Hello Mr RALH.
CCP based on Subjective data like visual Inspection is normally practised by Chefs in restaurants like roasting/grilling or smoking of the products,where he observes the color change of the product while grilling etc.How ever this has to be validated and such training may be provided to trianee chefs etc.and supported by SOP.
Ingenious suggestion but I am dubious as to its ISO 22000 validity.
One of the primary reasons for the original introduction of the “OPRP” program was to handle situations where a hazard was risk-assessed as a potential / necessary “CCP” but quantitative critical limits could not be readily allocated/validated. Subsequently, the interpretation has “enlarged”.
A similar approach to yr idea is seen in the SFBB (safer food better business) system in UK. This was implemented in certain business applications, eg catering, so as to satisfy the compulsory requirements of the haccp portion of the ca.2006 EC food safety directive. (Attempts to implement a formal haccp approach were found impractical, ie technically too difficult for intended users).
The UK text is careful to note –
“This pack is based on the principles of HACCP (hazard analysis and critical control point), but you will not find words such as ‘HACCP’ or ‘hazard’ in the pack because we have cut out all the jargon.” Nor will you find any reference to CCP. Have attached document below if anyone interested.
One might (generously?) call this an “informal” haccp methodology.
In above case, the validation of the “critical limit” was that the methodology was officially issued/auto-approved.
I can see the attractiveness of a similar approach for ISO 22000 in the industries mentioned but I doubt that this was the intended purpose of the text under current discussion. Also doubt that this interpretation would be acceptable in an audit for compliance to the ISO 22000 standard.
However only too willing to be convinced by some data – can you elaborate on its application (in India?) / supply any links to the published acceptability of this interpretation for ISO 22000 purposes ?
Rgds / Charles.C