16 replies to this topic

[cugrad1995]

Hello All,

I am working with a distribution center that receives, stores, stages, and transport frozen seafood. Does anyone have a sample HACCP plan for such a distributor? Also, is it necessary to perform a Hazard Analysis for each separate seafood product that they are bringing into the facility?

Thanks!

[Dr Ajay Shah]

Your HACCP Plan should be fairly simple. Your main CCP will be monitoring receival of Frozen food at -18°C and storing the product at -18°C and distributing the product at -18°C.

If you have not already done a HACCP course then I suggest that you register on one and do one to help you with designing your HACCP Plan.

It is not necessary to have HACCP plan for each individual item as it can be categorised as "Frozen Seafood" and that should cover everything.

[Charles.C]

Your HACCP Plan should be fairly simple. Your main CCP will be monitoring receival of Frozen food at -18°C and storing the product at -18°C and distributing the product at -18°C

Or a prerequisite ?

Rgds / Charles.C

[YFoodSafety]

Or a prerequisite ?

Rgds / Charles.C

I think that the first step "receiving" is a prerequisite and the other 2 steps "Storage and distribution" are CCPs
Regards,
Youssef

[Foodworker]

I think we have just started the classic HACCP debate!

My own view is that calling it a CCP or PRP or CP is just applying a label. As long as the risk is controlled and reviewed etc., it doesn't matter what you call it.

I don't want to start another thread here, but with the advent of the different Food Safety Standards over the last few years, a disproportionate amount of time and discussion is spent in HACCP studies working out whether something is a CCP or not, rather than how to control the risk.

I think I am right in saying that most food safety incidents and recalls are down to failures in pre-requisite programmes.

Going back to the original post, there is a similar thread on S&D HACCP at the moment with a sample HACCP plan. (unfortunately, that one too got off subject, which was probably also my fault!)

Edited by Foodworker, 16 March 2011 - 10:31 AM.

[Charles.C]

Dear Foodworker,

Too much bait to resist.

My own view is that calling it a CCP or PRP or CP is just applying a label. As long as the risk is controlled and reviewed etc., it doesn't matter what you call it

I think I am right in saying that most food safety incidents and recalls are down to failures in pre-requisite programmes.

I think you are (silently) advocating dumping HACCP in favour of ISO 22000, eg anything may> PRP may> OPRP may> CCP

Rgds / Charles.C

PS @Cugrad - regarding the original post Qu.2, the short answer is that it depends on the process / risk analysis. If HACCP risk equivalence can be demonstrated, a grouping of products is conceivable.

[Foodworker]

I thought I would dangle a worm to see if anything was swimming nearby

I am not especially a fan of ISO22000, to be honest I have not worked with it enough to form an opinion.

I have worked with HACCP since the year dot and I am 100% behind a systematic method of analysing risk and controlling it. What is concerning me is that the language and methodology of HACCP is increasingly taking priority over its implementation.

There are countless posts in these fora asking what the CCPs in process X are. Then there are countless post saying that these are the CCPs and these are your CPs, PRP etc.

If you identify a hazard with a reasonable risk of it occuring, then you need to control it, whatever you call it.

We all do our analyses and identify CCPs. We then present them during an audit. (I know that food businesses are required to work with HACCP principles regardless of whether they are audited, but this is the most common time that anybody outside the company looks at the system). We then wait whist the auditor (me included!) sagely strokes his/her chin and pronounces judgement about your choice of CCP.

I get very annoyed with auditors who say that because you have not called point Y a CCP when in his opinion it should be he is raising a Non Conformity, despite the fact that the risk is perfectly well managed.

Consider for instance the frozen storage temperature which started this thread. Some people will say this is a CCP and some will say it is not. Even if it is not called a CCP, you should still identify a limit, monitor it, calibrate the equipment, document it, validate it verify it, take action when the limit is exceded and review it. What extra would you do if you call it a CCP?

We all have to go through the process but we are in danger of playing a game with auditors.

[Charles.C]

Dear Foodworker,

Good thoughts.

Consider for instance the frozen storage temperature which started this thread. Some people will say this is a CCP and some will say it is not. Even if it is not called a CCP, you should still identify a limit, monitor it, calibrate the equipment, document it, validate it verify it, take action when the limit is exceded and review it. What extra would you do if you call it a CCP?

I think i would ensure that my risk matrix was not 3x3 (or use the crafty American layout )

I get very annoyed with auditors who say that because you have not called point Y a CCP when in his opinion it should be he is raising a Non Conformity, despite the fact that the risk is perfectly well managed.

You really validate / document all yr non-CCPs ?

Rgds / Charles.C

[YFoodSafety]

Dear Foodworker
Good judge for this statments:

Consider for instance the frozen storage temperature which started this thread. Some people will say this is a CCP and some will say it is not. Even if it is not called a CCP, you should still identify a limit, monitor it, calibrate the equipment, document it, validate it verify it, take action when the limit is exceded and review it.

Youssef

[Foodworker]

I could never truthfully say that I have validated all of my non CCPs but probably most, especially where there is a measurable parameter.

Food contact surface cleaning for instance is rarely called a CCP. However, the general tolerance for cleaning is that there is no debris and that there are no pathogens remaining. (There may also be a TVC level, but this opens another can of worms - back to the fishing again!)

The cleaning process is the application of defined cleaning chemicals at a defined concentration for a defined contact time at a defined frequency.

These aspects are validated by an assessment of the achieved level of cleaning by visual and microbiological swab testing. If the concentration or contact time does not provide a result which is within the tolerance then they are increased until the point that they do is identified.

The ongoing acheivement of the tolerance is then verified by auditing of cleaning records, swabs, complaints, GMP audits etc.

Again, what extra would you do if you called it a CCP?

[Charles.C]

Dear Foodworker,

Ahem.

Well, I wouldn’t call it a CCP, but neither would i require proof of compliance to yr suggested tolerance for pathogens.

It seems more useful to me to initially focus on the basics of selecting a CCP before going into the consequential minutiae (not that they are unimportant and may overlap). The variety of interpretations of "CCP" currently in use is not exactly negligible even between "standards" (BRC cf SQF for example !). Although the available options cannot compete with OPRP of course.

Rgds / Charles.C

[Foodworker]

Morning Charles,

This is the point that I was trying to make.

It is because there are so many interpretations and opinions of the definition of a CCP too much emphasis and time spent in applying a label of CCP, CP etc to a control.

Unfortunately it is audits and auditors/inspectors who have made the process worse.

It has got to the stage that I have got one company where there are two sets of HACCP plans. We present one plan to auditors who want it one way and the other plan to auditors who want it another way. The food safety content of the plans is the same, only the labels are different.

We have done this just to get an easier ride during the audits rather than have arguments over points of principle.

[YFoodSafety]

[These aspects are validated by an assessment of the achieved level of cleaning by visual and microbiological swab testing. If the concentration or contact time does not provide a result which is within the tolerance then they are increased until the point that they do is identified.

The ongoing acheivement of the tolerance is then verified by auditing of cleaning records, swabs, complaints, GMP audits etc.

Again, what extra would you do if you called it a CCP?
[/quote]

Dear Foodworker
So, there is no extra to be taken if we called it a CCP, but i have a comment on the above underline sentence: not only we should increase the concentration and contact time of disinfectant (we should follow the instructions of its uses as ther are a maximum limits) but also we can reveiw the cleaning procidures and take any needed corrective actions and/or change disinectant it self as it may be no longer effective.
Thanks and regards,
Youssef

[Foodworker]

Dear YFoodsafety

You are absolutely correct with these additional points. (I only selected concentration as an example, and indeed there are additional considerations such as temperature, rinsing and drying which may be relevant)

However I would also undertake these additional activities even if it is not called it a CCP.

To do otherwise is poor practice.

Edited by Foodworker, 22 March 2011 - 04:49 PM.

[Charles.C]

Dear All,

Slightly

Indeed the question of how to select prerequisites, CCPs etc has a long history without, AFAIK, reaching any consensus agreement. I suppose one rare textual specificity is the “Codex CCP” albeit still requiring a subjective answer to the meaning of “acceptable”. Another might be the (far more contentious) American “Regulatory CCP”. And similarly for Prerequisites where lists of to-be-included activities, irrespective of specific risk assessed aspects, go back a long way (eg to GMP) although the (questionable?) concept of designating a “low risk hazard” as semi-automatically having its associated control measure categorised as a Prerequisite is, I think, a later addition (seems to hv sort of quietly slid in?).

One can waffle a long time on this topic without reaching a particular conclusion however to illustrate (I think) Foodworker’s comments I noticed this conceptual risk matrix as used by a large company for their development of ISO 22000 which nicely illustrates some possible (equivalent) alternatives. The attached comments on the potential error in being too prescriptive are also well made IMO.

 ISO 22000 concept risk matrix.png   111.05KB   27 downloads

Another practical constraint is seemingly that GFSI (and BRC?) are determined to explicitly define the category menu for Prerequisites hence the re-inventing of ISO 22000 as the FSSC semi-clone. It is maybe a pity that FSSC did not repeat the exercise for OPRPs also (standing on my soapbox again!).

Rgds / Charles.C

[MQA]

Hi to all!

Great discussions; had too many responses that I have decided on none.


Dear cugrad1995

• Your Hazard Analysis per product would be determined by the number of steps in the Flow Chart. If all your products follow the same Flow Chart, then you have one Hazard Analysis Table to implement

• I am a believer that receival should hold a CCP for some elements: temperatures should be monitored, product checked for its integrity BEFORE it enters your facility. Your receival register is an important record for a potential Product Recall. Besides, your business is dealing with a high risk category, regardless that product received is frozen

• It would definitely be beneficial to the business if someone had HACCP certification

Hello All,

I am working with a distribution center that receives, stores, stages, and transport frozen seafood. Does anyone have a sample HACCP plan for such a distributor? Also, is it necessary to perform a Hazard Analysis for each separate seafood product that they are bringing into the facility?

Thanks!

[Food Quality Services]

This reply is very late, as the original post was over a year ago. But I would like to add that it is important that the distributor makes certain that all suppliers are legitimate. They must all have a FDA Seafood HACCP plan, and they must assure that they are complying with all of the species specific hazards and chemical and toxin hazards. There is a lot of "fishy" fish out there and if you write a HACCP plan, you must account for it.