17 replies to this topic

[Martinblue]

Hi All,

Just quick question about CCP. Can a CCP in HACCP be purely based on quality issue!

We are sandwich manufacturer where we used raw vegetable like tomatoes and onions after chlorine washing but in some recipes we use same vegetables after roasting or cooking.

Can this roasting/cooking step be a CCP?

Please help!



Martin Blue

[Charles.C]

Dear Martinblue,

The original versions of HACCP (at least the American ones) covered hazards due to safety, quality and economic fraud. The last 2 were quietly dropped out within a few years leaving the focus on safety.

What is the hazard which you believe the roasting / cooking step is controlling / eliminating ?

If it's a simple change in flavour, then not HACCP related.

(Some Buyers and SQF do deliberately add quality factors into their HACCP programs but (current) traditional HACCP, no)

Rgds / Charles.C

[GMO]

Now purists say "no". There is a good reason for this. HACCP is seen as a complicated subject. There is benefit in keeping it simple and keeping it only about food safety, however, many sites do consider quality and as long as you don't get confused, it can be ok. Personally though I wouldn't and I would have a separate "quality plan" (a less in depth plan which covers all of the quality and legal points on the plant. You could call these quality points or QCPs if you must!)

That said, is the roasting step after the washing or the way into high care? If it's the latter, it might be a CCP anyway, if it's the former, it's worth considering cooling times (although probably for veg the cooling times are so short it might not be a safety issue anyway.)

[nitac]

HACCP is purely about food safety nothing else. Thats my two pennys worth!! makes my toes curl when I see QCP's and LCP's in HACCP (Just had the hazard of "cutting hands on pallet strapping" as a CCP in the one Im auditing at the moment!!)

If your roasting process is INSTEAD of chlorine washing then it serves to "remove or reduce to acceptable levels" the risk of pathogenic contamination then its automatically a CCP according to the CODEX decission tree. BUT you will need to have validation work (lab analysis before and after) and a set time / temperature plus records of checks etc for roasting if you do decide its a CCP.

[Martinblue]

Thanks for your contribution.


It sounds like it should not be a CCP as chlorine wash (CCP)is already reducing or eliminating hazards to an acceptable level but what is about Post Cooking-Chilling of same vegetables!

would this chilling be a CCP as Temperature should be ≤5⁰C with in 90 minutes.



Please suggest.

Martin Blue

[GMO]

Thanks for your contribution.


It sounds like it should not be a CCP as chlorine wash (CCP)is already reducing or eliminating hazards to an acceptable level but what is about Post Cooking-Chilling of same vegetables!

would this chilling be a CCP as Temperature should be ≤5⁰C with in 90 minutes.



Please suggest.

Martin Blue

I suppose the question to ask is if you don't acheive that time / temp combination, will it be hazardous or likely to be hazardous? Maybe, maybe not. It largely depends on how effective your chlorine washing is I suspect. There is however, nothing wrong with having two CCPs both for the same thing if one reduces loading and another prevents that residual loading then increasing to unsafe levels.

I say go through a validation exercise on it, you'd have to anyway if it became a CCP so it can either be justification for or explanation why it's not, so whichever answer you get it won't be wasted work.

[shrikant Kulkarni]

I think, measure which are applied to control the quality shall be treated as Process Control Points & not as a CCP.

[Charles.C]

It sounds like it should not be a CCP as chlorine wash (CCP)is already reducing or eliminating hazards to an acceptable level

I'm afraid that a lot of refs probably won't agree with that convenient general statement. The USFDA for one.

of course, it may depend on yr validatable result / defined acceptable level.

A potential Pandorra's Box.

Rgds/ Charles.C

[James H]

In our raw aggregate process, sometimes the distinction between quality and food safety can be fairly grey. For instance, the regulatory requirements for our finished product allow for a significant amount of FM occurrence (be it glass, rocks, metal, dirt, etc.). Obviously, high levels FM levels that meet regulatory compliance aren't something our customers are looking for, so we conform to their much lower specs. It's these specs that we base our risk and CCPs.

So, we have regulatory standards that we greatly exceed to meet customer demands. I've taken to referring to what we have as customer CCPs, and the concept has been a point of discussion with HACCP minds I've spoken to. A few have referred to them as quality CCPs, for what it's worth.

[esquef]

As Charles C stated SQF 2000 Level 3 is a HACCP-based approach to quality, and yes, the quality analogue to a CCP is a QCP.

[Jomy Abraham]

Chlorine Wash is basically called as Sanitization and its a mandatory step for the preparation of fruits and vegetables to be used in veg salads, sandwiches, fruit salads etc. Here, the pathogenic micro hazards are either eliminating or reducing to an acceptable level. In order to assure it, 80 to 100 ppm sodium hipo chlorite solution is recomended. As there is no further Step to reduce/eliminate the micro hazards after the chlorine wash, Chlorine sanitization can be considered as a CCP. In case of other steps like cooking, baking, roasting and frying, the same effect is happening and hence all these steps can be considered as CCPs. But in case of pre processing, any pre heating or temperature controls are not necessary to consider as a CCP. Because, in Decision tree, we can proceed with the quest " Any further step eliminates/reduce the risk of hazards". So such pre process temperature controls can be conisdered as OPRP as per ISO 22000 FSMS.

Suggestions are welcome..

Regards
Jomy Abraham

Hi All,

Just quick question about CCP. Can a CCP in HACCP be purely based on quality issue!

We are sandwich manufacturer where we used raw vegetable like tomatoes and onions after chlorine washing but in some recipes we use same vegetables after roasting or cooking.

Can this roasting/cooking step be a CCP?

Please help!



Martin Blue

[Simon]

Personally I don't mind seeing quality criteria in HACCP plans despite it offending the purists. You want to provide costomers with safe, wholesome, quality products and having all of these criteria thought out, assessed, documented and controlled under one system to me reduces duplication and focusess the mind of the business and all of those involved.

[GMO]

Personally I don't mind seeing quality criteria in HACCP plans despite it offending the purists. You want to provide costomers with safe, wholesome, quality products and having all of these criteria thought out, assessed, documented and controlled under one system to me reduces duplication and focusess the mind of the business and all of those involved.

I don't mind it as long as people don't get distracted by it; unfortunately IME people do get distracted by quality issues. The joy of HACCP is it's simple, you don't have to go into the huge detail that quality would demand. I think it takes a very experienced technical professional to be able to combine them both without missing the point. I've seen HACCP plans where quality is considered in great detail but the TM was unaware that one of their metal detectors was ferrous in foil (yet it was allegedly controlling stainless steel).

[Charles.C]

Dear Jomy Abraham,

Here, the pathogenic micro hazards are either eliminating or reducing to an acceptable level.

Can you validate this statement ?.
I agree that some textbooks do use the step as a CCP but typically on their logic that the risk (ie pathogen level) is "minimized" unlike the requirement in standard HACCP texts (eg Codex, NACMCF). The latter part of yr statement is not impossible but IMEX, extremely rare for routine hypochlorite-based systems.

Rgds / Charles.C

[faisal rafique]

Dear all,

It looks not to be CCP because hazard mainly considered as which causes illnes or injury. Treatment is there so may be cp, but to be more liberal
Faisal Rafique

[Jason H.Z.C.]

Dear All,

In my personal opinion, HACCP is a good tool recommended by Codex to deal with the food safety hazards.

The principle of HACCP system is risk assessment + defining control measures. Some measures are critical, thus they are set as CCPs(of course according to decision tree).

However, this tool can also be used by enterprises to deal with all "hazards" affecting their business. e.g. quality of products often decide the price of such products. Thus if enterprise can also use this tool to control quality aspects.

If a business "hazard" has been identified they can also establish control meansures for such "hazard".

So in my opinion it is only a tool or a method to control hazard. But the definition of hazard can be determined by companies themselves.i.e. They can define the hazard as same as codex definition(Any physical, chemical or biological agent in or condition of a food with the potential for cause an adverse health effect). Or they can define a hazard as codex definition + any hazard with potential for cause an adverse business effect.

Just my five cents opinion,

Best regards,

Jason

[Jomy Abraham]

I dont have any validated study report in this case. ..
Soaking the vegetables in 100 ppm sodium hypochlorite solution (prepared in chilled water) for 20 minutes can reduce the initial TPC of the vegetables to acceptable levels of TPC ( need to refer/specify). Especially for green salads, sanitization is the option to eliminate or reduce the mibiological hazard to....the reference standard...!!

Can't we consider this as a CCP based on the definition and the Decision tree, if the micro load is reduced to the industry standards?

Regards
Jomy Abraham

Dear Jomy Abraham,



Can you validate this statement ?.
I agree that some textbooks do use the step as a CCP but typically on their logic that the risk (ie pathogen level) is "minimized" unlike the requirement in standard HACCP texts (eg Codex, NACMCF). The latter part of yr statement is not impossible but IMEX, extremely rare for routine hypochlorite-based systems.

Rgds / Charles.C

[Charles.C]

Dear Jomy abraham,

Can't we consider this as a CCP based on the definition and the Decision tree, if the micro load is reduced to the industry standards?

The short answer is usually No.
For the long (validated) answer see thread below, posts #29 and 32 -

http://www.ifsqn.com...dpost__p__34703

Rgds / Charles.C