7 replies to this topic

[Sujit Nair]

Hi,

As per ISO 22000 standard, what all can be considered as control measures ?

The definition, states that it should either prevent, eliminate a food safety hazard or reduce it to an acceptable level.

Whether end product testing can be considered as an Control measure.

I feel that testing is an monitoring or verification activity and it does not control any food safety hazard.

Is there any reference based on which we can conclusively say that ?

Sujit

[Charles.C]

Hi,

As per ISO 22000 standard, what all can be considered as control measures ?

The definition, states that it should either prevent, eliminate a food safety hazard or reduce it to an acceptable level.

Whether end product testing can be considered as an Control measure.

I feel that testing is an monitoring or verification activity and it does not control any food safety hazard.

Is there any reference based on which we can conclusively say that ?

Sujit

Dear Sujit,

Welcome to the forum !

Generalising and simplifying, you might say that, at a minimum, any activity effecting the implementation of a PRP program, OPRP program or CCP is describable as a control measure.

And yes, i realise that does not exactly correspond to the definition . In the context of ISO 22000, you should read the ([re]-Interpretation document - ISO 22004, this contains a lot of explanation/ examples on this topic, eg see sec.7.1)

Rgds / Charles.C

[Sujit Nair]

Dear Charles,

Thanks.

I need some more input on the below statement.

Whether end product testing can be considered as an Control measure.

Let us take a hypothetical case of milk processing, wherein Pasteurisation is the control measure. But, some people take the subsequent Alkaline phospahtase as the control measure. But I feel AP testing is a verification exercise.

How do we counter such assumptions.

Your comments please.

Sujit

Dear Sujit,

Welcome to the forum !

Generalising and simplifying, you might say that, at a minimum, any activity effecting the implementation of a PRP program, OPRP program or CCP is describable as a control measure.

And yes, i realise that does not exactly correspond to the definition . In the context of ISO 22000, you should read the ([re]-Interpretation document - ISO 22004, this contains a lot of explanation/ examples on this topic, eg see sec.7.1)

Rgds / Charles.C

[APPAJI]

Dear Sujit,
You are right. Phosphatase test is only detection and control is what is to be done in case test shows fail. That action is control. So maintaining required temperature of 73 Deg C or what ever is validated.
Regards
Appaji

[Charles.C]

Dear Sujit Nair,

Typically a question of chronology. A (HACCP) control measure (CM) is an action / activity intended to be preventative, ie it is in-process. In fact HACCP strives to avoid / minimise testing of the finished product other than for validation/ verification purposes.

I suppose the result of an AP test, if used in monitoring a pasteurisation-CM, could be a possible critical limit but I guess the usual T/t parameters are in practice globally (?) mandatory (limited experience as a milkman .)

Rgds / Charles.C

The classification of PRP as a CM is obviously debatable as per above description. There has previously been discussion over this (the Didier Blanc ISO publication is helpful if you wish to search here). Maybe can consider PRP as an "over-process" CM.

[adamelanie]

I struggled too in the past months for the same topics and this is my conclusion:
I've considered as PRP all the applicable requirements of EU Reg. 852 and/or PAS 220. What is covered by these requirements I do not even consider that could enter my process as an hazard.
The controls on these are audits and records reviews.

Then when in the HA I detect an hazard the control measures are all the procedures and or the process steps that allows me to reduce the hazard.
Even if I'm not working in the milk industry I try with the above example: the hazard should be bacteria growing in the end product or something like that.

The control measure is the pastorization.
The monitoring of the control measure is Temperature & time of the pastorization step (taht are recorded).
Since for this step I also have strict limits to keep then I would consider the pastorization step as a CCP of the process.

The microbio analysis could be another monitoring but temperature and time are those essential for the fastest intervention on the process to keep it under control.
hope this helps!

[Sujit Nair]

Dear All,

Thanks for all the inputs. It has certainly helped to clarify.

Sujit

[Tony-C]

Dear Charles,

Thanks.

I need some more input on the below statement.

Whether end product testing can be considered as an Control measure.

Let us take a hypothetical case of milk processing, wherein Pasteurisation is the control measure. But, some people take the subsequent Alkaline phospahtase as the control measure. But I feel AP testing is a verification exercise.

How do we counter such assumptions.

Your comments please.

Sujit

As you have indicated pasteurisation is your control measure. Time/Temperature are your critical limits. Most plants have automatic monitoring and divert which should be tested before start up. A phosphatase test is useful as verification but could also indicate a failure not related to time/temperature such as cross contamination from raw milk in the plant.

Regards,

Tony