Dear SriramB,
No problem to discuss, it’s a generally interesting topic (to me anyway ).
For myself, development of yr query first requires a realistic hypothesis/justification as to why hand-cleanliness might be a significant hazard?.
PS assuming that a significant risk is concluded, one criterion for determining the standards (self-imposed) choice between ccp/oprp might be based on the ability to define a validatable critical limit.
Hi Charles,
sorry but I am getting lesser occasions to log in and hence the delay.
I agree that every case will merit different conclusion, but am putting forward an hypothetical situation:
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Assume we start of with a pie making plant, where end product is well cooked etc...
Now, we want to add a new "salad' packing line, on a small scale. Also assume we plan to pack salad leaves manually by hand.
The QA manager believes Gloves give a false sense of cleanliness and prefers to use plain , cleaned hands.
Now, the
HACCP team sits to review the line, and the following observations are made:
1. there are known occurences from the market of other brand Salads being withdrawn due to E coli contamination.
2. Ecoli could cause severe and wide spread food safety issues.
Now the salad line is climate controlled and positive air pressure etc. The salad is washed and treated before it comes to packing station. routine tests find that the leaves are clean at this point of the process. these leaves are now packed manually into bags. the bags will be kept cool etc till consumer gets them.
Our only worry is that the
manual packing must not introduce any pathogens to the product.
3. Our salad line has a handwashing station at entry and also many other stations e.g. in the cafeteria, toilets etc..
4. The path a employee takes from the Toilet to the salad line is such that, he may touch railings, door handles etc.
We do some tests and find that the railings and door handles, have micro contamination.
5. Operations manager says it is not feasible for him to ensure all possible contact surfaces are kept clean especially in walkways etc..
6. The
HACCP team determines that the final handwash station on the actual salad line probably is most suitable for getting the hands clean.
7. The
HACCP team also reflects that there are similar final stations in the Pie making line, but the fact that pies are cooked etc, reduces the risk of the living contaminant from passing on to final customer.
8. On the same token, the salad line is susceptible, as the contaminant
can pass on to the consumer.
Process Map:
9. now the process flow shows the salad leaves packing as part of the steps, but the handwashing is not indicated as a 'equipment', 'step/ or 'process' which the product ' i.e.' 'Salad' passes through.
10. Indeed , handwashing seems to be included generally under the Hygiene PRP.
11. But the
HACCP team decides that the handwashing activity has a greater role to play, in the "Salad" line. it is preventing the fresh contaminantion from Hands , but not used for removal/ mitigation of any contamination already present in the 'Salad'.
12. If this Hand washing was compromised , consumers would very likely fall sick based on other industry experience.
(hence High Probability and also High severity)
13. So, some one says lets make it a critical step... OK, but in theory it is still not part of the 'Product' flow chart. It is a PRP.
14. So, someone else says, lets make this a crucial PRP or an oPRP.
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Quote"
assuming that a significant risk
is concluded, one criterion for determining the standards (self-imposed) choice between
ccp/oprp might be based on the ability to define a validatable critical limit. "
Here the critical limit for hazard ( I am taking pathogenic bacteri as the hazard)= 0 numbers pathogenic bacteria on hand
So Operational limit to ensure adequacy of handwashing, hypothetically based on studies, could be (i.e. Operational Control Points) :
1. rinsing hands under water- set time ( indicated by light)
2. Uisng treated soap dispensed in preset quantity ( dosed with flourescent indicator)
3. Scrubbing till Light indicator goes off
4. Rinsing - set time
maybe even,
5. inspecting hand under UV blacklight ( no flouresecence = cleaned hands)
The above procedure could be validated by trials and micro tests.
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In the above case, I would find Handwashing as critical on the specific Salad line compared to other areas.
I would get a validated procedure as it merits being proven effective and measurable.
I would find
CCP not the right word as it is not part of product flow.
Maybe oPRP suits as it is part of a PRP but more improtant in context of this line.
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Whew.............. Sorry for inflicting the above on you
, but I am still getting interested in this topic!
Like i said I am not in this industry, so please forgive if I have imagined a completely unfeasible way to produce Salads!
Regards,