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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? (552 member(s) have cast votes)

How many CCP's in your HACCP System?

  1. 0 (Zero) (138 votes [24.95%])

    Percentage of vote: 24.95%

  2. 1-2 (224 votes [40.51%])

    Percentage of vote: 40.51%

  3. 3-4 (115 votes [20.80%])

    Percentage of vote: 20.80%

  4. 5-6 (50 votes [9.04%])

    Percentage of vote: 9.04%

  5. 7-8 (10 votes [1.81%])

    Percentage of vote: 1.81%

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

    Percentage of vote: 1.08%

  7. More than 10 (10 votes [1.81%])

    Percentage of vote: 1.81%

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#151 RG3

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Posted 11 December 2014 - 08:18 AM

Perhaps the wording in the question is phrased incorrectly but by definition The HACCP Plan = The CCPs of the HACCP Program. Therefore in my opinion the answer is no.

 

You can still have a Hazard Analysis and PRP's with controls in place and have a team and meet annually and have risk assessments but not necessarily have CCP's therefore not have a HACCP Plan.

 

HACCP Program = The written document of the hazard analysis and the CCPs

HACCP System = The documents and result (records) of implementing the HACCP Program


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#152 Snookie

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Posted 11 December 2014 - 05:33 PM

The HACCP plan is far more than the CCP's.  There is risk analysis, product description and so much more.  The plan shows you have done all of the analysis.  That you don't have a CCP says you have everything under control.  I would think the theory would hold true for Quality Plans as well. 


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#153 RMAV

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Posted 12 December 2014 - 11:55 AM

http://www.ifsqn.com...ssible/page-10 CCP as part of the acronym was hashed over briefly in 2011.  I think we could fight over that one. 

 

GMO had a good point in there that's worth repeating: "It's one of those situations that as a rule of thumb, fewer CCPs often indicate a more controlled system and probably a 'better' hazard analysis; BUT, that does not necessarily follow that 0 is the best of all. What is 'best' is what's right for your company and for your process"


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#154 xylough

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Posted 10 March 2015 - 10:45 PM

Hi Charles,

 

I agree with you. When I first encountered a plan with no CCP it puzzled me, but an auditor told me that it was fairly common. He called HACCP plans with no CCP a Food Safety and Quality Systems Plan. Now with the advent of FSMA, the Preventative Control Rule and HARPC, I think there will be more and more plans that will migrate/ transform/evolve away from the CCP mode of thinking to the preventative controls mode.

 

regards,

 

Xylought


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#155 BEACHTEC

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Posted 17 April 2015 - 04:18 PM

Absolutely. It's interesting to note that not having a critical control point (CCP) in a HACCP does NOT prevent you from having CP's; in other words the process brings value and understanding to your analysis, even if you dont find epic problems. No CCP's?  Work on the CP's!

 

Hope this helps...

 


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#156 Charles.C

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Posted 22 April 2015 - 06:14 PM

Absolutely. It's interesting to note that not having a critical control point (CCP) in a HACCP does NOT prevent you from having CP's; in other words the process brings value and understanding to your analysis, even if you dont find epic problems. No CCP's?  Work on the CP's!

 

Hope this helps...

Hi beachtec,

 

IIRC, Codex HACCP guarantees no need to worry about CPs because this terminology is an American (HACCP) Invention (NACMCF).

 

So maybe it's easier to stay with wholly Codex based FS Systems and really minimise yr documentation workload ? :smile:


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#157 tlee

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Posted 24 April 2015 - 05:30 PM

it is possible to have zero CCPS in a HACCP Plan.  It depends on the operational PRPs and the actual product.

 

Example: Depending on the factory and the process, a CSD line maynot have any CCPs.

 

 THis can be because of the physical and chemical characteristics of the product and the technologhy used to bottle it.

 

 

 

Troy


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#158 Charles.C

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Posted 24 April 2015 - 11:27 PM

it is possible to have zero CCPS in a HACCP Plan.  It depends on the operational PRPs and the actual product.

 

Example: Depending on the factory and the process, a CSD line maynot have any CCPs.

 

 THis can be because of the physical and chemical characteristics of the product and the technologhy used to bottle it.

 

 

 

Troy

 

Thks for the input but the acronym defeated me and GG :smile:

 

??

http://www.egcsd.org/menus/


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Charles.C


#159 Plastic Ducky

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Posted 28 April 2015 - 07:37 PM

Simon and all,

 

The Flexible Plastic Packaging Company where I work has 4 CCPs. I find it a bit excessive, but they were somewhat argued into place in the past by SQF auditors. Three are simply based on allergens. One is based on controlling the amounts of chemicals in the inks/solvents/lamination glue to acceptable levels.

 

Allergens in a packaging company? And no I'm not talking about the Snickers Bars in the vending machines (why do they raise such hell about that??) This is an argument that has been made in the past by SOME of the SQF auditors we have had but not all of them. At several points in the flow of production there are opportunities for things to be misrepresented as to their needed allergen declaration.


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#160 Simon

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Posted 28 April 2015 - 07:50 PM

Hello PD, they don't seem sensible or based on any science to me.

 

I would think about changing your audit company.

 

If you wanted to provide more details on each of the CCPs, what they are and how you control them etc. we could discuss them in more detail; maybe in a new topic.

 

Regards,
Simon


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#161 Antores

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Posted 28 April 2015 - 08:26 PM

Yes, You do your Risk Analysis to identify Critical Control Points. That doesn't mean you need to have them. depending of the operation (especially non-processing), you may not find Critical Control Points. NOW.. technically this will be more like a Risk Assessment (more than an Actual HACCP)..

 

With that said, part of your HACCP program in to review the processes and procedures and identify if there are new CCP.. Lets say you don't have one, but then decided to change/add a process or a machine and now you have a CCP.. then you have a complete HACCP..

 

In my case, I like to call my food safety plan RISK BASED, instead of HACCP based, because I do not have CCP..


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#162 Charles.C

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Posted 29 April 2015 - 03:20 PM

In my case, I like to call my food safety plan RISK BASED, instead of HACCP based, because I do not have CCP.

 

.Hi Antores,

 

I'm sure the HACCP Auditors must enjoy meeting you !

 

IMO, it simply comes down to one's (justifiable) definition of a "HACCP Plan". And there are many of them.

 

Some Companies use multiple definitions according to the intended recipient. :smile:


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#163 WACIRU

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Posted 20 May 2015 - 08:07 AM

Amazing topic and poll results.

I have always been of the opinion that zero CCP is a possibility. However, my trainer kept on saying we should have atleast one CCP and that it gives a sense of credibility to the HACCP anllysis to whoever is auditing the system. 

I must agree this is a tough act of balancing and highly subjective.


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#164 Simon

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Posted 20 May 2015 - 11:38 AM

I would argue if a hazard is elevated to a CCP for effect only then the HACCP system is not credible and neither are those who are complicit in the elevation.  Food Safety should always be about science and data.

 

Feeling quite grumpy and intransigent today. :closedeyes:


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#165 Dimitis

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Posted 22 May 2015 - 09:56 AM

Hi all,

 

It really concerns me, if we can be HACCP certified with no CCPs. We have a small packing line, no allergens no metal detectors (our suppliers are HACCP compliant) but its mandatory to be HACCP certified also. I am working on our HACCP plan, but no CCP yet.


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#166 martavm

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Posted 22 May 2015 - 04:31 PM

Hi all,

 

Honestly, I cannot understand why we must have a CCP if we can control the likelihood of introducing hazards with the implementation of OPRP´s (many people do not use this tool). I was working for a company with 6 CCP´S! After reviewing their system I realised they should consider just 2 CCP´s and implement OPRP´s...that´s very helpful and I haven´t seen this method of controlling the hazards in many companies, what do you think about it? I reckon most of people confuse OPRP with CCP...


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#167 JPO

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Posted 22 June 2015 - 07:13 PM

There can be zero CCP's in other lower risk processes such as food packaging manufacture.

Thanks for sharing. :bye:

Regards,
Simon

Our warehousing and distribution business has a HACCP plan (soon to be a HARPC plan :headhurts: ) that has no CCP's.  

 

All our hazards are controlled with our prerequisite programs.  BRC Issue 6 auditors have said  :spoton: for the past 2 years and FSSC 22000 auditors said "yep, looks OK to us" for the 3 years prior to that.


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#168 ladytygrr

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Posted 22 June 2015 - 07:49 PM

Our HACCP plan currently contains zero CCPs. We are an RTE food processing facility with all components able to be stored at ambient temperature. There is a toasting of our product but that is simply for aesthetics as the raw ingredient(s) that are toasted could easily be put into the finished product without any issue to the consumer; it will just look a little bit different.

 

According to our Ops Mgr, we control all of the control points after they occur to the point that none of them fall into the "critical" category; to my knowledge, this is based on the risk analysis matrix rather than the decision tree although we do have both as reference documents in our HACCP program.

 

I am just starting my third week here, though, and ended up identifying an issue today that I would appreciate any feedback on. We use several nut butters, including peanut butter, for our product. Our batching operators add the ingredients based on recipes but there is no second check that the batch operator used almond butter instead of peanut butter. I am thinking from an allergen standpoint; if we use PB instead of another nut butter and it goes into a product labeled as free from peanuts although processed in a facility with peanuts, couldn't that be an issue?

 

I am thinking this is another support to my argument FOR the use of bar coding as the ingredients used would be captured in real time and we could conceivably even use the software as a double check. If they scan a peanut butter container and it's not in the recipe, the software would return an error message and not let them continue. Heck, that could be a double check for the integrity of ALL recipes. My ops mgr came up with a far simpler idea of getting neon colored stickers to affix to the containers of allergen-containing raw ingredients during the receiving process which I also think is a good idea. 

 

Both the neon sticker and bar coding ideas were nixed by upper management.

 

Would anyone else out there consider this a CCP? I am so new to this that my head is automatically jumping to CCP but maybe I'm being an alarmist?

 

~Emily~

 

P.S. The fact that this thread still exists from 2004 is AWESOME!


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#169 Charles.C

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Posted 23 June 2015 - 04:56 AM

Hi ladytgrr/Emily,

 

It's impossible to give a meaningful opinion on yr HACCP Plan without knowing the process but if you are describing an RTE manufactured product from fresh raw material, i would say yr haccp plan is, to put it politely, unusual unless it's fresh produce which i deduce it's not. I suspect you may have an armada of PRPs.

 

it goes into a product labeled as free from peanuts although processed in a facility with peanuts, couldn't that be an issue?

 

Well basic RA would suggest YES.

 

Is this the actual labelling or are you just speculating ? i sort of got the impression from this forum that the entire USA uses "protective", "it may contain",  labelling universally for  cases like you describe. And perhaps for good reason. Whether such labelling would be a CCP will be debtable.


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#170 ladytygrr

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Posted 23 June 2015 - 01:06 PM

 

 

Is this the actual labelling or are you just speculating ? i sort of got the impression from this forum that the entire USA uses "protective", "it may contain",  labelling universally for  cases like you describe. And perhaps for good reason. Whether such labelling would be a CCP will be debtable.

Charles,

 

Thank you for the reply.

 

I need to refine my answer. Those products of ours which do not contain peanuts/peanut butter have the fairly common US note "peanuts and tree-nuts are present in our facility". 

 

We always clean and sanitize before moving from one run of product on to another product to prevent allergen contamination. But, when I realized we don't have anything in place to "catch" the instance of mistaken use of peanut butter in place of another nut butter for a product that is not supposed to contain peanuts, I started wondering if this should be a CCP from an allergen perspective. 

 

My main concern is that we do not currently have a "catch" in place for that moment of human error when a batch operator accidentally picks up the peanut butter bucket instead of the almond butter bucket and there is no step to verify the correct ingredients have been put into the recipe. Generally speaking, mixing up our ingredients isn't going to hurt anyone, especially since none of our ingredients need to be processed to be made safe. But it seems that peanut allergies can be/are very severe so no check that the proper ingredients are going into the recipe leaves us open to mistakes that would put an allergen into a product that isn't labeled with that ingredient.


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#171 Charles.C

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Posted 23 June 2015 - 03:22 PM

Hi ladytgrr,

 

Thks for response.

 

I anticipate that yr facility includes all the allergen-related activities you refer within an allergen control program which is classified as a Prerequisite. Other approaches do use CCPs,  for example for labelling and specific equipment cleaning steps.

 

The decision as to CCP or PRP is related to haccp methodology. A PRP is a less well-defined entity than  a CCP.  Originally lists of available PRPs tended to focus mainly on hygienic, system-wide activities, for example the SSOP functions. Nowadays the accepted scope has widened to include a variety of  functions loosely classifiable as QA Support activities. The ISO 2002-1 standard is maybe the prime example of  the current range of PRPs.  OPRPs have further expanded the options for ISO HACCP.

 

The potential errors you mention simply illustrate that HACCP is based on subjective probability, aka risk assessment. HACCP cannot guarantee perfection but attempts to come as close as possible in a proactive/evolutionary  way.

 

The downside of using a multitude of PRPs is that people tend to take them less seriously than CCPs so that errors of the kind you mention are overlooked. Yr comment sugests that this may have occurred in the allergen conrol program.

 

i didn't quite get yr comment  "Generally speaking, mixing up our ingredients isn't going to hurt anyone". Peanut cross-contamination certainly can in the wrong mouth.


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#172 ladytygrr

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Posted 23 June 2015 - 05:55 PM

i didn't quite get yr comment  "Generally speaking, mixing up our ingredients isn't going to hurt anyone". Peanut cross-contamination certainly can in the wrong mouth.

I meant outside of allergen issues. For example, if we add an extra dollop of an ingredient such as rice syrup or put in double protein powder A instead of half of protein A and half of protein B, it's not going to be harmful in that our ingredients aren't harmful in large quantities. And our product of RTE bars would need to be consumed in humongous quantities in order to reach a large quantity of any one ingredient.

 

At least, in my third week with the company and in the industry, that's what I've been informed of. I still intend on continuing my own learning of our products and ingredients individually so that I am better educated about it all.  :gleam:


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#173 lkosler

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Posted 08 July 2015 - 06:12 PM

It is possible.  We have no CCP's in our process.  We have one raw ingredient- a mined mineral.  No microbial concerns, no allergens and a solid GMP program.  It depends on what your producing.


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#174 OrganicCandyAng

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Posted 29 July 2015 - 01:05 PM

I wrote a HACCP plan after implementing PRPs. Both the auditor I had come in and the state of IL were impressed with my program and seemed unphased by the fact that I have no CCPs. As long as you have some sort of documentation that you walked through the process and review it occasionally, they are happy. The exercise having been done is best.

 

I spoke with someone about having one CCP and they said something on the lines of "if it's not likely, if the risk is very low, don't create yourself a CCP because you think you need one. If you do, you have to implement a measurable control to prove it's being covered creating more work when the situation is unlikely"

 

I've also encountered wondering if metal detection was a CCP but it was in place before the HACCP program was written so I just have noted that at this point in the process, the risk is low due to our metal detection SOP/Policy.  I refer to each written policy at each point in the process and that seems to cover me.


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#175 djames

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Posted 24 August 2015 - 05:31 PM

My answer is yes as long as the Operational Prerequisite Programme validates the risk of Hazardous Contamination as low tending to zero Risk Priority Number( RPN) 

and any previous CCP,s Risk of breaching the Hazardous limits are validated as having a low probability of occurrence.  


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