Hello:
I found this thread highly interesting. I have been teaching HACCP since 1995 at the state level as a regulator and independently, and have developed over 100 food safety systems and have audited about 300 operations under GFSI standards; I also develop BRC systems as well as those to comply with PGFS and other similar standards.
Several areas of missing scientific information, specifically the efficacy of any antimicrobial treatment, confound the issue of setting CCP in the packing of fresh produce. There are currently no registered antimicrobials for human pathogens on whole fruits and vegetables. This is because to meet the standard as a sanitizer under FDA rules, the application must result in a 5-log or greater reduction in target organisms on the plant material. Many existing studies only reference about a 1-2 log reduction, about the same as plain potable water rinse. Since the definition of a CCP is that it is step that will eliminate, prevent or reduce a significant hazard to acceptable levels must be met, we cannot scientifically require a CCP for human pathogen reduction by applying an antimicrobial, unless we have peer reviewed publish studies relevant to the process. But then, the problem arises as such studies can conflict, one showing efficacy while others under similar laboratory conditions showing infectiveness, and all of this is highly dependent on the plant material itself, as well as many variables in the application, time, temperature, coverage, concentration, pH, on and on.
The mandated use of HACCP for fresh produce puts operations in jeopardy since and auditor can rule either way in an evaluation of the need for a CCP. If one tries to rely on the hazard analysis as justification, you run right up against the same problem of significance, what one person considers likely, and what another person considers likely is subject to all sorts of bias.
What we can say, however, is that when water is reused (re-circulated) we can find a CCP for the treatment of the water. We can in-fact eliminate harmful bacteria that build up in reused water through application of several registered products (registered for water treatment).
Thus the dump tank issue constitutes a significant hazard for cross contamination and growth of bacteria, if the tank water does not retain antimicrobial qualifies. Additionally, if produce is cut, exposing vulnerable plant tissue, colonization of the plant material is likely if re-circulated water quality is not maintained, thus strengthening he argument for a CCP.
Such cut plant material can also grow harmful bacteria, and the FDA Food Code for example requires processed produce to be maintained at below 41 degrees in storage, thus we have a CCP that is legitimate and valid for cold holding of processed fruits and vegetables.
Finally, metal detection comes up as a CCP when inclusion of metal is likely, when cutting with saws, blades or other mechanical methods.
It is worthy to note that FSMA preventative controls say nothing about CCP. This is a political answer to the difficulties of scientific validity for claiming a CCP in whole produce as found in the private standards.
The application of HACCP to the packing of whole fruits and vegetables is a terribly biased and uneven field and has placed the industry under GFSI requirements in a very vulnerable spot, and unfairly so.
