12 replies to this topic

[EBB12]

Hello! I have a question that I am hoping someone can help me with.

 

I am revising our HACCP plan and am stuck on the CCP step, as I am fairly new to this. We use a hydro-cooler for one commodity only, and it is just to cool the product of field heat. In reviewing previous audits of our facility, I have learned that no CCP's were determined because we are strictly a harvesting and packing facility, and there are no processing steps involved. However with all the research and articles I have found, it seems to me that the wash step should be a CCP, even if it is just being done to cool product? My other concern is that previously we have had cooler/cold storage audits, and from here on we will be having packinghouse audits, which I believe changes the requirements. Any help/resources would be greatly appreciated!!

[Dr.Khan]

Hi EBB12

 

First of all  you need to determine why you would like to make the cooling step as CCP?  the simple test is that after the cooling step you pack the product at the room temperature or it is packed at the modified cooler temperature and deliver to the customer under temperature control conditions below 5 ⁰C. If the product can be stored and delivered at the room temperature then you do not need to classify this step as CCP, however, if the product after cooling kept under temperature control conditions and deliver to the customer under such condition then it is CCP and you must ensure to keep the monitoring temperature record  not only of the process step but also logistic steps (storage temperature and deliver temperature).

 

The change in audit scope means that auditor will be not only looking at the CCP steps data in the manufacturing but also will audit storage and transport record if you deliver any product which is a high risk product.

 

Kind regards

Dr Humaid khan

MD

Halal International Services

Beverly HillS NSW Australia

[Charles.C]

Hi EBB,

 

Yr initial requirement is to find a specific BCPA  safety-related hazard which is essential to be controlled by the hydro-cooler.

 

Regarding Packinghouse Operations, I suggest you do a search here for Primus who specialise in auditing this area and whose guidelines are posted on this Forum (somewhere).

[EBB12]

I dont believe that the cooling step should be a CCP. We use well water that is tested monthly, and the tank is drained and cleaned at the end of each day. To me, that justifies that it does not need to be a CCP. Where i question that however, is the fact that we do include a free chlorine test before any product is added to the tank. I forgot to mention that the product being hydro-cooled in sweet corn, with husk on. So there should not be any dirt or organic matter that is getting recirculated in the water, we just add the chlorine as a precaution. According to FSMA, you are not required to add any antimicrobial to wash water, but since we do, should that step be a CCP?

[Scampi]

As soon as you treat the water, you must also add monitoring to the chemical level in said water.....chlorine would not be anyone's first choice for a lot of reasons.(not stable, toxic, hard on equipment, not effective)  Why would you be treating the water?

 

However, it does not automatically make it a CCP.....you need to perform a risk assessment to determine if it is

 

an example of a CFIA hazard analysis---the FSEP manual is available on line and may be of some help

 

3.2.6 Determination of CCP and other control measures (HACCP Principle 2)

(Form 8)

For each hazard identified, an analysis shall be conducted to determine:

• The likely occurrence of the hazard;

• The severity of possible adverse health effect associated with the hazard;

• If the identified hazard is controlled by prerequisite programs;

• If the identified hazard is partially controlled by a process control;

• If the identified hazard is controlled at a CCP;

• If the identified hazard is out of the establishment’s control.

The establishment shall use Form 8 or equivalent to document the hazard analysis as

well as the prerequisite programs, the process controls (PC) and the CCP selected to

control the food safety hazards identified.

All PC(s) and CCP(s) associated with the processing steps shall be indicated beside the

corresponding step in form 3 or equivalent.

NOTE: To facilitate verification by CFIA representatives, FSEP recommends

establishments number the CCP sequentially and identify the hazard(s) each controls

i.e., B for biological, C for chemical, P for physical hazards. (e.g., CCP1-BCP, CCP2-B).

[Charles.C]

IMEX hydrocoolers often do represent a CCP but only when being used as a washing stage, not a cooling one. The reason is that the chlorine controls the risk of cross-contamination via the water to fresh incoming material.

[CMHeywood]

CCP = last point in the process chain where contamination can be removed or reduced to acceptable levels.

 

If that definition is correct, then your cooling process is temperature control.  If that is meant to control contamination (control microbio growth) then it could be a CCP.  If temperature adjustment only, then it may not be a CCP.

 

A washing process to remove dirt and other contamination would be a CCP.

 

Controlling the cleanliness of your water supply would be an important part of your risk assessment.

[MusselsGalore]

It would seem to me that there can be a risk for biological hazard with the addition of water to your process wether cooling or washing.  The first CCP should be wether or not the water is from a certified potable source and that source and its conveyance is free from contamination.

[Charles.C]

Hi Ebb,

 

This is what i was talking about in Post 6. There is another more detailed publication available but unable to find yet.

The critical limit is typically the level of 'sanitizer" maintained in the hydrocooler.

 

 food safety - washwater sanitizers.pdf   317.71KB   98 downloads

 

 

[Charles.C]

addendum

 

Hi Ebb,

 

I recommend you have a look at this thread which has some interesting discussion on topics related this thread.

http://www.ifsqn.com...removing-a-ccp/

 

I also recommend you to have a look at the (2015) article URL-linked in Post 8 (still working at this time).

 

PS - the attachment in this Post is also quite interesting -

http://www.ifsqn.com...ccp/#entry92692

[kamau]

According to BRC vs7,A ccp is a step at which control can be applied and is essential to prevent or eliminate a food or product safety hazard to an acceptable level.

Which hazards are likely to be introduced at the process step of hydro cooling?

Analyse the hazards and determine the severity of each.

You said the hydro cooling is just to cool the product of field heat.Does the product come into contact with the cooling water?

[EBB12]

According to BRC vs7,A ccp is a step at which control can be applied and is essential to prevent or eliminate a food or product safety hazard to an acceptable level.

Which hazards are likely to be introduced at the process step of hydro cooling?

Analyse the hazards and determine the severity of each.

You said the hydro cooling is just to cool the product of field heat.Does the product come into contact with the cooling water?

 

Yes, the product does come into contact with the water, but the water and ice used are tested monthly. A sanitizer is added as a triple precaution, but there is no specific food safety hazard that is essential to being controlled. Sanitation level is checked hourly while the machine is in use.

[Charles.C]

According to BRC vs7,A ccp is a step at which control can be applied and is essential to prevent or eliminate a food or product safety hazard to an acceptable level.

Which hazards are likely to be introduced at the process step of hydro cooling?

Analyse the hazards and determine the severity of each.

You said the hydro cooling is just to cool the product of field heat.Does the product come into contact with the cooling water?

 

Hi kamau,

 

I suggest you read the materials linked in Post 10. for example -

 

Another commonly accepted definition of a CCP is a step in a process where the loss of control results in an unacceptable level of risk. Clearly, water-processes that commingle products or that utilize circulated water meet this definition.

(counter arguments relate to interpretation of "validation" /  "prevent" /  "acceptable level" / "killing step")

 

@Ebb - afaik the hydrocooler is usually a packinghouse  procedure. I'm unclear as to its exact usage/location in yr OP.

 

Additionally to the (hydrocooler) reference in Post 8, the general washwater stage / probable hazards / control are detailed/analysed in this recent publication -

 

 Control of Cross-Contamination during Washing Fresh-Cut Leafy Vegetables (2017).pdf   738.28KB   63 downloads

 

There is no doubt that opinions vary as to the haccp plan appropriate for packinghouses. Just as a little background to haccp / fresh produce washing -

 

(1) USFDA avoid using CCPs

(2) CFIA use CCPs

(3) afaik the US Fresh Produce Industry use CCPs

(4) HARPC - exemption ??.

 

It's a much discussed topic.