24 replies to this topic

[GMO]

In your opinion if you were in a bakery making breads, scones etc, would you expect baking to be a CCP? Presumably as flour can contain Salmonella and b. cereus the baking would kill the former and kill or reduce the water activity (presumably?) to prevent growth of the latter? But then if the temperatures required for that weren't reached, the bread would be raw surely?

Which comes to another question; if the cooking step in a HACCP plan would render the foodstuff inedible through quality reasons if the temperature for safety reasons was not attained; is it still a CCP or not?

[D.R. Tirtasujana]

Hi GMO,

I would say that, in this case, baking is not CCP.

The operation limit (the limit needed to make the product of good quality) is far above the limit needed to control the hazard (critical limit, if it is a CCP). We don't need to monitor the critical limit since if it is not reached, the product is automatically rejected by the baker or even by the consumer in case it is unintentionally sent to the market. No one would eat or accept them because of poor quality... So, we don't have to manage this baking as a CCP.

I have also ever seen a bakery which didn't determine baking as their CCP... and they are ISO 22000 certified (by international certification body).

Thus, in my opinion, your 2nd question should also be answered by "it is not a CCP" as well

Regards,
-Rizki-

[GMO]

Thank you.

It's one of those things which is a tough one to call IMO; perhaps we need to put another question into the decision tree to account for this because there are microbiological hazards prior to baking which baking reduces to a safe level, yet it's not a CCP. I suppose it depends on your interpretation of "is this step specifically designed to reduce or eliminate" question (if you use that tree) in which case you could argue for baking that it's not and it's more around flavour / quality then you could argue if the controls failed the hazard would not exist because the bread would be rejected.

Hmm. An interesting one. I'd be tempted to have it as a CCP anyway, I know that's probably not right. Just like metal detection can be argued not to be a CCP, I wonder if it causes more problems not to have it? Sorry, your statement "I have also ever seen a bakery which didn't determine baking as their CCP... and they are ISO 22000 certified (by international certification body)" do you mean you'd never seen a bakery which didn't have baking as a CCP or you only see bakeries which don't have baking as a CCP?

[D.R. Tirtasujana]

I agree with you, that it depends on the interpretation of the question no#2 in Codex Decision Tree... I myself, would say "no" as the answer for the question no#2, so that, for me it is not a CCP. However, we still need to monitor it (e.g. as OPRP).

What I saw was just one bakery. Actually, it was a retail company, where it sells ready to eat foods, breads, meat, fish, etc. So, the bakery line is a part of the company. ISO 22000 (and of course HACCP) is implemented there. When the HACCP team determine the control measure, they decided the baking to be an OPRP (not CCP).

Anyway, what I believe is, there is no right or wrong HACCP system, but there is "valid" or "invalid" HACCP. The same control measure can be a CCP in one company but not CCP in another, and still both HACCP are valid.

Whatever we decide, whether baking is a CCP or OPRP, as long as we can prove that it is a valid control measure, and verification after implementation shows that the control measure is effective, then we can say to anybody that the product is safe

Regards,
-Rizki-

[GMO]

Cool. Thanks for your full answer. I'm much clearer now, baking isn't my field of expertise and inevitably after working in ready meals a heat process step feels like it should be a CCP. I suppose the lesson I should learn is to judge each process on its merits not presuppose.

[Charles.C]

Dear GMO,

I think there is usually a customary caveat (somewhere) in presentations of Codex-type HACCP trees that the methodology is offered as a tool for specifying CCPs, ie an interpretation of the core risk assessment of HACCP, and that reference to “basics” is necessary in case of unclarity. (Items like series of, different type, metal detectors spring to mind; even there, subjectivity may enter and allow individual user’s risk philosophies to over-ride and energise auditors’ whiskers, eg it is often considered “best practice” (critical?) to maximally correct as close to a problem source as possible.)

Regardless of the enticing philosophical aspects of using baked quality to conclude the non-existence of a CCP, it is probably more appropriate (conservative?) to simply ask the basic HACCP question that “if a certain baking temperature is unattained, is the result "safe to eat” or perhaps more precisely, “what is the health-related risk if eaten” ?

I believe a little searching on this forum suggests that the (traditional) implemented HACCP consensus is to set the baking temperature as a CCP, albeit a small sample. IMHO, ISO 22000 is biased in view of its unavoidable fascination with generating oprps?. Quite happy to be proven wrong of course.

There is another interesting thread here on baked meat pies where the contents are (may be) initially, separately, pre-cooked before the final bake. Some preference was then shown for 2 CCPs although by no means a consensus. But no preference for zero.

I suspect yr second question was dreamed up while holding the baby in the other hand ??

Rgds / Charles.C

[GMO]

Thanks Charles. The meat pie one is an interesting one. The filling may be cooked (which will reduce the micro loading but we can never assume sterility) so I would argue the second cooking step would create ideal temperatures for growth of any remaining micro if another kill stage temperature is not achieved.

The more I think about it, the more I argue myself into it being an oPRP, then out again, thinking it should be a CCP...

I suppose another way of looking at it could be if you have a high / low care facility in your bread making site, if you allowed the bread to enter the high care side; even if it was to be thrown out later, you could end up with raw / cooked cross contamination.

In the end though what really matters is how you would handle a failure of the cooking process and I'm not sure it would be different if it were a CCP or an oPRP so does it matter?

[tech]

in my opinion, baking is a quality control point and not a CCP. the temperatures set for baking are specific to achive good quality and not target specic to certain bacteria. Normally for your bacteria in flour, a raw material specification will doas a control measure as your supplier has to control these either by UV or otherwise to meet quality regulatory levels.

[cosmo]

In my process I use baking as a CCP for product preservation. I monitor for low moisture and low water activity, thus preventing micro and moulds in the finished product during it's shelf life.

[Marco]

Dear GMO,

I worked in a major bread manufacturer in UK. The only CCPs were raw ingredients sieving and metal detection. The cooking step was considered a process control point.
The pre-baking process steps were about 60 minutes and cooking roughly 24min in a tunnel oven with 3 zones at different temperatures ranging from 210C to 230C. Internal temperature of the product was checked at oven exit and recorded in a process control sheet. This was mainly done to make sure the bread was baked to specification and to make changes to the process when measures were out of spec.

IMO baking is more a technological step (reducing humidity, stabilising the structure, developing aroma and colour) rather than a safety one.

Regards
Marco

[Charles.C]

Dear GMO,

In the end though what really matters is how you would handle a failure of the cooking process and I'm not sure it would be different if it were a CCP or an oPRP so does it matter?

Well, as implied by ISO 22004, it doesn't matter as long as the relevant control measure is safety validated . So logically there was therefore no need for introducing the concept of OPRP, right ??

Rgds / Charles.C

PS here are a couple of haccp plans for bread (previously uploaded here) -

 ab1 haccp plan bread 1.pdf   39.79KB   1820 downloads
 ab2 haccp plan bread 2.pdf   192.33KB   1528 downloads

and here is one of several other threads here on related topic (although new ideas are always welcome of course!)-

http://www.ifsqn.com...dpost__p__31736

A quick summary of the above might include the word "overkill" . Just illustrates the variations in opinion which exist. I daresay there are published examples with very few CCPs also but haven't seen them yet. ??

[MQA]

A few years back, I had to argue black and blue with the external auditor that the baking was not a CCP. Products produced were basic flavours: white and wholemeal of flat breads. It was a quality issue well before it was a critical issue. Baking temperatures were over 500 degrees and the food handlers were well trainined to know if the bread did not pull apart (did not rise) that it was thrown out. In the end, when visited by the auditor's boss, it was ruled as not a CCP.

I know you already have a few responses. But I thought I'd share mine with you too.

[GMO]

Dear GMO,



Well, as implied by ISO 22004, it doesn't matter as long as the relevant control measure is safety validated . So logically there was therefore no need for introducing the concept of OPRP, right ??

Oh so blooming true. Instead of CCP overkill, I'm getting OPRP overkill on plans I'm looking at recently. Anyone else feeling this way? Like by introducing it, they are introducing a "grey area" which means indecisive people have an option? It's like why you should never have an opinion based questionnaire marked from 1-5 because people chose 3. God people are dull.

[Charles.C]

Dear Jaqmqa,

Appreciate yr comment. This thread has become quite an interesting survey of opinions. And subjectivity.

I guess the topic also illustrates the difficulties of being an auditor with a list of crosses and ticks when confronted by a subjective issue. Where would we/they be without “Validation”, the Compromiser’s choice.?

I realise it is somewhat “apples and oranges” but RTE vegetables are an interesting example of another “spoil before dangerous” case. Sometimes validatable generalisations can be “risky”.

@GMO – dull = cautious? (you must be a liberal) This situation is partly a corollary of the notorious equality CP > OPRP. Of course, the judicicious assignment of “significant” risk level cut-offs and/or adjusting likelihoods of occurrence offers one simple escape route (at the possible cost of more paperwork). The Pragmatizer's choice ?

Rgds / Charles.C

[pau]

Baking is not a CCP. For bread to be breag, it has to reach temperatures of about 200 F (Viable product rule). In bread making, you would want to make metal detection a CCP.

In your opinion if you were in a bakery making breads, scones etc, would you expect baking to be a CCP? Presumably as flour can contain Salmonella and b. cereus the baking would kill the former and kill or reduce the water activity (presumably?) to prevent growth of the latter? But then if the temperatures required for that weren't reached, the bread would be raw surely?

Which comes to another question; if the cooking step in a HACCP plan would render the foodstuff inedible through quality reasons if the temperature for safety reasons was not attained; is it still a CCP or not?

[Charles.C]

Dear pau,

Thks yr opinion.

temperatures of about 200 F

Probably 200 degC?

Rgds / Charles.C

[GMO]

Thanks everyone. Interesting comment on sieving; that's the one control point IMO I would have as a OPRP in most cases (in fact it's the only one where I think OPRPs make sense) but that's just my opinion!

[Hongyun]

I hope I'm not posting something stupid here.

I think it is not mandatory for restaurants to have HACCP? But let's say if one restaurant is HACCP certified, and they produce molten chocolate cake for the customers, then, should baking be a CCP here?



pic from The BITES Site

The ingredients contains egg and the inside is not fully baked in order to get that runny texture. What do you guys think? Process from the website states the mixture is baked at 450 degrees, for 7 to 10 mins.

Edited by Hongyun, 21 January 2011 - 02:40 PM.

[GMO]

As in a chocolate fondant?

My question was regarding bread. In the UK a system based on HACCP is a requirement of catering kitchens and there is an argument that if it's a CCP for one product it should be for all (even if it makes less sense for others). I've certainly taken that approach in the past to try and avoid confusion in a factory setting.

In a chocolate fondant, I suspect the temperature of the liquid centre is significantly lower than normal cake batters (or else it would fully cook) so yes it is likely to be a CCP IMO.

[Hongyun]

As in a chocolate fondant?

My question was regarding bread. In the UK a system based on HACCP is a requirement of catering kitchens and there is an argument that if it's a CCP for one product it should be for all (even if it makes less sense for others). I've certainly taken that approach in the past to try and avoid confusion in a factory setting.

In a chocolate fondant, I suspect the temperature of the liquid centre is significantly lower than normal cake batters (or else it would fully cook) so yes it is likely to be a CCP IMO.

Ah I see... I had assumed it was "baking" in general.

[Ludmile]

Hi,

I just tried to download these plans, but I wasn't successfull, can anyone please download it and send to my e-mail address? My e-mail is xxxxxx

Thank you very much

Ludmile

 ab1 haccp plan bread 1.pdf   39.79KB   1820 downloads
 ab2 haccp plan bread 2.pdf   192.33KB   1528 downloads

Dear GMO,



Well, as implied by ISO 22004, it doesn't matter as long as the relevant control measure is safety validated . So logically there was therefore no need for introducing the concept of OPRP, right ??

Rgds / Charles.C

PS here are a couple of haccp plans for bread (previously uploaded here) -

 ab1 haccp plan bread 1.pdf   39.79KB   1820 downloads
 ab2 haccp plan bread 2.pdf   192.33KB   1528 downloads

and here is one of several other threads here on related topic (although new ideas are always welcome of course!)-

http://www.ifsqn.com...dpost__p__31736

A quick summary of the above might include the word "overkill" . Just illustrates the variations in opinion which exist. I daresay there are published examples with very few CCPs also but haven't seen them yet. ??

Edited by Charles.C, 27 September 2012 - 12:10 PM.
email address deleted

[Charles.C]

Dear Ludmile,

I just tried downloading the first pdf file. Seems to be working ok for me.
Please try again.

Rgds / Charles.C

[Ludmile]

Hi,

I just forgot to validate my login, it worked out now!

Thank you!!

Hi,

I just tried to download these plans, but I wasn't successfull, can anyone please download it and send to my e-mail address? My e-mail is xxxxxx

Thank you very much

Ludmile

 ab1 haccp plan bread 1.pdf   39.79KB   1820 downloads
 ab2 haccp plan bread 2.pdf   192.33KB   1528 downloads

[brandywaldrep]

Has anyone actually done any testing to PROVE the "viable product rule" for bread?  With the new FSMA and elevated HACCP requirements for GFSI standards, it will be necessary to justify that reasoning with scientific evidence.  I don't think it is enough to say that product won't meet visual standards if cooked below 180 deg.F for example... because then you will need some way to prove that products not meeting color specifications or certain physical parameters don't get released.  Some may even argue that the finished product parameters would become CCPs at that point.  What we need to prove is my theory that dough not cooked to 180 deg F. will not even run on the equipment (i.e. it will be self-limiting ---- will stick to pans, not be sliceable, etc.) --- if we can prove that, then we can eliminate the need for baking to be a CCP in any bread-producing plant.  Am I the only one with this thought?  Can anyone perhaps do this study in a pilot plant somewhere so we don't all have to waste an oven full of product to prove this?

[mgourley]

The American Institute of Baking (AIB) was working on this a couple of years ago. Not sure if they ever completed the project.

 

Marshall