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No CCPs in a Haccp Plan - Can This Be Possible?


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Poll: How many CCP's in your HACCP System? (554 member(s) have cast votes)

How many CCP's in your HACCP System?

  1. 0 (Zero) (138 votes [24.86%])

    Percentage of vote: 24.86%

  2. 1-2 (225 votes [40.54%])

    Percentage of vote: 40.54%

  3. 3-4 (116 votes [20.90%])

    Percentage of vote: 20.90%

  4. 5-6 (50 votes [9.01%])

    Percentage of vote: 9.01%

  5. 7-8 (10 votes [1.80%])

    Percentage of vote: 1.80%

  6. 9-10 (6 votes [1.08%])

    Percentage of vote: 1.08%

  7. More than 10 (10 votes [1.80%])

    Percentage of vote: 1.80%

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#26 Esther

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Posted 30 October 2005 - 11:38 AM

Looking at the objectives for implementing a Haccp System, is it possible to have zero CCPs in a Haccp Plan.

My answer is yes....but many would disagree with me. My logic is based on deliberately instituting intervention steps at all steps or a particular step of the process.

Feel free to comment.

Charles Chew



Hello

Short time ago I read something regarding a legislation coming on january 2006. The article was address mainly to the official vets making inspections. If I am not mistaken I understood that It would not be neccesary to implement a HACCP system for some kind of food establisments, it would be enough for them just to follow a good hygiene practices guide.

So. As you, I think they mean that it is possible to have 0 CPP, therefore they will not demand a HACCP plan to those establisments


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#27 Charles Chew

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Posted 30 October 2005 - 02:00 PM

Esther,

So. As you, I think they mean that it is possible to have 0 CPP, therefore they will not demand a HACCP plan to those establisments



Not really! IMO, what the article probably means (similar to the EU DIrective No....whatever) regardless of the position, is that you still need to conduct the CCP Determination Decision Tree to verify your decision - 0 CCP

You still need to have the Hazard Control Table where the risk assessment is perfomed to justify your assessment and the measures you are applying to protect your process / i. product / e. product thru' SOP / SSOP etc as support elements.

IMO - a HACCP Plan still needs to be in place but the decision is 0 CCP.......its a precursor to the system.

Charles Chew
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#28 Franco

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Posted 31 October 2005 - 07:55 AM

Short time ago I read something regarding a legislation coming on january 2006.


Hi Esther,

this thread about Hygiene package may help

SDF hygiene package thread

Regards. Franco
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#29 Charles Chew

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Posted 02 November 2005 - 10:14 AM

Absolutely possible - we are in fact controlling a process segment which we have identified as no viable critical control points for control measure but instead through GHP / GMP.

To be honest - I would rather control a CCP than none at all. At least the auditor would focus on the CCP rather than the entire process including the emvironment. :doh:


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#30 yorkshire

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Posted 02 November 2005 - 12:10 PM

To be honest - I would rather control a CCP than none at all. At least the auditor would focus on the CCP rather than the entire process including the emvironment.



Good point Charles.
An auditor will find it hard to believe that there are no CCPs and may dig deep to find any weakness in the system.

Now I think about it, that is what an auditor should be doing anyway. :dunno:
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#31 joyfranks

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Posted 18 November 2005 - 12:07 AM

Hi all,

Great discussion on CCP's and yes I believe that some companies do not have any. As part of ISO22000 we have had to produce a questionaire to assess the risk level of companies before audit days can be calculated, higher risk meaning more audit time. If anyone is interested I could post the questionaire to see if what I have put together actually does calculate the correct risks. One of the questions is how many CCP's, logic being the more CCP's the higher the risk. Please let me know.

Joy


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#32 Simon

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Posted 21 November 2005 - 10:24 PM

Hi all,
If anyone is interested I could post the questionaire to see if what I have put together actually does calculate the correct risks. One of the questions is how many CCP's, logic being the more CCP's the higher the risk. Please let me know.


I'm interested please go ahead and post it Joy.

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Simon
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#33 Simon

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Posted 14 February 2006 - 08:33 PM

Hi all,
If anyone is interested I could post the questionaire to see if what I have put together actually does calculate the correct risks. One of the questions is how many CCP's, logic being the more CCP's the higher the risk. Please let me know.


BUMP.

Can you still post this Joy?

Simon
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#34 Gaskit

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Posted 11 December 2006 - 03:32 PM

Hi all, Just to re-vitalise this interesting subject has anyone got any comments on the attached documents (they both used to be CCPs, as wrote by a FSMS consultant when we initially commenced BRC / IoP certification).

Thanks and regards,

Steve

Attached Files


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#35 MartLgn

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Posted 11 December 2006 - 05:09 PM

Hi all, Just to re-vitalise this interesting subject has anyone got any comments on the attached documents (they both used to be CCPs, as wrote by a FSMS consultant when we initially commenced BRC / IoP certification).

Thanks and regards,

Steve


Steve.

Are you saying that your consultant originally had these two processes down as CCP's ?

Both of your CCP determinations are well structured and the use of existing controls seems entirely reasonable for the steps of material procurement and receipt, I cannot imagine how supplier management could be a CCP in any organisation which has controls in place such as refered to in your assesment. I can imagine how materials intake could result in a CCP in certain circumstances but your assesment shows that your GMP systems already control any such risks. Nice and straightforward just the way we wish it could always be !
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#36 Gaskit

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Posted 12 December 2006 - 09:20 AM

Steve.

Are you saying that your consultant originally had these two processes down as CCP's ?

Both of your CCP determinations are well structured and the use of existing controls seems entirely reasonable for the steps of material procurement and receipt, I cannot imagine how supplier management could be a CCP in any organisation which has controls in place such as refered to in your assesment. I can imagine how materials intake could result in a CCP in certain circumstances but your assesment shows that your GMP systems already control any such risks. Nice and straightforward just the way we wish it could always be !


Dear Mart, Thanks for your kind words, I attach the original documents generated by the FSMS consultant and have stood 4 BRC audits to date with no non-conformances, it was this thread that enlightened me to the real controls and hazards.

Kind regards,

Steve

Attached Files


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#37 Charles.C

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Posted 12 December 2006 - 06:56 PM

Dear Gaskit,

Interesting documents. Have a few comments.

Perhaps I'm misunderstanding the thrust of yr post but I don't quite see how one concludes these functions as CCPs without analyzing the risk factors (Perhaps this was somewhere else?).

I similarly failed to understand the meaning in the packaging4 Rotacut dwl where the significance is categorized into - severe, likelihood (likely?) and significant (less likely?). Categorised how ??

My auditors would never let me escape with generalizations such as "all hazards", "microbiological contamination" (eg would be asked typical species, frequency of occurrence (= f[validity of hazard.]),etc"

Nonetheless, I admired the brevity, especially if the auditors are happy with it too. :biggrin:

Rgds / Charles.C


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#38 Gaskit

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Posted 14 December 2006 - 09:09 AM

Dear Gaskit,

Interesting documents. Have a few comments.

Perhaps I'm misunderstanding the thrust of yr post but I don't quite see how one concludes these functions as CCPs without analyzing the risk factors (Perhaps this was somewhere else?).

I similarly failed to understand the meaning in the packaging4 Rotacut dwl where the significance is categorized into - severe, likelihood (likely?) and significant (less likely?). Categorised how ??

My auditors would never let me escape with generalizations such as "all hazards", "microbiological contamination" (eg would be asked typical species, frequency of occurrence (= f[validity of hazard.]),etc"

Nonetheless, I admired the brevity, especially if the auditors are happy with it too. :biggrin:

Rgds / Charles.C


Dear Charles,

Thanks for your kind comments, my auditor comes from a medical background and is quite satisfied with the brevity, notwithstanding it is cardboard we are processing.

Any pointers as to what microbes (specific names) may survive or grow on card would actually be helpfull as I do wish very soon to extend the above taking in all your comments.

Kind regards,

Steve
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#39 Charles.C

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Posted 14 December 2006 - 06:42 PM

Dear Steve,

I must confess that I only encountered plastics / cardboards in a secondary role as a packaging medium. My comparison was more to the primary item in my own case which was typically seafood so that the auditors naturally focused on this item.
I'm sure there are plenty of packaging micro. people on this forum who can answer yr query ( a quick google indicated yeasts, molds and some bacillus genus were common contaminants but am only guessing) .
In fact, in many HACCP food plans in my experience, the risk due to plastic / cardboard is categorized as negligible based on epidemiological statistics etc. I liked to include plastic / cardboard as an incoming CCP for BCP hazards since I favoured the concept of 'intuitive' prioritization which I used to automatically define all source materials as CCPs. This was a bit alien to auditors (inon - routine approach) but one could usually validate it after a bit of literature scrambling (plus retelling some personally experienced packaging disasters) which usually satisfied the auditor. In such cases I admit I used a semi-generic type of evasion to detail the hazard similar to this link -

http://www.inspectio...a/pizza6e.shtml
and
http://www.inspectio.../pizza10e.shtml
( I supplied a bit more detail to define an acceptable material, eg FDA standard number)

Rgds / Charles.C


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#40 Gaskit

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Posted 15 December 2006 - 08:42 AM

Dear Steve,

I must confess that I only encountered plastics / cardboards in a secondary role as a packaging medium. My comparison was more to the primary item in my own case which was typically seafood so that the auditors naturally focused on this item.
I'm sure there are plenty of packaging micro. people on this forum who can answer yr query ( a quick google indicated yeasts, molds and some bacillus genus were common contaminants but am only guessing) .
In fact, in many HACCP food plans in my experience, the risk due to plastic / cardboard is categorized as negligible based on epidemiological statistics etc. I liked to include plastic / cardboard as an incoming CCP for BCP hazards since I favoured the concept of 'intuitive' prioritization which I used to automatically define all source materials as CCPs. This was a bit alien to auditors (inon - routine approach) but one could usually validate it after a bit of literature scrambling (plus retelling some personally experienced packaging disasters) which usually satisfied the auditor. In such cases I admit I used a semi-generic type of evasion to detail the hazard similar to this link -

http://www.inspectio...a/pizza6e.shtml
and
http://www.inspectio.../pizza10e.shtml
( I supplied a bit more detail to define an acceptable material, eg FDA standard number)

Rgds / Charles.C


Dear Charles,

As always your help is indispensable, thank you for your time and patience.

I am now going to work on production for the remainder of the year (busy period for us), so may I wish you and all other members of saferpak a very merry christmas and a glorious new year.

Best regards,

Steve :x_biggrin:
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#41 Esther

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Posted 01 January 2007 - 07:54 PM

Looking at the objectives for implementing a Haccp System, is it possible to have zero CCPs in a Haccp Plan.

My answer is yes....but many would disagree with me. My logic is based on deliberately instituting intervention steps at all steps or a particular step of the process.

Feel free to comment.

Charles Chew



Hello Charles Chew and Simon

I am sorry for being off for so long, I was very busy with a BRC/ IFS certification which finally has been quite successful.

Totally agree, it is possible to have No CPP in a food manufacturing process.

I hope to come back to the forum more frequently.

HAPPY NEW YEAR 2007 !!

Sincerely
Esther
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#42 Simon

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Posted 01 January 2007 - 09:48 PM

I am sorry for being off for so long, I was very busy with a BRC/ IFS certification which finally has been quite successful.

Hey no need to apologise Esther, the forums are always here to give you a warm welcome. I'm happy you have been successful in your cetification work; here's to more success in 2007. Happy New year!

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#43 Charles Chew

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Posted 02 January 2007 - 02:06 AM

Totally agree, it is possible to have No CPP in a food manufacturing process.


Dear Esther

Welcome back and a Happy New Year to ALL

While it is possible to have no CCP in a Food Safety Program (specific process or otherwise) the inherent risk of doing this is that all the SOPs and SSOPs (HACCP) or OPRPs (ISO 22000) immediately become the control measures of significant concern as the system now rely on these operational PRPs to manage potential hazards.

Its quite a daunting task to launch such an approach to managng risks. You may want to reconsider.

Warmest regards and Greetings
Charles Chew
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#44 Charles.C

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Posted 02 January 2007 - 10:12 AM

Dear Charles Chew,

I conceptually agree with you .

I would myself intuitively suspect that any food system which claims to have no CCPs has overlooked or underestimated the significance of some parameter. Of course, it is also necessary to specify / quantitate the threshholds when something becomes significant or otherwise. This is not always so simple as it looks IMO even if such may be validatable from the literature.
Admittedly, such an opinion may not be too well acceptable from a regulatory aspect where black / white is the preferred situation.

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#45 KellyB

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Posted 02 January 2007 - 12:35 PM

Let me just give you an example of 0 CCPs.
In the company I work we have a HACCP Plan with 5 CCPs. Also 2 years ago we opened a mini-market which buys products only and directly from the company. We proved success in exercising GMP in the store so the auditors accepted 0 CCPs in the HACCP plan of the store.
I hope this contributed to your research Charles.
Regards
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#46 Charles Chew

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Posted 02 January 2007 - 02:41 PM

. We proved success in exercising GMP in the store so the auditors accepted 0 CCPs in the HACCP plan of the store. I hope this contributed to your research Charles.


Hi Kelly,

Mini markets are distribution centres for a wide variety of foods. Would I be right to assume that your Company's mini-market also sells frozen and chilled products. If so, would you be able to verify that the safe quality characteristics of these frozen/chiiled goods are not compromised in the event there is a break down in your freezer / chiller or perhaps the monitoring devices being out of range.

Having zero CCPs is not really the problem. However it must be a daunting task to demonstrate objective evidences of effectiveness vis-a-vis your systems verification and validation unless ALL your CPs or OPRPs are working in combinations to achieve the intended objectives.

Intersting indeed.

Warm regards
Charles Chew
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#47 Charles.C

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Posted 02 January 2007 - 03:45 PM

Dear Kelly,

Charles Chew has said it for me.
I must confess that when I used to inspect factories, I always entered with the belief that I would be able to find at least one serious fault (from a HACCP viewpoint). If I failed it meant that I hadn't looked closely enough or the smokescreen put up was too good on the occasion. Not that I necessarily took punitive action but more a matter of personal satisfaction.
I would keep yr present auditors, they're doing a good job for you! :biggrin:

Rgds / Charles.C


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#48 KellyB

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Posted 03 January 2007 - 08:37 AM

Dear Charles Chew/Charles C.
No frozen/chilled products are sold from the mini market yet.
At the "mother" company, all temperatures/humidity are controlled/monitored through real-time computer program and they all give alarm (in case of a problem) within 30 seconds either to my boss/my computer (when at work) or to his/my mobile phone (when at home/away). I just suppose that 0 ccp's were needed for the mini-market, not because the auditors just did not notice (in fact they are VERY strict, we had a long discussion with them about this before we convinced them). It's but because the mother company does it all (for instance we monitor when the products expire and we give the store a command to send them back to us for refusal). Needless to say that we don't do the same with all our customers :lol:
But soon the store will be dealing with frozen/chilled products also, so things will change. By that time we will switch from HACCP to ISO 22k, I promise to keep you auditors updated for the changes!
Rgds/KellyB.


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#49 Charles.C

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Posted 03 January 2007 - 10:24 AM

Dear Kelly,

The products are relevant as you say.
As per Charles Chew, you must have had some interesting validation discussions. The manouevre of grouping "basic" GMP-type hazards into a preliminary HACCP requirement may have some relevance also.

Regardless, it is my hypothesis that most auditors will be happier if you can show them a minimum of 1 CCP since otherwise you end up with a whole load of nice theory (I hope!) which eventually produces a totally clean slate. If only the world were so compliant (excepting for the auditing profession of course).

I used to have a line in my appraisal form such as "How many CCPs" with a side-note to myself, "If zero, watch it!, don't forget to look all round the perimeter in the lunch break."

Perhaps the other auditors here will not agree ?? - Please comment Cazyx (the forum's toughest auditor ? ) :welcome:

Rgds / Charles.C


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#50 KellyB

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Posted 03 January 2007 - 08:19 PM

Dear Charles.C & Charles Chew,
While these discussions were taking place, I should rather be playing lotto... to cut a long story short today's decision at the company is that the store will be selling frozen products as soon as possible because custormers requirements increase. Needless to say that I'm already working :crybaby: to revise the HACCP plan until we'll be ready for the ISO 22k.
Regards...
Kelly B.


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