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CCP Nightmare

labelling ccp sealing

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#1 Andy_Yellows

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Posted 07 September 2017 - 09:25 AM

Hi all,

 

Having a bit of a stinker with some potential CCPs and am in the middle of re-writing our HACCP docs at the minute. I've heard contrasting view on CCPs- some saying that these should be kept to a minimum and only implemented at CRITICAL stages and others saying that once the product has been made (in this example fruit juice that has been machine squeezed) every step afterwards is critical as there are no further steps to prevent/eliminate hazards. So the filling of the bottle through a sieve, capping, labelling, palletising and cold storage is all critical. This just doesn't sound right to me, although following the 4-question decision tree it kind of makes sense for the sieving, capping, labelling and cold storage to be seen as CCPs.

 

Hope this makes sense and that somebody can clarify the situation. It just doesn't make sense to have so many CCPs I don't think.

 

Many thanks,

Andy


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#2 BrummyJim

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Posted 07 September 2017 - 10:34 AM

Hi Andy,

 

Other than cross contamination, which should be resolved by GMP etc, you're probably looking at foreign bodies and micro as your hazards. Thus filtering and pasteurisation (and possibly washing the fruit) are likely to be your CCPs. Once you're sealed there's less to worry about. If the product is temperature critical, then cooling and chiller temp should be considered, but the chiller temperature will probably not be a CCP.


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#3 Gerard H.

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Posted 07 September 2017 - 11:48 AM

Hi Andy,

 

In addition to the earlier answer, there are a few things to consider:

  • Only the food safety Risks are put in the decision tree
  • You need to figure out what the risks are for your product. Risk = a substantial probability that the hazard manifests itself at your consumer. In other words, that your consumer gets ill or injured by your product
  • Make clear what the microbiological risks really are for your product (fruit juice = low pH, high acidity)
  • Consider whether natural toxins (like patulin) are applicable for your product

Indeed, it is not an easy task to rewrite the HACCP docs. Sometimes you need to go back to basics. Good luck!

 

Kind regards,

 

Gerard Heerkens


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#4 Andy_Yellows

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Posted 07 September 2017 - 01:14 PM

Hi Andy,

 

Other than cross contamination, which should be resolved by GMP etc, you're probably looking at foreign bodies and micro as your hazards. Thus filtering and pasteurisation (and possibly washing the fruit) are likely to be your CCPs. Once you're sealed there's less to worry about. If the product is temperature critical, then cooling and chiller temp should be considered, but the chiller temperature will probably not be a CCP.

Hi BrummyJim, I agree that filtering and pasteurisation are the main CCPs. I also agree that there is less to worry about once sealed but my confusion comes about with the actual sealing process itself. Technically that is done to prevent further contamination and loss of control at this stage can put the consumer at risk. Equally with labelling if the product is labelling wrongly (i.e incorrect shelf-life for example) there is potential for the consumer to be at risk. Does that make these processes critical?

 

Hi Andy,

 

In addition to the earlier answer, there are a few things to consider:

  • Only the food safety Risks are put in the decision tree
  • You need to figure out what the risks are for your product. Risk = a substantial probability that the hazard manifests itself at your consumer. In other words, that your consumer gets ill or injured by your product
  • Make clear what the microbiological risks really are for your product (fruit juice = low pH, high acidity)
  • Consider whether natural toxins (like patulin) are applicable for your product

Indeed, it is not an easy task to rewrite the HACCP docs. Sometimes you need to go back to basics. Good luck!

 

Kind regards,

 

Gerard Heerkens

 

 Hi Gerard, thanks for your advice. I may indeed have to strip it right back and start from square one!

 

Regards to both, Andy


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#5 BrummyJim

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Posted 07 September 2017 - 01:45 PM

Hi Andy,

 

I wouldn't consider labeling a CCP, just a production check. It can't influence the safety of the product per se, but it can mis-identify it. As for the sealing process: how do you test that the seal is good? We produce bag-in-box, so we just put a 20kg weight on bags to test the seal. That's not possible with bottles.

 

Test each step against the standard decision tree. Is it the last opportunity to reduce that particular hazard (CCP) or does another step do the job just as well (Control Point)? Also be aware that you need to put in some form of control measurement for it to be a CCP, Below is a HACCP chart from a bottling plant.

 

STEP NO.

PROCESS STEP

STATUS

CRITICAL LIMIT

MONITORING PROCEDURE

CORRECTIVE ACTION

 

RECORD

RESP

8.

 

 

11

Pasteurise

 

 

Fill Bottles

 

 

 

 

 

 

 

 

 

 

 

 

CCP3

 

 

CCP3

 

 

 

 

 

 

 

 

 

 

 

 

Minimum temp 83.9oC.

 

 

Minimum filler temperature 80C

 

 

 

 

 

 

 

 

Record temperature every 15 minutes

 

Record temperature every 15 minutes

 

 

 

 

 

 

 

 

Will automatically recirculate water until temperature rises.

Inform Technical if temperature drops.

 

Pasteuriser log sheet

 

Pasteuriser log sheet

 

 

 

 

 

 

 

 

 

 

 

Filler Operator

 

 

Filler Operator

 

 

 

 

 

 

.

 

 

STEP NO.

PROCESS STEP

STATUS

CRITICAL LIMIT

MONITORING PROCEDURE

CORRECTIVE ACTION

 

RECORD

RESP

15.

Bottle Rinse

QCP

Water jets reach bottom of bottle

 

 

Visual check

Stop line and hold product back to last good check

Pasteruriser sheet

Filler Operator

11.

 

 

 

Fill Bottles

 

QCP

Brix as per the finished product information sheet

Start and hourly throughout run

Segregate product and investigate reason

Finished product sheet

Operator

 

18.

Cap bottles

 

 

 

QCP

Secure cap.

Check at Start and hourly throughout run

Stop and correct machine. Test previously packed product.

Finished product sheet

Operator

20.

Apply code to bottle

QCP

Visual Checks

Check at Start and hourly throughout run

Stop line, correct fault quarantine product

Finished product sheet.

 

Operator

 

25.

Apply labels

 

QCP

Visual Checks

Check at Start and End of Run

Stop line, correct fault, quarantine product

Finished product sheet.

 

Operator

 

27.

Apply code to outer labels

 

CP

Visual Checks

Check at Start and End of Run

Stop line, quarantine product

Finished product sheet.

 

Operator

 


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#6 BrummyJim

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Posted 07 September 2017 - 01:48 PM

Sorry. Formatting completely ****ed

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#7 CMHeywood

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Posted 13 September 2017 - 10:04 PM

A definition that I have seen is that a CCP is the last step where you can reduce or remove contamination.  However process steps after this may expose your product to additional sources of contamination, and I would think it is justified to state another CCP only if you are capable of detecting and removing contamination is the subsequent process.

 

If you cannot reduce or remove contamination at a subsequent process step, then you have no control available.  Thus, probably not a CCP.


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#8 Ryan M.

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Posted 14 September 2017 - 04:23 AM

CCP takes into account the pre-requisite program that are in place and established, as well as, the risk.  So during juice filling / bottling you need to separate out the three hazard types (biological, chemical, foreign material).

 

Foreign material most likely not a CCP as you would have adequate controls in place through your pre-requisite programs and well designed equipment would not contribute as a hazard.

 

Chemical most likely not a CCP as you have your pre-requisites in place.

 

Biological maybe a CCP...depends on what you use to control the hazard.  It is a significant risk, but can be effectively managed and control with pH and temperature.

 

This type of thinking is what you need to apply to the decision tree.  Hope this helps.


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#9 Andy_Yellows

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Posted 15 September 2017 - 12:16 PM

Thanks all for your input. My logic, particularly behind the labelling, is that this step is partially designed to reduce the risk of microbiological contamination as it ensures (in theory) that the product isn't consumed past a certain date, is stored correctly and is prepared correctly. You wouldn't bother labelling anything if it didn't inform consumers of these instructions. So when the question "Is this step specifically designed to eliminate a hazard or reduce it to an acceptable level?" is asked the answer for me is yes. But you could probably make anything a CCP if you look at it hard enough. I'll give it some thought.

 

Thanks,

 

Andy


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#10 Charles.C

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Posted 17 September 2017 - 04:01 PM

Thanks all for your input. My logic, particularly behind the labelling, is that this step is partially designed to reduce the risk of microbiological contamination as it ensures (in theory) that the product isn't consumed past a certain date, is stored correctly and is prepared correctly. You wouldn't bother labelling anything if it didn't inform consumers of these instructions. So when the question "Is this step specifically designed to eliminate a hazard or reduce it to an acceptable level?" is asked the answer for me is yes. But you could probably make anything a CCP if you look at it hard enough. I'll give it some thought.

 

Thanks,

 

Andy

 

Hi Andy,

 

I assume this is not iso-haccp.

BRC ? SQF ?

 

Opinions vary but I suggest you initially think more about Risk Assessment (ie Likelihood/Severity of specific hazard) / Risk Matrices / Control Measures and less about Decision Trees (DTs). Maybe review NACMCF/Codex on haccp.

 

(Maybe try some of the typical question-based methods to assess risks from defined hazards,  eg have you ever known this hazard to occur in yr facility, etc etc)

 

I also suggest to study some typical haccp plans for yr product, eg with respect to Prerequisites.

 

I don't use DTs myself for CCP determination but regarding yr previous post -

 

Is the step specifically designed to eliminate or reduce the likely occurrence of the hazard to an acceptable level?

 

 

This question was initially introduced to handle  process steps that are specifically designed to control specific hazards. (Note that is the step and not the control measure which is being queried).

 

The intent of the question is really as to whether the step itself controls the (specific) hazard .

 

For example, milk pasteurization at 71.7degC for 15 seconds is specifically designed to control vegetative pathogens. In comparison, ambient storage of raw materials is not specifically designed to control hazards such as pest infestation.

 

If you are not sure as to Yes/No for this question, taking the alternative route through the Decision Tree should ultimately give the same (final) answer.

(See haccp textbook by Mortimore et al on this topic).

 

Microbial hazards are typically controlled by elements such as pH and temperature.

Labelling is sometimes used to control a risk due to allergenic ingredients/allergenic contamination.


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Kind Regards,

 

Charles.C


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#11 Andy_Yellows

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Posted 18 September 2017 - 08:34 AM

 

Opinions vary but I suggest you initially think more about Risk Assessment (ie Likelihood/Severity of specific hazard) / Risk Matrices / Control Measures and less about Decision Trees (DTs). Maybe review NACMCF/Codex on haccp.

 

I think you're probably right, I'm not a fan of decision trees myself and would prefer to make matrix-based decisions on CCPs. The reason I went with the DT method was because of the wording in our FS standard (STS Public Sector):

 

"11.1.11 The HACCP team shall, by the application of a decision tree, or such other method applicable to the type of product or production, determine which steps and/or stages are critical to food safety and legality."

 

I'll take on board all advice given and hopefully should get this finished relatively stress-free.

 

Regards,

 

Andy


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#12 Charles.C

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Posted 18 September 2017 - 09:03 AM

Hi Andy,

 

The choice/convenience of CCP method also may have some relevance to the actual process.

 

As per an earlier post, if this is a pasteurization process, the situation is more literature "standardised" (eg Post6) from a risk asssessment /D-tree/CCP POV.  If not, from memory of USA Juice Rules, further hazard items like E.coli O157 may come into play due their potential survival in quite acid environments and the D-tree query under discussion (Post 10)  becomes less "appropriate".

 

Both the above processes have been (haccp) discussed in earlier threads here (somewhere).


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Kind Regards,

 

Charles.C






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