Dear Philip,
Interesting post. One immediate comment is that it is rather unusual to find a process step used as a prerequisite due to the usual visualisation as a more generally applied program (eg GMP controls) but I would not say impossible since control of received ingredients can be overlapped into PRPs and also "infrastructure related". Regret that I haven't seen the Campden document so difficult to comment on their procedure however any argument presumably also depends on what bacterium you are referring to. If it was a RTE, then a non-zero tolerance for salmonella (legislatory critical limit ??) would usually apply but not so (although perhaps with geographical variations) in the case of L.mono.... (or S.aureus if >10-12degC) I guess this is one support for referencing FSOs when choosing critical limits in the HACCP plan structure. Also there is another aspect of a CCP definition which refers to the ability of a control measure to prevent an acceptable situation changing into an unacceptable one. Ultimately, a deviation will require an appropriate corrective action and I think scenarios such as you mention regarding failure of a CL hv in fact been examined in the literature en route to proposals in the event of failures of home refrigerators (one rule- of- thumb is given in my FDA link previously).
Again, perhaps it''s easier to avoid the D-tree (and even pre-requisite calculations) altogether and use a risk assessment, eg how often do refrigerators fail to achieve a temperature / time adequate to prevent a "representative (?)" level of L.mono (with its own likelihood of occurring) increasing to above an FSO ? And the severity ?? Well, if you're in Canada, it's officially / automatically "high" from memory, and probably in most other locations. That probably leaves you with a choice of M or H to achieve a CCP for a 3x3 matrix. Seems rather simpler than a D-tree ?? 
However I do believe the analysis / validation would be more complicated for salmonella. Certified raw materials = pre-requisite ?
Certainly looks like the Americans should throw away a lot more food from the refrigerator than the Brits. In practice, not so sure ?
Rgds / Charles.C
added - I did some looking around and storage-related functions do appear in some lists of prerequisites (esp.retail) thereby (presumably) neatly avoiding both decision tree and risk assessment procedures as long as the validation reference is acceptable. This is one of the most expanded (FDA, US retail HACCP) presentations that I could see -
PROCEDURAL STEP 1
Develop Prerequisite Programs
If you want to build a sturdy home, you should start with a strong foundation. The same is true of a food safety management system. In order for your food safety management system to be effective, you should first develop and implement a strong foundation of procedures that address the basic operational and sanitation conditions within your operation. These procedures are collectively termed "prerequisite programs."
When prerequisite programs are in place, you can focus more attention on the hazards associated with the food and its preparation. Before beginning to write your food safety management system, it is recommended that you develop and implement prerequisite programs. Prerequisite programs may include such things as -
• Vendor certification programs
• Training programs
• Allergen management
• Buyer specifications
• Recipe/process instructions
• First-In-First-Out (FIFO) procedures
• Other Standard Operating Procedures (SOPs)
Basic prerequisite programs should be in place to -
• Protect products from contamination by biological, chemical, and physical food safety hazards
• Control bacterial growth that can result from temperature abuse
• Maintain equipment
Prerequisite Programs to Control Contamination of Food
These procedures insure that -
• Soiled and unsanitized surfaces of equipment and utensils do not contact raw or cooked (ready-to-eat) food
• Workers with certain symptoms, such as vomiting or diarrhea, are restricted or excluded
• Raw animal foods do not contaminate cooked (ready-to-eat) food
• Effective handwashing is practiced
• Eating, smoking, and drinking in food preparation areas are prohibited
• Water in contact with food and food-contact surfaces and used in the manufacture of ice is potable
• Toxic compounds are properly labeled, stored, and safely used
• Contaminants such as condensate, lubricants, pesticides, cleaning compounds, sanitizing agents, and additional toxic materials do not contact food, food-packaging materials, and food-contact surfaces
• Food, food-packaging materials, and food-contact surfaces are not contaminated by physical hazards such as broken glass from light fixtures, jewelry, etc.
• An effective pest control system is in place
• Hair restraints are used
• Clean clothing is worn
• The wearing of jewelry (other than a wedding ring) is prohibited
Prerequisite Programs to Control Bacterial Growth
These procedures ensure that all potentially hazardous food is received and stored at a refrigerated temperature of 41°F or below. Note that the Food Code makes some allowances for specific foods that may be received at higher temperatures.
Prerequisite Programs to Maintain Equipment
These procedures ensure that -
• Food-contact surfaces, including utensils, are cleaned, sanitized, and maintained in good condition
• Temperature measuring devices (e.g., thermometer or temperature recording device) are calibrated regularly
• Cooking and hot holding equipment (grills, ovens, steam tables, conveyer cookers, etc.) are routinely checked, calibrated, and operated to ensure correct product temperature
• Cold holding and cooling equipment (refrigerators, rapid chill units, freezers, salad bars, etc.) are routinely checked, calibrated, and operated to ensure correct product temperature
• Warewashing equipment is operated according to manufacturer's specifications
• Toilet facilities are accessible to employees and maintained
The items addressed by this procedural step are the foundation by which your entire food safety management system is based. The success of any food safety management system is dependent on how well you control these basic sanitation issues in your establishment
This is getting slightly Off-topic but in the process i noticed 2 other interesting items which people might find interesting -
UK (legal-oriented?) haccp ccp template example for cooked meat pies -
HACCP_Plan_template_cooked_meat_pies.pdf 60.22KB
371 downloads
detailed hygiene (EU 2006) decision tree based analyses for chilled production. May well be related to the well-known CFA book, (GMO should know better than me ) -
(final storage step is not generally listed under GMP except 1 example, remainder are noted as must be examined within overall HACCP plan )
ECFF_decision_tree_recc._for_prod.chilled_foods.pdf 397.86KB
87 downloads
