22 replies to this topic

[akool18]

Dear everybody,

I am confused of answering CCP decision tree (follow HACCP Codex Alimentarius)

Beginning with Q1 : Yes

Then Q2 : No

Q3: Yes

And Q4 :No

Finally, that processing step turn to be CCP following decision tree.

The thing that make me confused is that the content of Q2

Q2 = Does this step eliminate or reduce the likely occurence of the hazard? The answer is "No". How could this step be CCP if this step cant eliminate or reduce the likely occurence of the hazard?

The decision tree result in CCP but CCP can not reduce or eliminate hazard. 

So in this case, in Q4 if there is no subsequent step eliminate or reduce hazard. Next step could back to Q1a (or Q2b in other CCP decision tree version) which is to modify the step or process or product. If we dont re - modify, the final product would be unsafe.

I am looking forward to hearing from you, 

 

[Charles.C]

Dear everybody,

I am confused of answering CCP decision tree (follow HACCP Codex Alimentarius)

Beginning with Q1 : Yes

Then Q2 : No

Q3: Yes

And Q4 :No

Finally, that processing step turn to be CCP following decision tree.

The thing that make me confused is that the content of Q2

Q2 = Does this step eliminate or reduce the likely occurence of the hazard? The answer is "No". How could this step be CCP if this step cant eliminate or reduce the likely occurence of the hazard?

The decision tree result in CCP but CCP can not reduce or eliminate hazard. 

So in this case, in Q4 if there is no subsequent step eliminate or reduce hazard. Next step could back to Q1a (or Q2b in other CCP decision tree version) which is to modify the step or process or product. If we dont re - modify, the final product would be unsafe.

I am looking forward to hearing from you, 

 

Hi akool,

 

i think it is important to remember that -

 

(1) The objective of the initial stages of the Codex HACCP System is to determine if, and where, Critical Control Points (CCPs) may exist in the Process Flow.

(2) CCP (Codex) is defined as - A  step  at  which  control  can  be  applied  and  is  essential  to  prevent  or eliminate a food safety hazard or reduce it to an acceptable level.

 

I do agree the interpretation of the Codex Decision Tree can be rather subtle. I think the present confusion is due to an initial misquote, ie Q2 of Codex tree should read -

 

"Is the Step specifically designed to eliminate or reduce the likely occurrence of a hazard to an acceptable level**?"

 

The significance/interpretation of the missing words can be explained (based on Mortimore) as per attachment below -

 

 Codex decision tree, Question2.pdf   28.91KB   277 downloads

 

Hope the above assists.

[akool18]

Dear Charles C.

 

Thank you for your nice explanation. HACCP is clearer to me now. But i am still wondering

 

In case of Q2 = No. It means that step is not  specifically designed to eliminate or reduce the likely occurrence of a hazard to an acceptable level. 

And, if the step is not specifically designed, how could it satisfy the effectiveness level (below 14 as i remember in some assessment control measure)

 

If the step does not satisfy effectiveness level how it could be practically monitored?

 

Thus, if it become CCP in the end, how could we monitor that step (CCP)?

 

i dont like to say " i think". But, as you said 

(1) The objective of the initial stages of the Codex HACCP System is to determine if, and where, Critical Control Points (CCPs) may exist in the Process Flow.

 

In the case, Q1,Q2,Q3,Q4 = YNYN, we must notice that this step may be CCP. And, after that, we have to consider if it satisfy effectiveness level. Incase it does not satisfy effectiveness level, it have to be specifically re - designed for practical monitoring?

 

It is what you mean, isnt it?

 

I am looking forward to hearing from you

[Charles.C]

Dear Charles C.

 

Thank you for your nice explanation. HACCP is clearer to me now. But i am still wondering

 

In case of Q2 = No. It means that step is not  specifically designed to eliminate or reduce the likely occurrence of a hazard to an acceptable level. 

And, if the step is not specifically designed, how could it satisfy the effectiveness level (below 14 as i remember in some assessment control measure)

 

If the step does not satisfy effectiveness level how it could be practically monitored?

 

Thus, if it become CCP in the end, how could we monitor that step (CCP)?

 

i dont like to say " i think". But, as you said 

(1) The objective of the initial stages of the Codex HACCP System is to determine if, and where, Critical Control Points (CCPs) may exist in the Process Flow.

 

In the case, Q1,Q2,Q3,Q4 = YNYN, we must notice that this step may be CCP. And, after that, we have to consider if it satisfy effectiveness level. Incase it does not satisfy effectiveness level, it have to be specifically re - designed for practical monitoring?

 

It is what you mean, isnt it?

 

I am looking forward to hearing from you

 

Hi akool,

 

Please study the example in the attachment. One needs to focus on the "can" and "essential" in point (2) of my previous Post. The Critical Limit quantitates the "How".

 

The Tree is typically used as a Decision Tool so either YES/NO response pattern in the example is considered as sufficient to confirm a CCP. .

 

In practice, various Process steps commonly associated with CCPs  are "specifically designed" which is one reason why this specific question is in the Codex Tree. However modern HACCP (and particularly ISO-HACCP) has tended to define some of these "traditional" CCPs  (eg "Receiving") as  PRPs. This change is reflected in the more recent Campden Decision Tree which adds a preliminary YES/NO  PRP query to the Codex format.

 

Personally i rarely use the Codex Decision Tree. It's easier IMO to use direct Risk Assessment > CCPs. Less arguments.

 

The Practical HACCP text book by Mortimore et al offers numerous examples (and discussion) of the Codex Tree and is worth reading to appreciate the variations.

Edited by Charles.C, 11 December 2016 - 09:43 AM.
expanded

[akool18]

Dear Charles C,

So we have 2 methods to identify CCP, is it right? And, the second way risk assessment, is it offically accepted method? I also prefer risk assessment method to CCP decision tree method. But, i am afraid that auditor from third party does not  accept.

I am looking forward to hearing from you

Sincerely yours,

[Charles.C]

Dear Charles C,

So we have 2 methods to identify CCP, is it right? And, the second way risk assessment, is it offically accepted method? I also prefer risk assessment method to CCP decision tree method. But, i am afraid that auditor from third party does not  accept.

I am looking forward to hearing from you

Sincerely yours,

 

Hi akool,

 

I suggest you ask yr auditor which basic Methodology(s) will be acceptable for determining HACCP CCPs. Or perhaps it is stated in the relevant Standard ?.

 

Assuming Codex is acceptable, here is a quote from Codex (2009) –

 

7.  Determine CCPs (see Principle 2)

 

The determination of a CCP in the HACCP system can be facilitated by the application of a decision tree (e.g. Figure 2), which indicates a logic reasoning approach. Application of a decision tree should be flexible, given whether the operation is for production, slaughter,  processing,  storage,  distribution  or  other.  It  should  be  used  for  guidance when determining CCPs. This example of a decision tree may not be applicable to all situations. Other approaches may be used. Training in the application of the decision tree is recommended.

 

 

If you re-examine the structure of the Codex Decision Tree I think you will see that the 2 response patterns quoted are self-defined.

[Foodworker]

In my opinion, the Codex Decision Tree is responsible for more ineffective and cumbersome food safety systems than imaginable. It is a tool which may be used but it is not mandatory in Codex or any of the main food safety standards.

 

What is normally mandatory is the risk assessment itself, ie how likely is it that a hazard will occur and if so how serious is it. There are numerous systems sround to do this.

 

The only question from the Decision Tree which serves much purpose is the subsequent step.

 

HACCP courses, be they for food or packaging still seem to spend half the time going through the Decision Tree questions.

 

Students come out of these courses bewildered when back in their own environment. I have seen countless systems where the risk assessment shows that all potential hazards have zero or minimal risk but they are still all put through the Decision Tree. If something is not a risk, it can't be critical.

 

As said earlier, do a good risk assessment, if there is a high risk and there is no subsequent step call that a CCP. 

 

If a BRC auditor penalises you for not using the Decision Tree challenge it.

[akool18]

Dear Foodworker and Charles C,

Thank you for your help.

So precious advice.

[Charles.C]

Hi Foodworker,

 

I don't disagree with yr comments but a large part of the blame IMO rests with Codex since, afaik it still, after 20 years, fails to specify whether the tree, if used, should (a)  only be applied to "significant"  hazards or (b) used for every Process Step. Codex then offers no examples of hazard analyses to clarify the matter. IMEX most haccp courses, auditors, and many, IMO, otherwise brilliant haccp texts implement the latter option. Why they do it i can only assume is for presentation convenience. The result is a decision tree encyclopedia

 

In comparison the NACMCF haccp text which afaik is supposed to be harmonised with Codex spells out to use the former option (if used at all).

 

Personally i incorpoate the existence or otherwise of a "subsequent step" in my initial Risk Assessment. (Presumably unacceptable logic to FSMA though ? ).

[CMHeywood]

Control measures are for contamination (biological, chemical and physical).

 

What you are saying:

(1)  Yes, we have control measures because there could be contamination.

(2)  No, the control measures don't remove or reduce the contamination.  (You are saying your control measures don't work or you don't have the correct control measures)

(3)  Yes, the contamination remaining after the process could be at an unacceptable level.

(4)  No, a subsequent process would not remove or reduce the contamination to an acceptable level.

 

So you are either selling product with an unacceptable level of contamination, or any contamination in the finished product is always at an exceptable level (question 3), or you are not understanding what control measures are necessary to remove the unacceptable contamination from your product (question 2).

 

The way you monitor this process is to determine if all the production settings are correct during production, the gauges are reading correctly, and some sort of testing or inspection to determine that any contamination is at an acceptable level before going to the next process.

[akool18]

Control measures are for contamination (biological, chemical and physical).

 

What you are saying:

(1)  Yes, we have control measures because there could be contamination.

(2)  No, the control measures don't remove or reduce the contamination.  (You are saying your control measures don't work or you don't have the correct control measures)

(3)  Yes, the contamination remaining after the process could be at an unacceptable level.

(4)  No, a subsequent process would not remove or reduce the contamination to an acceptable level.

 

So you are either selling product with an unacceptable level of contamination, or any contamination in the finished product is always at an exceptable level (question 3), or you are not understanding what control measures are necessary to remove the unacceptable contamination from your product (question 2).

 

The way you monitor this process is to determine if all the production settings are correct during production, the gauges are reading correctly, and some sort of testing or inspection to determine that any contamination is at an acceptable level before going to the next process.

Dear CmHeywood,

The problem is not choosing the CM. Problem is answering question following decision tree.

And, furthermore, any step in processing flowchart may become CCP. And after it is choosed to be CCP, Control Measure is designed for that step. 

Or:

We choose CCP and control measure before building up flowchart. and if so, answering CCP decision is meaningless. For example, for detecting metal, galss, ... we use Xray or metal detector at the end of the production. So, is it necessary to anwer CCP decision tree?

[Ioannisg2364]

Sorry but I am also a little confused when determining whether for example cold storage is a CCP (for pathogens) or not (by the way, a subsequent step in the process flow diagram is cooking).

 

If I do not use the codex decision tree  and I only consider the definition of a CCP (i.e. a critical control point is defined as a step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level) for my decision, then cold storage is a CCP because cold storage aims to prevent a food safety hazard from reaching unacceptable levels.

 

If, however, I use the codex decision tree then my answers are likely to be as follows: Q1=Y, Q2=N, Q3=Y, Q4=Y (because the subsequent step is cooking), i.e. YNYY and this results to NO CCP. Having said this I notice that Q2 does not include the term to prevent (as it is mentioned in the definition of a CCP).

 

Now, is cold storage a CCP or not and why?

 

Thanks in advance for any justified professional opinion. Is there a mistake in my thinking process?

[Ioannisg2364]

In my opinion, the Codex Decision Tree is responsible for more ineffective and cumbersome food safety systems than imaginable. It is a tool which may be used but it is not mandatory in Codex or any of the main food safety standards.

 

What is normally mandatory is the risk assessment itself, ie how likely is it that a hazard will occur and if so how serious is it. There are numerous systems sround to do this.

 

The only question from the Decision Tree which serves much purpose is the subsequent step.

 

HACCP courses, be they for food or packaging still seem to spend half the time going through the Decision Tree questions.

 

Students come out of these courses bewildered when back in their own environment. I have seen countless systems where the risk assessment shows that all potential hazards have zero or minimal risk but they are still all put through the Decision Tree. If something is not a risk, it can't be critical.

 

As said earlier, do a good risk assessment, if there is a high risk and there is no subsequent step call that a CCP. 

 

If a BRC auditor penalises you for not using the Decision Tree challenge it.

Interesting discussion, improves understanding.

 

So, if I understand this right, after Hazard identification--> risk assessment (probability + severity)--> determination of significant risks--> significant risks that cannot be controlled (i.e. prevented, eliminated or reduced to acceptable levels) at a subsequent process step(s) may be considered to relate to CCPs and the rest to be treated with OPRPs?

 

Is this correct?

[Scampi]

I'm a decision tree lover!!

 

Of course you need to apply it to every step! Sheesh lol   

 

I detest risk assessments, they are way too subjective 

 

decision tree, yes or no, black or white.      are their PRPs that reduce/eliminate the hazard to an acceptable level yes or no....yes?? Beautiful, list them and move on       

 

Often, there is more than one control for each hazard, beautiful, add them all in!  

[Ioannisg2364]

Hello Scampi,

 

Does the 1st Question of the Codex Tree refer to PRPs or to measures to control particular hazards at each process step?

Does the 2nd Question of the Codex Tree refer to PRPs or to the step (under examination) in the process?

 

Sorry if I am little bit confused :)

I'm a decision tree lover!!

 

Of course you need to apply it to every step! Sheesh lol   

 

I detest risk assessments, they are way too subjective 

 

decision tree, yes or no, black or white.      are their PRPs that reduce/eliminate the hazard to an acceptable level yes or no....yes?? Beautiful, list them and move on       

 

Often, there is more than one control for each hazard, beautiful, add them all in!  

[Scampi]

  You take a single step or ingredient and apply it horizontally across all questions and repeat for each step AND ingredient

 

So, let's say the step is mixing, you have BCP hazards, how are the controlled, what are the PRP's?  For "P", it may be something like pre op inspections and/or preventative maintenance .       You may end up with multiple PRPs controlling the hazards. 

 

That's why I prefer a decision tree----you can see if you've really controlled the hazards or not

 

https://inspection.c...2/1525869759693

 

This is a link to the CFIA decision tree (called the Form 8)   it may offer a better visual and explanation

[Ioannisg2364]

Thank you for the response but I am still a bit confused.

 

I thought (and still do) that PRPs are not related to particular product(s) or ingredient(s) or food fasety risk(s) (i.e. BCP) or processes but they are considered basic conditions applied to the food organization.

 

PRPs are not designed (by definition) to eliminate a specific hazard or reduce it to an acceptable limit. They are actually not expected to be considered in the decision tree unless OPRPs are related to specific hazards and process steps if not CCPs.

 

When this is the case, then we rather have control measures at CCPs but not PRPs.

 

Am I missing something?

 

 

  You take a single step or ingredient and apply it horizontally across all questions and repeat for each step AND ingredient

 

So, let's say the step is mixing, you have BCP hazards, how are the controlled, what are the PRP's?  For "P", it may be something like pre op inspections and/or preventative maintenance .       You may end up with multiple PRPs controlling the hazards. 

 

That's why I prefer a decision tree----you can see if you've really controlled the hazards or not

 

https://inspection.c...2/1525869759693

 

This is a link to the CFIA decision tree (called the Form 8)   it may offer a better visual and explanation

Edited by Ioannisg2364, 07 May 2021 - 12:19 PM.

[Scampi]

I think you're over thinking this

 

PRPs are mandatory requirements, yes, but they are there BECAUSE THEY CONTROL HAZARDS, so if you exclude them it makes them moot.  

 

Once you work through EVERY STEP AND INGREDIENT in your facility, and insert your programs that control hazards, where you DO NOT have a hazard satisfactorily controlled, then you see where a CCP or additional controls need to be applied

 

I've attached an example

Attached Files

•  form 8 example.docx   13.57KB   37 downloads

[Ioannisg2364]

OK, I think I see your point. Thanks for clarifying.

 

However, I get the impression (from your response) that you do not conduct any risk assessment in order to determine significant and not significant risks prior to using the decision tree. Is this correct? Are you using the decsion tree for sort of 'risk assessment'?

 

Personally, I am inclined to conduct a risk assesment first (probability X severity) and the result thereof are significant risks that are not controlled (or not likely to be controlled) to an acceptable (risk)  level by PRPs only.

 

The significant risks (per process step) are then taken into the decision tree in order to determine CCPs and OPRPs. And this is where my 'labyrinth' starts.

 

For example in a (simplified) process like: receiving of raw materials--> cold storage--> preparation (washing, mixing etc.) -->cooking-->distribution, I always considered cold storage as a CCP for B and eventually also for A (allergens). Cooking  was my next CCP in the process.

 

However by playing around with the codex decision tree I cannot really justify why cold storage for B is a CCP (which is also according to relevant literature).

 

I am confused.....

I think you're over thinking this

 

PRPs are mandatory requirements, yes, but they are there BECAUSE THEY CONTROL HAZARDS, so if you exclude them it makes them moot.  

 

Once you work through EVERY STEP AND INGREDIENT in your facility, and insert your programs that control hazards, where you DO NOT have a hazard satisfactorily controlled, then you see where a CCP or additional controls need to be applied

 

I've attached an example

[Scampi]

Whoa, that's why i don't like RAs

 

Taken out of context storage may seem "risky" but you've got controls in place already  same goes with allergens..........by making them a CCP, you're basically saying you have zero control in your facility, so you're defaulting to CCP to control the hazard

 

I don't do RAs unless I want something out of the norm.  I use forms 1-10 codex style along with a hearty PRP plan

 

 

It really sounds to me like you need some back to basics formal HACCP training...........it is a process, and you cannot take 1 thing out of the whole plan and run with it, it's like a spider web...........change one thing ok sounds great,         oh sh*t, i did't realize all these other things would happen too..Its inter connected

 

RA allow you to look at 1 small thing-with blinders on

[Charles.C]

Sorry but I am also a little confused when determining whether for example cold storage is a CCP (for pathogens) or not (by the way, a subsequent step in the process flow diagram is cooking).

 

If I do not use the codex decision tree  and I only consider the definition of a CCP (i.e. a critical control point is defined as a step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level) for my decision, then cold storage is a CCP because cold storage aims to prevent a food safety hazard from reaching unacceptable levels.

 

If, however, I use the codex decision tree then my answers are likely to be as follows: Q1=Y, Q2=N, Q3=Y, Q4=Y (because the subsequent step is cooking), i.e. YNYY and this results to NO CCP. Having said this I notice that Q2 does not include the term to prevent (as it is mentioned in the definition of a CCP).

 

Now, is cold storage a CCP or not and why?

 

Thanks in advance for any justified professional opinion. Is there a mistake in my thinking process?

 

As you can see haccp is subjective. Sometimes more of an Art than a Science.

 

Are you aware that the latest version of Codex Hygiene no longer includes the Tree ?.

 

If you simply reference the standard iso22002-1 for yr choice of PRPs, It will resolve the meanderings in posts 12-20.

 

I also noticed this CFIA solution using analogous logic to above -

 

 HACCP COLD STORAGE FACILITY.pdf   258.22KB   34 downloads

 

 

[Ioannisg2364]

Hi Charles,

 

Thanks for your feedback and the attached pdf.

 

After all this conversation above and after having read several HACCP examples in the Web in the past and recently, I will finally agree that HACCP is subjective rather than objective.

 

At the end of the day, it is about what one wants to prevent and why. So, if one does not (fully) trust (for whatever reason) the effectiveness of PRPs it is one's choice to work with more (rather than with less) significant risks (after the RA) and define more (rather than less) CCPs where critical limits exist and real time monitoring is possible.

 

Having said this, I guess I will insist on considering cold storage a CCP (e.g. for B) for the following reasons:

• There is a critical limit regarding the temperature (for example < 5 oC) and this is the beginning of the danger zone...
• Cold storage temperature can (and should) be monitored in real time and if any deviation occurs, then immediate corrections (and last but not least appropriate corrective actions) are required.
• The CCP definition includes also the word 'prevention' of a hazard, which is a fact in cold storage (the growth of pathogens is becoming very slow, in a way it is prevented, provided that the critical limit is not exceeded, otherwise ---> danger zone!)
• Now, although not a microbiologist myself, I do not want to play guess games with pathogens and their toxins or spores if cold storage is not controlled properly and strictly in real time and the danger zone is reached..... thus, even cooking is likely not to be effective if cooking temperature is only 75oC.....Pathogens and their toxins and spores cannot be monitored and measured in realtime (not yet, unfortunately). One more reason why I consider cold storage a CCP.

It is, finally, a choice isn't it?

 

So, I do not want to rely anymore (at least not fully) on any decision tree which (obviously) does not include all parameters that can appear in the real world.

 

Thanks for your response. I find this forum really great. A lot to discuss and to learn from.

 

PS: Thanks for suggesting ISO 22002-1. I do currently have ISO 22002-2. I will also obtain ISO 22002-1 sooner or later.

[Charles.C]

Hi Charles,

 

Thanks for your feedback and the attached pdf.

 

After all this conversation above and after having read several HACCP examples in the Web in the past and recently, I will finally agree that HACCP is subjective rather than objective.

 

At the end of the day, it is about what one wants to prevent and why. So, if one does not (fully) trust (for whatever reason) the effectiveness of PRPs it is one's choice to work with more (rather than with less) significant risks (after the RA) and define more (rather than less) CCPs where critical limits exist and real time monitoring is possible.

 

Having said this, I guess I will insist on considering cold storage a CCP (e.g. for B) for the following reasons:

• There is a critical limit regarding the temperature (for example < 5 oC) and this is the beginning of the danger zone...
• Cold storage temperature can (and should) be monitored in real time and if any deviation occurs, then immediate corrections (and last but not least appropriate corrective actions) are required.
• The CCP definition includes also the word 'prevention' of a hazard, which is a fact in cold storage (the growth of pathogens is becoming very slow, in a way it is prevented, provided that the critical limit is not exceeded, otherwise ---> danger zone!)
• Now, although not a microbiologist myself, I do not want to play guess games with pathogens and their toxins or spores if cold storage is not controlled properly and strictly in real time and the danger zone is reached..... thus, even cooking is likely not to be effective if cooking temperature is only 75oC.....Pathogens and their toxins and spores cannot be monitored and measured in realtime (not yet, unfortunately). One more reason why I consider cold storage a CCP.

It is, finally, a choice isn't it?

 

So, I do not want to rely anymore (at least not fully) on any decision tree which (obviously) does not include all parameters that can appear in the real world.

 

Thanks for your response. I find this forum really great. A lot to discuss and to learn from.

 

PS: Thanks for suggesting ISO 22002-1. I do currently have ISO 22002-2. I will also obtain ISO 22002-1 sooner or later.

 

Hi loannis,

 

Another factor which has not been discussed here is haccp "politics". If you have a look at older haccp plans, eg ca. 1990 era, you will see that they typically contained a multitude of CCPs, sometimes at virtually every step of a Process (eg, see following pdf). The consequence was a  documentation nightmare.

 

 USDA haccp plan refrigerated foods,1994.pdf   218.41KB   14 downloads

 

Afaik the haccp concept of PRP was (subjectively),"tacitly" expanded so as to ameliorate the multi-CCP situation (ie reduce number of CCPs) around 2000 as can be seen in this list of PRPs in the well-known, foundational haccp system proposed by USFDA in 1997 -

 

Examples of Common Prerequisite Programs

The production of safe food products requires that the HACCP system be built upon a solid foundation of prerequisite programs. Each segment of the food industry must provide the conditions necessary to protect food while it is under their control. This has traditionally been accomplished through the application of cGMPs. These conditions and practices are now considered to be prerequisite to the development and implementation of effective HACCP plans. Prerequisite programs provide the basic environmental and operating conditions that are necessary for the production of safe, wholesome food. Common prerequisite programs may include, but are not limited to:

 

Facilities: The establishment should be located, constructed and maintained according to sanitary design principles. There should be linear product flow and traffic control to minimize cross-contamination from raw to cooked materials.

Supplier Control: Each facility should assure that its suppliers have in place effective GMP and food safety programs. These may be the subject of continuing supplier guarantee and supplier HACCP system verification.

Specifications: There should be written specifications for all ingredients, products, and packaging materials.

Production Equipment: All equipment should be constructed and installed according to sanitary design principles. Preventive maintenance and calibration schedules should be established and documented.

Cleaning and Sanitation: All procedures for cleaning and sanitation of the equipment and the facility should be written and followed. A master sanitation schedule should be in place.

Personal Hygiene: All employees and other persons who enter the manufacturing plant should follow the requirements for personal hygiene.

Training: All employees should receive documented training in personal hygiene, GMP, cleaning and sanitation procedures, personal safety, and their role in the HACCP program.

Chemical Control: Documented procedures must be in place to assure the segregation and proper use of non-food chemicals in the plant. These include cleaning chemicals, fumigants, and pesticides or baits used in or around the plant.

Receiving, Storage and Shipping: All raw materials and products should be stored under sanitary conditions and the proper environmental conditions such as temperature and humidity to assure their safety and wholesomeness

Traceability and Recall: All raw materials and products should be lot-coded and a recall system in place so that rapid and complete traces and recalls can be done when a product retrieval is necessary.

Pest Control: Effective pest control programs should be in place.

Other examples of prerequisite programs might include quality assurance procedures; standard operating procedures for sanitation, processes, product formulations and recipes; glass control; procedures for receiving, storage and shipping; labeling; and employee food and ingredient handling practices.
 

https://www.fda.gov/...tion-guidelines

 

 

The iso22002-X series further delineated/amplified the above in order to permit fssc22000 to be a GFSI-recognized rendition of iso22000.

 

Nonetheless, it is definitely still possible to find modern haccp plans which do retain chilled storage as CCP, eg -

 

 haccp guide,2017.pdf   529.37KB   28 downloads

 

The FSMA approach afaik avoids using trees. An analogous methodology is IMO excellently illustrated by the detailed haccp plans on this website -

https://meathaccp.wisc.edu/

 

Many haccp tree users now implement later modifcations of the original Codex tree, eg Campden tree. This inserts a simple PRP query step prior to Codex tree which can be a great time saver.

 

 Campden CCP tree.pdf   62.46KB   34 downloads

 

PS - referring back to yr last post, in the context of user's choice, it now seems an established approach in a risk assessment to concentrate on the likelihood of occurrence of the actual hazard > severity > mediation by any subsequent step > consumer risk. TBH when you initially mentioned "cold storage" I interpreted this as deep-frozen, -18degC storage, not chilled refrigeration at ca.2-5 degC.

For deep-frozen, I cannot recall ever seeing an instance in routine use of an actual hazard (ie micro.growth) occurring (after all the operational safety tolerance is enormous). And, from what I have so far seen in the Literature, the chilled scenario is not that much different in practice unless perhaps substantial storage times/shelf lives are targeted). So, if a low likelihood is historically-supported, the majority of risk matrices will IMO indicate a non-significant hazard.

Nonetheless I respect any decision to implement a CCP due to a particular situation/hazard. Ultimately, it's your haccp of course.