Anyway, can you explain to me what the main concept keeping my raw material unloading example from being used as a CCP? Is it that it is already supposed to be controlled by other factors, that it is hard to create critical limits for, or that it isn't really documentable or that later on the problem (dirty raw materials) would be detected? Or any one of those things?
If there are no CCPs doesn't documentation of following policy become difficult? Or should one just establish checklists that must be monitored at different times checking different aspects of GMP?
Hi Caitlin.
I assume that you are in the process of preparing for a BRC/IOP certification audit and are getting to grips with the Hazard analysis secion of the standard ???
I'll try and address the points you raised in order ....
1.I am not saying that your unloading process cannot be a
CCP but rather that what you had said indicated that you had not followed the correct process to determine whether or not it was.
2. Ideally you should have operating procedures or work instructions designed to minimise the risk of material being damaged, these would be ideal candidates for a prerequisite program to your
HACCP system.
3. If only being difficult to control and document was an excuse not to make a
CCP we would all be so much happier ! unfortunately it isn't and if your Hazard Analysis showed that a process was a
CCP then it must be controlled and documented no matter how dificult. It is an interesting point that you make about contaminated materials being detected later on, if youhad a procedure in place for inspecting material before use then this step could exclude the necessity of unloading as a
CCP.
4. If there are no
CCP's then there is no 'following' documentation, you would have the procedures that you use to achieve GMP and these would form the prerequisite programmes taht when followed ensure all risks are controlled to anextent that means you have no
CCP's.
If this is your first foray into BRC and
HACCP I would say that there is no universal right or wrong answers and you must assess your own processes as part of a proper Codex based
HACCP program and do what is right for your site. As a packaging producers you should find that a well implemented prerequisite programme of GMP and hygiene procedures would result in very few if any geniune
CCP's, the plant I am based at produces tens of millions paper based packages a year on 12 production lines for many of the biggest brands and we have 1
CCP.