
Dear FSSM,
Yr efforts are to be applauded.
I have to say that IMO you selected an extremely complex (and controversial) product area for a risk analysis request. However, it is undoubtedly important based on the various vegetable / fruit (microbial) disasters of recent years as particularly documented in US..
To encourage contributions I thought it might help to add a little background material for preliminary assistance.
Here are 2 short reviews for fresh produce, the first for the general microbiological situation (ca 2003) and a second more focused on (traditional) HACCP (ca 2002).
preharvest__postharvest__fresh_produce_pathogens__control.xls 2.61MB
445 downloads
food_safety_for_fresh_produce.pdf 618.67KB
521 downloads
Currently the most accessible up-to-date (microbial) reference is probably the link below which is the third in a continuing series (1998, 2001, 2008).
http://www.fda.gov/f...s/ucm064458.htm
The middle one also contains a wealth of basic information, much of which is still highly relevant.
The temperature and MAP aspects seem to remain undecided with respect to food safety except for specific products like melon, for example see Section 8-3 in above link.
As a general comment, I extracted this chunk from the 2001 set -
( http://www.fda.gov/F...s/ucm091050.htm )3.1.3. GMPs and HACCP
GMPs are FDA regulations directed at food processors and are located in the U.S. Code of Federal Regulations 21(CFR) Part 110.1 -- 110.99. GMPs cover all aspects of a processing environment from the design of a sanitary facility to rules forbidding jewelry on workers. Unlike GAPs, GMPs are rules that are clearly defined and easy to apply because a processing environment has easily defined boundaries and the processing activities can be contained and controlled.
Even though HACCP is not mandatory, it has been embraced by the fresh-cut processing industry as a useful tool for implementing food safety practices in the production environment. HACCP is well suited to identify hazards, monitor production for adherence to operational standards, and develop an effective record keeping system in a fresh-cut produce facility. With close attention to prerequisite programs, a processor can implement HACCP to round out their food safety program.
The terms HACCP and food safety are used interchangeably in the food industry, implying that HACCP may be the only approach to food safety. But HACCP is merely a component or tool in an overall food safety program and cannot be implemented without prerequisite programs such as GAPs, GMPs, and a Sanitation Plan firmly in place. This "cafeteria" style approach to food safety has served the fruit and vegetable industry well because the variety matches the multiple needs of the various produce business models from the fields to the fresh-cut processing facilities.
Estimates of the cost of HACCP and GMP implementation require a thorough analysis by expert economists. As an example, Table I-1 indicates the average costs of HACCP and GMP implementation in a typical medium sized fresh-cut processing facility as compared to recent fresh juice figures generated by the FDA in the final rule for fresh juice regulations (FDA 2001). The fresh-cut facility costs were derived from a medium-sized operation located in the middle of the United States and based on real costs averaged over the last 2 years. Costs were estimated based on the current practices in that facility.
Even though these operations use similar raw products, and have similar production activities, juice plant costs differed from the fresh-cut operation costs in several areas. One example is in the line item for pathogen controls. The cost differential occurs because pathogens must be controlled in the juice throughout the production process whereas pathogen control is only applicable in the wash water step for a fresh-cut processor. Also, the start-up costs for installation of a pasteurization system will be much higher than the cost of a chlorination system, but the recurring annual costs are similar. Another area of difference occurs in item 3, Monitoring the Standard Operating Procedures (SOP). The fresh-cut processor's food safety program relies almost exclusively on the prerequisite programs such as sanitation and GMPs to prevent contamination whereas the juice processors rely on pathogen controls such as pasteurization as illustrated in item 6 in Table I-1. In item 9 in Table I-1, outside testing costs are different because the fresh-cut processor has elected not to have an in-house laboratory; therefore, they send all the microbiological tests to an outside lab. Other differences are generally due to different philosophies of management.
Microbiological_hazards_in_fresh_leafy_vegetables_and_herbs_2008.pdf 985.83KB 372 downloadsFor the more sophisticated operations particular attention was given to the washing and sanitization steps where the efficacy of sanitizers and other interventions aimed at reducing pathogen levels were considered. The meeting concluded that while some reduction can be achieved there is a lack of significantly effective options other than heat or irradiation. While the latter can result in several log reductions of even colonising or internalised pathogens, there remains a need for further research focusing on both fundamental attachment mechanisms and inactivation of the pathogens in situ. Thus while processing would appear to be the one step with the potential for the reduction of microbial risks (e.g. disinfection), provide control of amplification of risks (e.g. chilling) and protect the product from further exposure (e.g. packaging), given the current state of knowledge and technology the meeting concluded that if a product is contaminated there is little that can be done to completely remove the contaminant although a reduction can be achieved and actions taken to prevent exacerbation of a problem.
Kind Regards,
Charles.C
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Posted 22 February 2010 - 04:37 PM
I have to say that IMO you selected an extremely complex (and controversial) product area for a risk analysis request. However, it is undoubtedly important based on the various vegetable / fruit (microbial) disasters of recent years as particularly documented in US..
To encourage contributions I thought it might help to add a little background material for preliminary assistance.
added - I subsequently noticed the FAO recent publication (2008) attached below from which I extracted this slightly depressing overview comment -
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Posted 22 February 2010 - 04:41 PM
Hi FSSM
Allergen warning information missing/Incorrect content information
Incorrect date coding
Regards,
Tony
Posted 10 June 2010 - 08:35 AM
Dear FSSM,
Apologies for (very) delayed response to yr vegetable flowchart but I found that an unexpectedly substantial amount of work was necessary to attempt an answer to yr question. And probably similarly with respect to those reading this response.
I mainly agreed with the posted comments on the physical hazards aspect of the vegetable chain - HACCP-ISO 22000 so I have focused on microbiological issues.
To save forum space, it seemed useful to put the content into 4 attachments (DOC0a, DOC1a, DOC2a, E0a). These contain –
(DOC0) – Main text.
(DOC1) - Background material - includes discussion on (i) the general risk status of vegetables and overall viewpoint of Risk Assessment/HACCP applicability, (ii) variable definitions of HACCP / CCP interpretation as particularly (but not exclusively) related to vegetables, + selected HACCP / risk-based analyses in the vegetable farm-to-fork chain, (iii) ISO 22000 related studies for vegetables (seemingly very few), (excluding books), (iv) official example of a simplified quantitative approach to estimating a required process bacterial reduction performance (bean sprouts).
(DOC2) – Background material - (i) a summary of some “descriptions” of the OPRP function which I found interesting and informative, (ii) details of method of assessment of OPRP / CCP in excel sheet E0. (Sadly the concept’s exact relevance still remains rather questionable as far as I am concerned, probably due to my incomplete understanding.)
(E0) – Excel sheet for an ISO 22000 based determination of the “Significant” Control Measures (CMs) in a sample flow chart for the Production of Minimally Processed Vegetables (an essentially Postharvest System)
I hope the material is interesting and useful, any comments very welcome as usual.
DOC0a.doc 279KB
764 downloads
DOC1a.doc 430.5KB
656 downloads
DOC2a.doc 231.5KB
677 downloads
E0a.xls 54KB
738 downloads
Rgds / Charles.C
PS – I hv no doubt there will be some unintentional typos/inconsistencies present, pls inform by pm if minor. If unsure, no problem to post.
Kind Regards,
Charles.C
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Posted 11 June 2010 - 06:27 AM
Dear FSSM,
Apologies for (very) delayed response to yr vegetable flowchart but I found that an unexpectedly substantial amount of work was necessary to attempt an answer to yr question. And probably similarly with respect to those reading this response.
I mainly agreed with the posted comments on the physical hazards aspect of the vegetable chain - HACCP-ISO 22000 so I have focused on microbiological issues.
To save forum space, it seemed useful to put the content into 4 attachments (DOC0a, DOC1a, DOC2a, E0a). These contain –
(DOC0) – Main text.
(DOC1) - Background material - includes discussion on (i) the general risk status of vegetables and overall viewpoint of Risk Assessment/HACCP applicability, (ii) variable definitions of HACCP / CCP interpretation as particularly (but not exclusively) related to vegetables, + selected HACCP / risk-based analyses in the vegetable farm-to-fork chain, (iii) ISO 22000 related studies for vegetables (seemingly very few), (excluding books), (iv) official example of a simplified quantitative approach to estimating a required process bacterial reduction performance (bean sprouts).
(DOC2) – Background material - (i) a summary of some “descriptions” of the OPRP function which I found interesting and informative, (ii) details of method of assessment of OPRP / CCP in excel sheet E0. (Sadly the concept’s exact relevance still remains rather questionable as far as I am concerned, probably due to my incomplete understanding.)
(E0) – Excel sheet for an ISO 22000 based determination of the “Significant” Control Measures (CMs) in a sample flow chart for the Production of Minimally Processed Vegetables (an essentially Postharvest System)
I hope the material is interesting and useful, any comments very welcome as usual.
DOC0a.doc 279KB 764 downloads
DOC1a.doc 430.5KB 656 downloads
DOC2a.doc 231.5KB 677 downloads
E0a.xls 54KB 738 downloads
Rgds / Charles.C
PS – I hv no doubt there will be some unintentional typos/inconsistencies present, pls inform by pm if minor. If unsure, no problem to post.
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Posted 11 June 2010 - 01:10 PM
Dear Tony,
Appreciate yr feedback.
Is this level of control sufficient to make this a CCP?
Does a later step in the process (Washing with Chlorinated Water) remove the hazard?
Kind Regards,
Charles.C
Posted 11 June 2010 - 11:06 PM
Dear FSSM,
Apologies for (very) delayed response to yr vegetable flowchart but I found that an unexpectedly substantial amount of work was necessary to attempt an answer to yr question. And probably similarly with respect to those reading this response.
...
Rgds / Charles.C
PS – I hv no doubt there will be some unintentional typos/inconsistencies present, pls inform by pm if minor. If unsure, no problem to post.
Posted 14 June 2010 - 12:35 AM
Dear Colleagues,
Some months ago, Charles gave us access to a Coca Cola/ Michigan State Food Safety presentations. There's a presentation about the selection of CCP and OPPR's.
http://fskntraining...._04_English.pdf
Attached you'll find the suggested decision tree
Regards
Excel
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Posted 30 September 2010 - 04:20 PM
This are two links that might be of interest to those involved with vegetables...
http://onlinelibrary...10.01630.x/full
Nou, X. and Luo, Y. (2010), Whole-Leaf Wash Improves Chlorine Efficacy for Microbial Reduction and Prevents Pathogen Cross-Contamination during Fresh-Cut Lettuce Processing. Journal of Food Science, 75: M283–M290. doi: 10.1111/j.1750-3841.2010.01630.x
http://onlinelibrary...1722.x/abstract
Luo, Y., He, Q. and McEvoy, J. L. (2010), Effect of Storage Temperature and Duration on the Behavior of Escherichia coli O157:H7 on Packaged Fresh-Cut Salad Containing Romaine and Iceberg Lettuce. Journal of Food Science, 75: M390–M397. doi: 10.1111/j.1750-3841.2010.01722.x
Regards,
FSSM
Edited by Charles.C, 11 September 2014 - 03:50 PM.
Posted 30 September 2010 - 08:35 PM
Dear Excellens,
I previously forgot to thank you for your nice diagrammatic efforts.
There is one box (No3) where the text is odd, ie why would one wish to maintain a significant hazard.? I seem to remember being equally confused by the same text in the original reference.
I hv to say that after working on the previous “vegetables” document, I hv become increasingly negative with respect to most published procedures for differentiating OPRP / CCP in respect to the “requirements” as per the official standard. More precisely, it seems to me that the standard is of sufficient ambiguity that one can adjust risk evaluations almost at will and satisfy auditor’s requirements, I doubt that this was the original intention. Maybe it’s a good thing in practice, ie pragmatic, but seems to defeat the original objectives (whatever they precisely were). I daresay my opinion can be deduced from my recent posts in this thread. It seems to me that, as currently utilised, OPRP is simply becoming redundant for practical purposes.
Would appear that ISO hv no current intention of making any changes / clarifications in the OPRP content perhaps due to their preoccupation with becoming fully GFSI compliant. I am wondering if a decline in usage of ISO 22000 will occur in favour of the other GFSI –non-oprp-requiring co-members.
Rgds / Charles.C
Kind Regards,
Charles.C
Posted 30 September 2010 - 08:51 PM
Dear FSSM,
thks yr links (both to same article? ).
I extracted a bit -
The products were stored at 5 and 12 °C until their labeled “Best If Used By” dates, and the microbial counts and product quality were monitored periodically. The results indicate that storage at 5 °C allowed E. coli O157:H7 to survive, but limited its growth, whereas storage at 12 °C facilitated the proliferation of E. coli O157:H7. There was more than 2.0 log CFU/g increase in E. coli O157:H7 populations on lettuce when held at 12 °C for 3 d, followed by additional growth during the remainder of the storage period. Although there was eventually a significant decline in visual quality of lettuce held at 12 °C, the quality of this lettuce was still fully acceptable when E. coli O157:H7 growth reached a statistically significant level. Therefore, maintaining fresh-cut products at 5 °C or below is critical for reducing the food safety risks as E. coli O157:H7 grows at a rapid, temperature-dependent rate prior to significant quality deterioration.
Kind Regards,
Charles.C
Posted 25 October 2010 - 05:36 AM
Dear All,
Just for casual interest, the table below (found on the net) shows a variety of food hazards / control measures classified into CCPs / OPRPs respectively. I believe the presentation was intended as part of an auditor group-evaluation scheme rather than a (concluded designation) reference list but sort of interesting nonetheless IMO.
Collection of examples of various CCPs - OPRPs.png 337.35KB
199 downloads
Charles.C
Kind Regards,
Charles.C
Posted 25 October 2010 - 05:52 AM
Dear All,
Just for casual interest, the table below (found on the net) shows a variety of food hazards / control measures classified into CCPs / OPRPs respectively. I believe the presentation was intended as part of an auditor group-evaluation scheme rather than a (concluded designation) reference list but sort of interesting nonetheless IMO.
Collection of examples of various CCPs - OPRPs.png 337.35KB 199 downloads
Charles.C
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Posted 30 October 2010 - 07:00 AM
Dear All,
A Short Note on Selection OPRPs / CCPs
This is a (partial ) agreement with Charles Chew’s opinion in another thread regarding the simplicity of the above-titled topic. However, IMO, this necessitates the consideration of ISO 22004 to be effectively a revised version of 22000 with respect to certain topics, eg the implementation of OPRPs.
One can perhaps equate CCP/OPRP to the Gold / Silver Standards in health treatment procedures, both are proven capable of achieving the desired result but the former has some more desirable features than the other, eg faster recovery.
Similarly, according to ISO 22004, the control measures (CMs) associated with a potential CCP/OPRP must, before categorisation takes place, be validated as achieving the intended level of control (ie acceptable level appropriate to food safety). This validation aspect (eg para 8.2 / 22000) is, IMO, unfortunately understated in paras 7.4 - .7.6, an omission which is attempted to be corrected in 22004, both textually and figuratively (eg see fig3). It seems to me that a viable validation should self-reject control measures which are simply impractical, eg do not permit corrective actions in a timely manner.
As per the above, I feel that a CM associated with an OPRP should have a "capability" close to that of a CM used at a CCP, not just be of "CCP-reject" status as tends to be implied by some categorisation procedures. Such a result also indicates an opportunity for improvement. The high degree of unconcern over the final ratio of CCPs / OPRPs is spelled out in 22004, hopefully read by all auditors.
Choosing the “Acceptable Level” which is the basis of the Hazard Analysis is not always so “simple” IMO, eg is Salmonella more correctly selected as per the typical Regulatory requirement or a more science based route via Minimum Infective Dose analysis ? The former is certainly likely to cause less hassle but adequate on FS grounds ?? (This aspect is, for example, of interest for products like fruit / vegetables with no bactericidal process step; the cumulative result of various CMs can be directly tested / validated to a typical Regulatory requirement but not so readily to MID type criteria.)
As an extension of the simplicity topic, I recently came across this one-stop Decision Tree for selecting between CCP / OPRP based on a slight modification of the traditional Codex HACCP tree. Contains a few innovative ideas and is worth examination IMHO, as is the detailed source document attached. Just shows how people love their pets.
iso 22000 oprp decision tree, 2010 -.png 89.53KB
92 downloads
safe manufacturing, ver 2010, .pdf 536.08KB
328 downloads
Rgds / Charles.C
Kind Regards,
Charles.C
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Posted 19 June 2011 - 04:24 AM
Can we have OPRP after a CCP, I mean can last step of a process can be an OPRP?
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Posted 11 November 2012 - 11:37 AM
DOC1a.doc 430.5KB 656 downloads
DOC2a.doc 231.5KB 677 downloads
E0a.xls 54KB 738 downloads
Rgds / Charles.C
PS – I hv no doubt there will be some unintentional typos/inconsistencies present, pls inform by pm if minor. If unsure, no problem to post.
Edited by Bahram Doulati, 11 November 2012 - 11:38 AM.
Posted 11 November 2012 - 06:21 PM
very important but not sufficient information
Thanks a lot and we will wait for more.....
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Posted 06 April 2014 - 05:49 AM
Dear Mr. Charles.C / Mr. Tony
I just starting new project on BRC FS Ver 6.0 on Cold Chain (end to end solution) and also GLOBAL GAP on agricultural farm back ward linkage to cold chain facility. Going through the various threads. Information is very usefl and informative to make my action plan ready to give shape for this project.
Once again thanks and great contribution for food safety professionals across the globe.
B T Gorti
food safety and compliance expert
Skype id-Saradiro Services
website-www.saradiro.com
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