Jump to content

  • Quick Navigation
Photo

Verification Frequency for Cold Storage CCP

Share this

  • You cannot start a new topic
  • Please log in to reply
10 replies to this topic
- - - - -

agasr

    Grade - AIFSQN

  • IFSQN Associate
  • 37 posts
  • 9 thanks
2
Neutral

  • United States
    United States

Posted 31 July 2015 - 11:46 PM

Hello all, 

Curious to know common practice across the industry when it comes to CCP Monitoring & Verification documentation related frequencies in Cold Storage. Some of our sites handle/store perishable TCS foods like Dairy, Fresh Pasta etc.,  that are stored in Refrigerated conditions. In our Hazard analysis we have determined the storage step to be a CCP. The coolers where the products are stored are monitored every 15 mins by a software (LOGIX) & All alerts on any deviation is also communicated by the software to our engineering team for them to react & control before it becomes anywhere close to a food safety issue.  That is a tremendous technological advantage for us to ensure food safety by being timely & accurate data. 

 

While that is the Montoring aspect, I would like the forum members to weigh in on the frequency that you would aim for the formal review of data & its documentation with sign offs thus generated for verification purposes. Feel that it could be anywhere from Daily to a Weekly Frequency. 

 

Since this is unlike a Manufacture setup where one can do hourly checks, batch wise Verification checks on CCP to assist release, I eagerly look forward for your suggestions & practices. 

 

Regards, 

Sripriya. 



seafood

    Grade - Active

  • IFSQN Active
  • 7 posts
  • 8 thanks
0
Neutral

  • Earth
    Earth

Posted 03 August 2015 - 11:59 AM

By law you must review CCP monitoring data at least every 7 days.  Past 7 days you would need to write some kind of corrective action.  Daily would be required before pre-shipment release due to micro hazards that may require testing for ready to eat items but that shouldn't pertain to you.



Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 20,542 posts
  • 5662 thanks
1,544
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 03 August 2015 - 04:39 PM

Hello all, 

Curious to know common practice across the industry when it comes to CCP Monitoring & Verification documentation related frequencies in Cold Storage. Some of our sites handle/store perishable TCS foods like Dairy, Fresh Pasta etc.,  that are stored in Refrigerated conditions. In our Hazard analysis we have determined the storage step to be a CCP. The coolers where the products are stored are monitored every 15 mins by a software (LOGIX) & All alerts on any deviation is also communicated by the software to our engineering team for them to react & control before it becomes anywhere close to a food safety issue.  That is a tremendous technological advantage for us to ensure food safety by being timely & accurate data. 

 

While that is the Montoring aspect, I would like the forum members to weigh in on the frequency that you would aim for the formal review of data & its documentation with sign offs thus generated for verification purposes. Feel that it could be anywhere from Daily to a Weekly Frequency. 

 

Since this is unlike a Manufacture setup where one can do hourly checks, batch wise Verification checks on CCP to assist release, I eagerly look forward for your suggestions & practices. 

 

Regards, 

Sripriya. 

 

I assume there is no mandatory requirement.

 

From a practical POV, the key questions are how much risk you are prepared to take that no mistakes will  occur ?. And what is yr intended corrective action if there is a mistake ? eg worst case scenario - reject 6 days of product ?

 

My auditors allowed max 2 days after the monitoring record. That's why they call it a critical control point.  :smile:


Kind Regards,

 

Charles.C


Thanked by 1 Member:

Slab

    Grade - SIFSQN

  • IFSQN Senior
  • 438 posts
  • 208 thanks
105
Excellent

  • United States
    United States
  • Gender:Male
  • Location:The Heel of the Boot
  • Interests:Reading (history, science fiction), Photography, drawing,food safety, metrology, TQM, hoplology, etc.

Posted 03 August 2015 - 06:13 PM

Temperature controls really depend on product, process, and associated hazards.

 

However, you have determined this a CCP so monitoring should be continuous with offsite notification when cold storage CL fail (ref. FDA seafood HACCP). Verification (record review?) should be conducted no more than 7 days from record preparation.

 

As Charles C has mentioned a financial/food safety liability review of records would be best conducted based upon internal/scientific risk assessment. 

I find that CH. 12 and relevant tables of the FDA Seafood Hazards Guidance an excellent example for cold storage:

Attached File  Fisheries Guidance Chapter 12.pdf   774.03KB   107 downloads

 

My auditors allowed max 2 days after the monitoring record. That's why they call it a critical control point.   :smile:

 

 

Charles, what standard/model does this reference? 


Food Safety News  Marine Stewardship Council

 

"Some people freak out when they see small vertebra in their pasta" ~ Chef John


Thanked by 1 Member:

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 20,542 posts
  • 5662 thanks
1,544
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 03 August 2015 - 07:45 PM

Hi Slab,

 

Charles, what standard/model does this reference?

 

A local haccp regulatory interpretation of, from memory, a USFDA workshop.  But BRC were quite impressed also. And so were the overtime recipients.  :smile:

 

Without checking, I predict there are numerous published examples of < 7 days around also. Shades of on-line validation of Metal Detectors IMO.


Kind Regards,

 

Charles.C


Thanked by 2 Members:

seafood

    Grade - Active

  • IFSQN Active
  • 7 posts
  • 8 thanks
0
Neutral

  • Earth
    Earth

Posted 03 August 2015 - 07:45 PM

I would also like to know which standard that comes from and in what circumstance.  

 

If monitoring is continuous your engineering team (AND you) should be notified immediately electronically if there is a deviation at which juncture you would review the record and establish a path forward or corrective action.  If there were no deviations I don't see why it would be an issue going 7 days but it is far from a best practice.  If your engineering team is not trustworthy or you don't feel confident in their ability to perform a corrective action according to the procedure then it may be in your interest to perform a records review sooner or have the alerts sent directly to you as well so you can follow up asap.  If this is a cold storage facility you are referring to then I would imagine the owner of the product would be contacted for the disposition of the product following a deviation and you should be the one speaking with them regarding time and temperature abuse data collected during the deficiency and after the corrective action was taken so they may make an informed decision.



Thanked by 1 Member:

trubertq

    Grade - PIFSQN

  • IFSQN Principal
  • 658 posts
  • 281 thanks
137
Excellent

  • Ireland
    Ireland
  • Gender:Female
  • Location:Donegal

Posted 03 August 2015 - 08:44 PM

Personally I would be reviewing daily and signing off, because if something is wrong or missed how long would you be comfortable leaving it before detection?


I'm entitled to my opinion, even a stopped clock is right twice a day

Thanked by 1 Member:

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 20,542 posts
  • 5662 thanks
1,544
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 04 August 2015 - 10:39 PM

Hi agasr,

 

I had a little look into the haccp frequency of record review on the net.

 

TBH, the issue of "official" frequency where related to any verification, review-type activity is, afai could see, typically (and perhaps predictably) evaded with respect to actual numbers. The potential consequences of an actual failure are generally also evaded.

 

The specific usfda 1 week noted in post #4 seems to be a rare “official” example. It's justification is detailed in  the Seafood final rule 1995 -

 

FDA is convinced that a weekly review of HACCP monitoring and corrective action records would provide the industry with the necessary flexibility to handle highly perishable commodities without interruption, while still facilitating speedy feedback of information. FDA is reluctant to allow the level of flexibility provided by such language as ‘‘reasonable time,’’ out of concern for the confusion that it would generate. FDA’s experience with low-acid canned foods and acidified foods has demonstrated that review of these kinds of records is a critical verification tool. FDA is, therefore, adopting the proposed provision as § 123.8(a)(3) with one revision. As set out in the final rule, it requires that the HACCP-trained individual review the monitoring records of CCP’s and the records that document the taking of corrective actions within 1 week of the making of the records, rather than before shipment, as a part of a processor’s erification activities (§ 123.8(a)(3) (i) and (ii)).

FDA agrees, on the other hand, that this principle need not apply to the review of records of such verification activities as process control instrument calibration and product testing. The frequency of these activities will be variable and dependent upon the HACCP plan development process. Consequently, setting a specific review frequency for these records is not warranted. .......etc.

.Attached File  21CFR Parts 123 and 1240.pdf   876.9KB   62 downloads

 

Milk USA seemed to me to be relatively honest, albeit non-specific –

 

This review shall occur at a frequency that is appropriate to the importance of the record
These reviews shall occur within a reasonable time after the records are made.

http://www.fda.gov/F...P/ucm121336.htm

 

This impressive (official-looking) model audit training program is highly detailed/readable but afai could see remains non-specific (as are also the quoted CFR regs) although the neat  haccp example plan included  has daily review for some records, weekly for others. Perhaps the USDA ideal ?

Attached File  HACCP verification, Workshop model,2015.pdf   451.93KB   116 downloads

 

In contrast, this model “meat haccp”  example, presumably from the "meat haccp" website, for a (lower risk) system uses weekly (I didn't investigate their higher risk examples probably also on the website).

Attached File  meat haccp, bacon_haccp_plan.doc   136.5KB   65 downloads

 

There is also a related thread on this forum although for slightly more general verification scope than current one  –

http://www.ifsqn.com...ccp/#entry67028

 

Assuming corrective actions are not a concern (!), I think the OP’s original suggestion of 1 – 7 days has literature support provided that (a) no regulatory limit exists, (b) hazard analysis / historical monitored results/data is not incompatible.

 

Regardless, I  agree with Trubertq  (despite my own 2-day tolerance) that, at least for critical data like cooking outputs, a daily review makes sense. It all comes back to RA again. And potential costs. And maybe job security. :smile:


Kind Regards,

 

Charles.C


Thanked by 2 Members:

agasr

    Grade - AIFSQN

  • IFSQN Associate
  • 37 posts
  • 9 thanks
2
Neutral

  • United States
    United States

Posted 06 August 2015 - 11:28 PM

Thanks to all for responding with your views/suggestions. Very appreciative of this website/forum. 

 

To clarify, the LOGIX software operates with a tighter bandwidth compared to the Critical Limits on our CCPs. The Online monitoring is 24x7. On rare occasions when the room temps go above the Operating limits, there are instant alerts to the engineering teams via email, text & Call. Hence my remark on that the product dont go anywhere close being in a food safety risk. 

 

I would also like to know which standard that comes from and in what circumstance.  

 

If monitoring is continuous your engineering team (AND you) should be notified immediately electronically if there is a deviation at which juncture you would review the record and establish a path forward or corrective action.  If there were no deviations I don't see why it would be an issue going 7 days but it is far from a best practice.  If your engineering team is not trustworthy or you don't feel confident in their ability to perform a corrective action according to the procedure then it may be in your interest to perform a records review sooner or have the alerts sent directly to you as well so you can follow up asap.  If this is a cold storage facility you are referring to then I would imagine the owner of the product would be contacted for the disposition of the product following a deviation and you should be the one speaking with them regarding time and temperature abuse data collected during the deficiency and after the corrective action was taken so they may make an informed decision.

 

Very well captured seafood, only in the light of it being continuous monitoring  and solid response to alerts  I was wondering as what is the experience around the industry in terms of Verification frequency being more than daily. 

 

Thanks for your inputs. 

 

Hi Charles, 

 

Assuming corrective actions are not a concern (!), I think the OP’s original suggestion of 1 – 7 days has literature support provided that (a) no regulatory limit exists, (b) hazard analysis / historical monitored results/data is not incompatible.

 

Regardless, I  agree with Trubertq  (despite my own 2-day tolerance) that, at least for critical data like cooking outputs, a daily review makes sense. It all comes back to RA again. And potential costs. And maybe job security. :smile:

 

Thanks for a detailed account on the sources and the suggestions. Very helpful. The Corrective actions are not a concern, our history on alerts is very good not meriting a Daily Verification. Hence this attempt to see if we can go for a Weekly Verification process instead of Daily. Of course, should something change in our review, we could always move back to higher frequency at a later date. 

 

Thanks again for all your inputs. 

 

Regards,



FoodSafety_101

    Grade - Active

  • IFSQN Active
  • 16 posts
  • 4 thanks
0
Neutral

  • Canada
    Canada

Posted 07 August 2015 - 03:35 AM

Hi 

 

I agree with Seafood, I assist with another consultant at a CFIA federally inspected Cold Storage, with no coolers. They have no CCP. And CFIA performs whats called a "Section 4" Audit, where every two years the government audits federally registered Food Safety plans ( i.e FSEP). This facility has probes with alerts and a engineer on staff which also has a legal obligation to hold as an engineer. They have never been told they needed their Temperature as a CCP. They have procedures and steps in place (obviously) if a deviation occurs. Guess it all boils down to you hazard analysis and your particular risk. 



Tony-C

    Grade - FIFSQN

  • IFSQN Fellow
  • 4,223 posts
  • 1288 thanks
608
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Location:World
  • Interests:My main interests are sports particularly football, pool, scuba diving, skiing and ten pin bowling.

Posted 07 August 2015 - 04:51 AM

I would expect sign off of 'cooler refrigeration temperature records' each shift or at the end of the day by a supervisor/manager. It takes the same time to review as it would a week later. When I worked as a Production Shift Manager this would be one of the routine checks I would carry out during the shift along with processing temperatures, thus ensuring there were no 'surprises' at the end of the shift/day!

 

One other thing, I don't see this as verification, my idea of verification would be checks of product temperatures.

 

Regards,

 

Tony





Share this

0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users