First off, I greatly appreciate the volume of useful information I have sourced from various discussions here. Namely, whether an effective HACCP plan can contain no CCPs. I would love additional insight into a situation currently being examined within our organization.
Our organization produces nuts for use as non-critical aggregates in food and confectionery products. We receive raw product directly from farmers, and proceed to remove a variety of foreign materials from this raw product in addition to segregating the product based on various characteristics. Finished goods product is either shelled or unshelled, classified based on characteristics, and has had foreign material minimized to levels within the specifications of our customers. In addition, finished product is sampled and tested for acceptable levels of aflatoxin and foreign material by an on-site USDA entity before it is allowed to leave the facility (with the passing label applied by the USDA being "Fit for human consumption").
Our dilemma arises in the nature of our product. Through a series of CPs, we reduce and minimize the level of foreign materials (such as rocks, metals, etc.). However, we still market our product as a raw agricultural product not intended for use as a critical ingredient, and not safe for end-user consumption without additional processing. This has caused myself and other personnel to disagree somewhat on how HACCP applies to our process. As we evaluate our process for CCPs, we have no ultimate processes that reduce or eliminate a hazard to a level fit for actual human consumption, despite the label attached to the finished product by the USDA grading system. For instance, we have no metal detector in our process, and rely on the elimination of nonferrous metals through a series of magnets. Similarly, rocks and stones are removed from the product through specific machinery designed to do so. No kill step exists to eliminate inherent microbial pathogens from the product (as this would alter the very nature of the product), yet we attempt to minimize the potential for occurrence or contamination by such pathogens in our process through GMPs. So, no CP exists where the product we produce will undergo no further processing for a particular hazard before end-user consumption. Thus, in my mind, we have a HACCP program containing no CCPs.
On the other hand, we have the argument that an intrinsic necessity of a HACCP plan is at least one identified CCP. Some personnel argue that the USDA sampling and testing of finished product for the presence of aflatoxin and foreign material provides us with a go/no go step in our process to control these hazards. I find fault in this due to the sampling method present, as even a very high confidence level and low confidence interval are still only monitoring a portion of the product, and that the USDA grading is simply a monitoring of our process similar to our own finished goods sampling.
We are not alone in our woe. Our entire industry seems to be in a similar situation to ours. Competitors consider their metal detectors as CCPs, something I fully agree with. In fact, the cleaned and sized product line includes a metal detector due to the increased quality demands from the intended use of the product. Some also consider their electronic sorting machinery as a CCP, which I do not agree with based simply on their unreliability in detection of foreign material. However, none of our peers have CCPs in place related to stones, sticks, or glass in their processes.
I apologize for the novel, but wanted to provide some level of detail as to our situation. Any thoughts?
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