7 replies to this topic

[kiss_lee28]

Hi to everyone!

Thank God I found a forum where I can really learn so much.. This is with regards to our HACCP Study, We arrived that glass fragments is a significant hazard from our sugar as raw materials. We have 2mm perforated sieve in the line, we used to pass the sugar thru sieve but we also have subsequent step and this is through X-ray Machine detection. We consider 2mm perforated sieve as our OPRP and X-ray Machine as CCP. Are you on the right track? Can we still consider X ray Machine as CCP even if we monitor and manage the quality and integrity of our sieve?

Thank you so much!
Hope for your reply the soonest

[FSSM]

Dear kiss_lee28,

Well, yes X-ray can still be CCP, but can be downgraded to OPRP if you have data to demonstrate that the risk you considered at that step is being managed (controled) by other control mesures (PRPs, OPRPs) and are not likely to fail.

Let´s see if there is anyother point of view in the forum.

Regards,

FSSM

[kiss_lee28]

Tnx FSSM,

What if X-ray Machine is likely to fail and no subsequent step after X-ray,we will consider 2mm perforated sieve as our CCP?

Thank you so much!

kiss_lee28

[Biss]

Hi,

I think you are in the right track.

[FSSM]

Dear kiss_lee28,

Well, any control measure has a likelihood to fail (monitoring integrity of the sieve), which one of the ones you have is less likely to fail?

Your CCP is the point of no return, no other thing you can do to your product will be able to eliminate or reduce the hazard and that would be better at the latest steps of your process. If you can rely on your control measure, then that should be your CCP.

Decision tree (example on page 30) from codex CAC/RCP 1-1969, Rev. 4-2003, 2th, and 4th questions:


2. Is the step specifically designed to eliminate or reduce the likely occurrence of a hazard to an acceptable level?

4. Will a subsequent step eliminate identified hazard(s) or reduce likely occurrence to an acceptable level?

Just this ones take you directly to a CCP.

I´m sure your point has been discussed any were else in this forum, and some pals consider x-ray as a monitoring device of your Integrity of Sieve Review Procedure. But some auditors, won´t be happy with this.

Regards,

FSSM

[GMO]

One note of caution.... X-rays don't necessarily detect glass and where they do, they will not necessarily detect all types of glass. The test cards you can get are for soda glass which is more readily detectable than other types of glass.

My question perhaps turns it on its head. Why is the glass there? Sugar processing presumably involves dissolving the sugar at an early stage where all foreign bodies should be removed?

The other thing I urge you to look at is your sieve and whether it is a CCP in itself, not just because it can remove contaminants but from experience, when seives break, parts can fall off which are very small and may not be detectable by your x-ray. So the fact the seive is intact may become a CCP in itself!

[Rita Inderpersad]

Dear kiss_lee28,

Well, yes X-ray can still be CCP, but can be downgraded to OPRP if you have data to demonstrate that the risk you considered at that step is being managed (controled) by other control mesures (PRPs, OPRPs) and are not likely to fail.

Let´s see if there is anyother point of view in the forum.

Regards,

FSSM

 

Dear kiss_lee28,

Well, yes X-ray can still be CCP, but can be downgraded to OPRP if you have data to demonstrate that the risk you considered at that step is being managed (controled) by other control mesures (PRPs, OPRPs) and are not likely to fail.

Let´s see if there is anyother point of view in the forum.

Regards,

FSSM

Dear Kiss Lee28

 

I am in the process of changing  my sieving process from a pre requisite to an OPRP and would like to know exactly what additional documentation is required to monitor the OPRP.

 

Appriciate if you could send in sample docs.

 

Thank You

Rita

[Charles.C]

Hi Rita,

 

Note that you are querying an 8-year old post.

 

Answer may be delayed.