11 replies to this topic

[Yannisg]

Does anyone have experience with the development of a HACCP study for the packing department of organic (biological) fresh vegetables?
The products are not cleaned prior to packaging but they are washed by the consumer.
I shall be grateful for any helpful information regarding the development of a full HACCP study.

Regards

Yannis

[Charles.C]

Dear Yannisg,

Welcome to the forum !

The post below (and successive ones) may be of interest but it will depend on yr basic product / process which i suggest you post here, eg Are you saying there is no cleaning at all ?

http://www.ifsqn.com...dpost__p__34771

Rgds / Charles.C

[Yannisg]

Dear Yannisg,

Welcome to the forum !

The post below (and successive ones) may be of interest but it will depend on yr basic product / process which i suggest you post here, eg Are you saying there is no cleaning at all ?

http://www.ifsqn.com...dpost__p__34771

Rgds / Charles.C

Dear Charles,

Thank you for your reply. Our products are fresh vegetables (e.g. cabbage, eggplants, lettuce, strawberries, parsley, cauliflower etc) which are delivered in plastic baskets after harvesting, stored under cold conditions (control of temp. and relative humidity), packed and distributed to super markets.
The products are only washed by the final consumer.
If I consider a hazard analysis then I can hardly establish any CCPs as all potential hazards (i.e. microbiological, chemical, physical) seem to get eliminated (washed away) by the final consumer. On the other hand I can hardly accept that we have no CCPs!
This is the basic reason why I ask for advice from people who may be familiar with this kind of products. Please take into consideration that I am not talking about fresh cut vegetables which require another approach.

Kind regards
Yannis

[birmingham2000]

I've been reading the forums with interest, so I thought this would be my first post!

Yannis, my previous role as Quality Manger for a Soft Fruit company supplying the Supermarket. Our HACCP plan did not have any CCP's.

The process started at the packhouse with the delivery of the produce. All hazards including cleaning, knife control, storage were controlled by pre-requistes and no CCP were identified in the process. The HACCP plan passed every BRC audit with an A grade.

Hope this reassures that if you cant find any CCP, then there may not be any, subject to a Hazard analysis.

B

[Charles.C]

Dear Yannisg,

A few comments.

The result requires doing a hazard/risk analysis for yr situation.

If you hv studied any of the fda refs included in my previous link, you will prob.realise that as per the strict definition of a ccp, there are unlikely to be any simple ccps in yr process since no control measures exist which eliminate any potentially significant BCP hazards. Some users modify the meaning of ccp to include “minimise” but this will probably depend on yr local industry norms. And similarly there is no control measure applied for reducing zero-tolerant pathogens to an acceptable level. However the use of low storage temperatures / time might be relevant to maintaining a level of a specific pathogen to below a certain maximum (ie ccp) finite level.

You do not elaborate yr process but I presume you are having to sell the produce as per some legal BCP specification ? If so, and if receival assurances of certain aspects, eg micro.parameters are involved, this is equated to ccps in some plans I hv seen (the reality is debatable but that is another issue) (although this ccp step is more typically found in long post-harvesting haccp plans.)

It all depends on yr exact process / consumer spec.

Quite often there will be a local organisation of related businesses who will hv met yr exact problem already and solved it (at a price of course, eg membership fee).

This NZFA set of various haccp plans for raw vegs might interest you –

http://www.nzfsa.gov...rt_Aug_2001.pdf

Rgds / Charles.C

[SophieH]

We supply organic vegetables. Our process does have a wash process. We don't have any CCP's. Just lots of control points!



quote name='Yannisg' timestamp='1294055600' post='40794']
Does anyone have experience with the development of a HACCP study for the packing department of organic (biological) fresh vegetables?
The products are not cleaned prior to packaging but they are washed by the consumer.
I shall be grateful for any helpful information regarding the development of a full HACCP study.

Regards

Yannis
[/quote]

[GMO]

I would say it is ok not to have any CCPs. I'd think that was fairly common in raw commodity foods, as long as you believe it's right, review it if anything changes and document your decision process, I'd have no issues with that.

[Yannisg]

We supply organic vegetables. Our process does have a wash process. We don't have any CCP's. Just lots of control points!



quote name='Yannisg' timestamp='1294055600' post='40794']
Does anyone have experience with the development of a HACCP study for the packing department of organic (biological) fresh vegetables?
The products are not cleaned prior to packaging but they are washed by the consumer.
I shall be grateful for any helpful information regarding the development of a full HACCP study.

Regards

Yannis

Dear Sophie,

Thanks for your post. May I ask you what exactly you are controlling?
Our quality control system consists basically of visual control of the vegetables (for the appearance of parasites), size and or weight according to the specifications of our customers and finally temperature and relative humidity control in the storage rooms and in the transportation vehicles. But these parameters rather relate more with the quality than with the safety of the products.
If you have a wash process then I suppose that you control the quality of your water. As we do not have this process step I cannot (in our case) consider the water quality as a potential contamination source.

Regards

Yannis

[Manal Saleh]

Dear Yannis,
I worked on very similar products but we were responsible for the farms as well. So the HACCP plans extended from the field to the final product.
If you are not responsible for the farms, then probably you have a firm vendor assurance scheme.
The HACCP plans for organic products followed the normal codex alimentarius process covering BCP hazards - but we had to focus on (1) the composting process especially for leaf salads, (2) chemical drift from neighbours for all products, (3) organic integrity during harvesting, transportation, packing, etc... and which covers the requirements of the organic law.
I hope this is helpful!

[biber]

Dear Yanni,

You should considar use forbiden chemical material for sanitation, pest control and packiging.
This could be CCP.
Also take chemical hazard from woter.

Best regards

[Lynda Leopold]

Hi All,
As the Food Safety Coordinator for a greenhouse vegetable packing house, I find this thread particularly interesting. We, too, had determined that no CCPs were present in our process (we do not wash, sterilise, cut or otherwise manipulate the veg other than packing from bulk to consumer containers). However, many of our customers (large retail) are beginning to require a HACCP plan as a condition of approved supplier status, along with audit certificates under the GFSI benchmark (we are certified by Primus GFS).

This has made me rethink my Hazard Analysis. In my opinion, the greatest risk to the produce is microbiological contamination from workers' poor hygiene. I had THOUGHT that the handwashing SOP, the gloves and hairnets SOP, and the don't-work-when-you're-sick SOP were adequate as PRPs and not CCPs, since there is no fool-proof way to control or measure these controls.

My inkling is to leave the plan alone, and declare that we have no CCPs in our process. And yet, that nagging thought remains...is Handwashing a CCP???

I'd love your thoughts/opinions.

FYI, it also burns me that we in the packinghouse are mandated by GFS audits to wear gloves, but the harvest crew audit does not require the use of gloves by harvesting employees. That is, my grower can harvest tomatoes by hand but my employees must handle them with gloves (often on the very same day! ). Anyone have any experience with this?

This forum has been helpful to me on more than one occasion as I have developed our food safety program from scratch. Thanks much.

Regards,
Lynda
Canada

[Dr Ajay Shah]

Dear Yannisg,

You will need to consider the type of compost you are using for your vegetables, the water quality in terms of chemicals such as chlorine, flourine and also microbiological if water is from dams, pest control, chemical drift due to wind from neighbouring firelds that may practice conventional prcatices. In search for other factors you can consult the following standard from Australia which may help you with your quest and it is free to download:


http://www.australia....asp?Sec_ID=135

Cheers