19 replies to this topic

[sadean]

Hi,

I am trying to determine if a destoner is a CCP or if the hazards are controlled through the preventative maintenance program. The process involves cooking and drying grain which contains a small amount of stones. There is a destoner at the end of the processing line. There is no magnets or metal detectors in this facility. It appears as though it should be a CCP, but I am unsure of how I set up the monitoring parameters for it to be one. What is the critical limit, monitoring procedures, etc.

Thanks for any information you can provide!

[Dr Ajay Shah]

It is a good idea for you to attend a HACCP Training course and use the Risk Assessment Matrix to determine the risk for your process if you have not already attended a course.

Please bear in mind that a CCP is something that you can measure e.g. Temperature, Pressure etc and that one can have critical limits on that control to be able to control it if it happens to go out of control.

From what you have described of your process, the cooking & drying process can be a CCP as you can determine the temperature and time of the process and place limits on it.

If you cannot measure or place limits on the destoner process then it cannot be classed as a CCP and can only be classed as a Control Point. (CP).

I hope this helps and assits you.

Regards

Ajay Shah

[Charles.C]

Dear sadean,

You are correct in that there are often differences of opinion regarding whether specific “Physical” hazards should be regarded as CCPs or not ? For the kind of process you mention, I doubt that this is a regulatory defined safety parameter but meaningful forum comments usually require some details of, at a minimum, the process and end product status / usage. These enable assessment of the risk as per previous post.

For many raw materials, an initial screening step for items like wood, stones etc is often typically considered as a PRP however if some specific use of the product exists, eg for direct use in a baby food, then the risk situation may change and particularly if the last stage is involved. The evaluation of this, as per previous post, requires you to assess yr risk in yr process for which established haccp procedures exist

Here is a very approx. empirical self-question for CCPs in traditional HACCP –

 empirical CCP.png   71.71KB   42 downloads

(it is assumed that some likelihood of the defect occurring is not un-reasonable, ie if "it" is impossible to happen, no reason to hypothesise further )
Rgds / Charles.C

[philip]

Agree with the previous posts. If you can't set a critical limit, it can't be a critical control point, hence it is a CP or OpPR depending on your understanding and approach. Our HACCP is defined in terms of PRPs. OpPRs and CCPs.
Now, speaking as an "owner" of destoners for cleaning pulses and vegetables, we have taken the view that the absence or minimisation of stones in the raw material in the first place is a part of the pre-requisite programme. So, better to not have stones in the first place, so mamage through specification and working with suppliers.
Of course some stones will inevitably be present, otherwise why bother with destoners. The design of these will dictate efficiency of removal, but bear in mind also that low density stones (pumice, chalk, etc.), may not be removed from th eproduct flow, hence the question about critical limits. However, the emptying of the destoner requires a proedural approach to prevent recontamination of the product stream. This is the OpPR.
I hope this helps understanding as to the meaning of Operational Prerequisites as well as the destoner specifically

[Charles.C]

Dear Philip,

I hope this helps understanding as to the meaning of Operational Prerequisites as well as the destoner specifically

Sorry, it didn't help me (unless it was supposed to demonstrate that Oprps are typically intuitive. ) Perhaps you could clarify.

Rgds / Charles.C

[SriramB]

Dear Philip,

I understand the Destoner cannot gaurantee removal of every contaminant (e.g. pumice). But , assuming there were no further controls (I am not sure of your product, but if it were veges that are consumed as is, ready to eat), then there is a chance that a Pumice of sufficient physical proportions to cause 'choking' could pass on to the consumer.

In this case, the critical limit for the hazard, i.e a foriegn object say pumice, would be - 0 numbers of objects of sizes that can choking, larceration etc. So, you would have your critical limit. Now, the destoner can become a CCP as it has a limit .

I believe that presence or absence of limits do not determine the CCP categorization. Rather the risk and the position of the control in the process sequence determine if it is a CCP. If we are unable to determine the limits OR if the control is not comprehensive in attaining the limits, i would note in the HACCP documentation that the hazard is 'uncontrolled' and advise management etc, so that we coiuld either effect process design changes or develop contingency measures.

I realize that I am not providing a solution, but have found out that not all food hazards toe the codex line

Cheers,

SriramB

[Tony-C]

Hi,

I am trying to determine if a destoner is a CCP or if the hazards are controlled through the preventative maintenance program. The process involves cooking and drying grain which contains a small amount of stones. There is a destoner at the end of the processing line. There is no magnets or metal detectors in this facility. It appears as though it should be a CCP, but I am unsure of how I set up the monitoring parameters for it to be one. What is the critical limit, monitoring procedures, etc.

Thanks for any information you can provide!

It would help if you indicated the intended use of the grain. I am assuming it is sieved at some stage of the process so the stones must be small and therefore represent a broken tooth hazard rather than a choking hazard?

Regards,

Tony

[Carlos Leoncini]

Hi, your question is very interesting. Supposing that destoning process has a CCP step, or at least could be consider as key operational process, I think I can help you. The key is to understand which operating variables command the destoner effectiveness. If you give me that data we could probably establish some critical limits. For example and depending on your equipment you could try to set or standardize some operational parameters like: air pressure, sieve width, feed capacity (Tn/h), aspiration volume (m3/h), screening inclination, Power(Kw), etc. Validation could be more difficult but not impossible. Please tell me if this info helped you. Regards. Carlos

[SriramB]

Dear sadean,

You are correct in that there are often differences of opinion regarding whether specific “Physical” hazards should be regarded as CCPs or not ? For the kind of process you mention, I doubt that this is a regulatory defined safety parameter but meaningful forum comments usually require some details of, at a minimum, the process and end product status / usage. These enable assessment of the risk as per previous post.

Rgds / Charles.C

Hi Charles, Sadean,

I use a Destoner in a Coffee roasting setup. The destoner works on the principle that all particles heavier than a 'roasted coffee bean' fall due to gravity whereas the Coffe beans are sucked up into hopper by a finely tuned Vaccum.

Now, as others have mentioned we still can get particles like charred wood, smaller stones, (in some cases concrete) which somehow manages to escape the destoner. Especially when the destoner catchement gets full.

We have rectified this by modifying the catchement and also plan to have two Destoner in tandem, etc.

But, consdering the end product,... all these beans get ground (very finely, or plunger ground) and in any case the coffee is consumed by decoctioning the ground coffee using Filters and hot Water etc. (i.e. the coffee is not consumed directly).

By this time any "non Coffee" particle is ground to smithereens and cannot harm the consumer. Indeed the destoner helps prevent damage to the grinder blades more than mitigate any 'real; Food safety risk.

But, I do have auditors, who are not convinced that the destoner should not be a CCP. But, they also do not rebutt the above justification conclusively.

Unfortunately, I havent much prior experience to draw upon regarding Destoners and any clarifications from the forum will be great!

cheers,

SriramB

[Carlos Leoncini]

An auditor should not be judging if a step in the process is or is not a CCP. They should evaluate if the CCP identification process and haccp analysis is correct. Auditors shall not give opinion on those matters because they are out of scope. Can anybody tell where in a standard says that the auditor can evaluate if a process step is a CCP?.

[amandas]

Interesting thoughts - here is one more to add to the many you have already:

First - a HACCP assessement needs to be made without the intention of classifying an existing piece of equipment as a CCP - so if we out that aside and approach it as such:

Physical hazard assesssement for Raw Material - assuming you have already noted stones as a hazard. Are there others? - metal, plastics, glass, aluminum etc
Process hazard analysis - are there other equipment that can add/remove the physical hazards?
Define the limits of the hazard - what size will cause a food safety issue - XXmm - XXmm
Now review if the destoner will remove all the hazards that may still be present prior to the destoner by the destoner (here is where it will be very difficult for you to claim that all foreign material hazards are removed). You may be able to demonstrate that a stone piece that meets your definition of a hazard will never pass through a "properly" operating destoner - in which case you may be able to classify the destoner as a CCP for the physical hazard stones (and Foreign Material of similar density). In this case, you will then have to define the proper operating conditions as noted by Carlos. You will also need a "challenge test" for your CCP - which could be putting stones at the size limit of the hazard inot the destoner and recording that it goes to the waste stream.

Your challenge will be in identifying how you are addressing other foreign material that remains as well as the potential of subsequent process adding other hazard. This is the reason most companies would report to puttign a metal detector/ X-ray machine at the end of the line.

You may be having screeners and color sorters that may be control points as well.

[Fred K]

Carlos,
I would appreciate if you could share with me how you go about validation of a destoner.

Thanks
Fredk

[Tony-C]

An auditor should not be judging if a step in the process is or is not a CCP. They should evaluate if the CCP identification process and haccp analysis is correct. Auditors shall not give opinion on those matters because they are out of scope. Can anybody tell where in a standard says that the auditor can evaluate if a process step is a CCP?.

Interesting thought Carlos but I am sure that would be covered off indirectly by validation and to some extent verification:

BRC 2 The Food Safety Plan - HACCP
2.9.2
Validation of each CCP:
Documented evidence shall show that the control measures selected and critical limits identified are capable of consistently controlling the hazard to the specified acceptable level.

The SQF Code, Edition 7 Module 2: SQF System Elements
2.5.2 Validation & Effectiveness (M)
2.5.2.1 The methods, responsibility and criteria for ........................ validating critical food safety limits ......................... shall be documented and implemented.
The methods applied shall ensure that:
iii. All critical limits and control measures individually or in combination effectively provide the level of control required.

ISO 22000:2005
8 Validation, verification and improvement of the food safety management system
8.2 Validation of control measure combinations
Prior to implementation of control measures to be included in ...... the HACCP plan ............. the organization shall validate (see 3.15) that
a)the selected control measures are capable of achieving the intended control of the food safety hazard(s) for which they are designated, and
b)the control measures are effective and capable of, in combination, ensuring control of the identified food safety hazard(s) to obtain end products that meet the defined acceptable levels.
If the result of the validation shows that one or both of the above elements cannot be confirmed, the control measure and/or combinations thereof shall be modified and re-assessed

Regards,

Tony

[FodfoodsafetyKate]

Hi everyone, 

I am jumping on this old post....

 

I am working with a coffee roaster and i fee that destoner is an oPRP, however, I am interested in validation....They currently have destoning as a CCP. How can you challenge test and validate a destoner?

 

Thanks

[Charles.C]

Hi everyone, 

I am jumping on this old post....

 

I am working with a coffee roaster and i fee that destoner is an oPRP, however, I am interested in validation....They currently have destoning as a CCP. How can you challenge test and validate a destoner?

 

Thanks

 

2 choices -

 

(1) define it as a PRP just like Post 4 and avoid hours of mental distress.

(2) buy an X-ray machine and validate with a Procedure equivalent to that on Pg 13 of attachment.

 Codex validation guidelines.pdf   206.81KB   27 downloads

[Dan E]

2 choices -

 

(1) define it as a PRP just like Post 4 and avoid hours of mental distress.

(2) buy an X-ray machine and validate with a Procedure equivalent to that on Pg 13 of attachment.

Codex validation guidelines.pdf

 

Charles,

 

I am having a hard time defining stone removal as a PRP. Stones are a common element to find throughout our process because of the nature of the product and how it is harvested, so I cannot control this through suppliers. We have two destoners in our process, and it is my understanding that process steps cannot be considered PRP's. After going through three different CCP decision trees I always come up with the destoner process step as a CCP because it is a hazard that poses a significant risk to the customer and there are no other control measures in place to eliminate or reduce the hazard to an acceptable level.

 

If something cannot be measured online, but it is a process element necessary for food safety, what do I call it? I can't make it fit with any decision tree and I don't know what else to call it other than a CCP. Also we are a very small operation so an optical sorter is not likely to happen any time soon.

 

Standard: BRC 8

Product: Rice

 

Regards,

Daniel

[Charles.C]

Charles,

 

I am having a hard time defining stone removal as a PRP. Stones are a common element to find throughout our process because of the nature of the product and how it is harvested, so I cannot control this through suppliers. We have two destoners in our process, and it is my understanding that process steps cannot be considered PRP's. After going through three different CCP decision trees I always come up with the destoner process step as a CCP because it is a hazard that poses a significant risk to the customer and there are no other control measures in place to eliminate or reduce the hazard to an acceptable level.

 

If something cannot be measured online, but it is a process element necessary for food safety, what do I call it? I can't make it fit with any decision tree and I don't know what else to call it other than a CCP. Also we are a very small operation so an optical sorter is not likely to happen any time soon.

 

Standard: BRC 8

Product: Rice

 

Regards,

Daniel

Hi Daniel,

 

It's a potentially infinite line of queries.

 

Is there a particular standard involved, eg BRC etc ?

 

Can you very briefly summarize the process/finished product to show where the destoners come in ?

 

PS -  if you think you can justify it being a CCP (how ?) and can validate a CL (how?), why not simply call it a CCP ?

[Dan E]

Hi Daniel,

 

It's a potentially infinite line of queries.

 

Is there a particular standard involved, eg BRC etc ?

 

Can you very briefly summarize the process/finished product to show where the destoners come in ?

 

PS -  if you think you can justify it being a CCP (how ?) and can validate a CL (how?), why not simply call it a CCP ?

 

Charles,

 

I was worried you might say that! 

 

I am working on getting BRC certified. 

 

The final destoner, the one I would imagine needs to be a CCP, is the last step prior to our CCP metal detection and packaging. 

 

My problem is that I do not know how to validate it. My understanding is that a CCP needs to include some form of critical limit and inspection and I don't know how to establish that for a destoner. As mentioned in post #4, stones of similar density to the product may be present and may not reject as reliably. A destoner is not foolproof in the same way a metal detector that is functioning properly should be, with very clearly defined limits for detectability and size. 

 

Regards,

Daniel

[Charles.C]

Charles,

 

I was worried you might say that! 

 

I am working on getting BRC certified. 

 

The final destoner, the one I would imagine needs to be a CCP, is the last step prior to our CCP metal detection and packaging. 

 

My problem is that I do not know how to validate it. My understanding is that a CCP needs to include some form of critical limit and inspection and I don't know how to establish that for a destoner. As mentioned in post #4, stones of similar density to the product may be present and may not reject as reliably. A destoner is not foolproof in the same way a metal detector that is functioning properly should be, with very clearly defined limits for detectability and size. 

 

Regards,

Daniel

Hi Daniel,

 

I'm not very familiar with rice destoners  but they seem quite sophisticated devices..

 

I suggest you consider the destoner unit as analogous to that of a sieve.

 

The haccp hazard for a sieve is typically stated as something like "metal (or XYZ) contamination due broken sieve" so that the CL is something like "Integrity of sieve is satisfactory" where "integrity" may be solely stated or variously detailed, eg no broken mesh,  all holes < 2mm, sieve is rotating at Y revs/min.

I anticipate that the CL for a destoner can be handled similarly.

 

IMO Validation of the destoner should be done via a procedure such as described in Post 11. Similar procedures are variously described for destoners on IT in order to evaluate their "Efficiency" for stone capture.

(can compare the validation procedure for a sieve as exampled in attachment to post 15)

 

Good Luck !

 

PS - an earlier thread here on validation of a sieve CCP/CL generated an equally complicated set of responses. One post stated that Validation was based solely on absence of customer complaints which the auditor happily accepted, eg -

https://www.ifsqn.co...ize/#entry53683

Edited by Charles.C, 26 November 2021 - 12:01 PM.
edited

[Dan E]

Hi Daniel,

 

I'm not very familiar with rice destoners  but they seem quite sophisticated devices..

 

I suggest you consider the destoner unit as analogous to that of a sieve.

 

The haccp hazard for a sieve is typically stated as something like "metal (or XYZ) contamination due broken sieve" so that the CL is something like "Integrity of sieve is satisfactory" where "integrity" may be solely stated or variously detailed, eg no broken mesh,  all holes < 2mm, sieve is rotating at Y revs/min.

I anticipate that the CL for a destoner can be handled similarly.

 

IMO Validation of the destoner should be done via a procedure such as described in Post 11. Similar procedures are variously described for destoners on IT in order to evaluate their "Efficiency" for stone capture.

(can compare the validation procedure for a sieve as exampled in attachment to post 15)

 

Good Luck !

 

PS - an earlier thread here on validation of a sieve CCP/CL generated an equally complicated set of responses. One post stated that Validation was based solely on absence of customer complaints which the auditor happily accepted, eg -

https://www.ifsqn.co...ize/#entry53683

 

Charles,

 

Thank you for that explanation, that makes a lot more sense to me now. We shall see what the auditor says!

 

Regards,

Daniel