Correct Procedure for Downgrading a CCP to a CP?

When I decided to downgrade a CCP to CP, do I need to identify the CP on my decision tree? If that is require, how can I do that as a typical decision tree only leads to PRP or CCP?

When I decided to downgrade a CCP to CP, do I need to identify the CP on my decision tree? If that is require, how can I do that as a typical decision tree only leads to PRP or CCP?

Dear rotiboy,

The basic reason for downgrading is usually due to evaluated risk.

If there is no significant risk >>> no need for decision as to CCP ?

Codex does not define a control point. Do you ?

Rgds / Charles.C

Dear rotiboy,

The basic reason for downgrading is usually due to evaluated risk.

If there is no significant risk >>> no need for decision as to CCP ?

Codex does not define a control point. Do you ?

Rgds / Charles.C

That is why I couldn't find 'control point' in codex decision tree. Normally anything that is not CCP will be oPRP/PRP. Lets say metal detection. It is a control measure. It is not covered by PRP. Hazard won't exceeds critical limit due to auto rejection at the metal detector. Base on this criteria, a decision tree will not classify it as CCP. Can't I call it a CP (wiithout 'critical')?

Dear rotiboy,

If yr metal detector (MD) query is typical, I think you may hv misunderstood the decision tree and / or misunderstood the way to do a hazard analysis.

Assuming a Codex tree, Q2 is the classic route for a MD to be a CCP. (ie YY)

If you are doing a preliminary direct risk analysis, one approach is to ask oneself regarding the likelihood / consequences if there is a failure in the existing set-up. The (multiplied) choice for a MD is usually something like MM or MH which in most matrices will generate a significant risk.

I agree the logic chain is debatable, ie if you hv absolute trust in all yr system inputs / processes / environment, or you believe any failures will hv zero safety consequence, no CCPs or OPRPs will exist. This is a possible situation but not so common and not generally regarded as a typical result for metal detectors (despite the manufacturer's guarantee ).

The Codex tree is supposed to provide a nice auditor-friendly CCP generator in this case. Unfortunately, some other control measures are less smoothly conclusive (eg the baking step in bread making).

Of course, if you initially decide the hazard is not significant, i suppose you can self-define as many CPs as you like. Some people simply directly equate [an undefined] CP to oPRP, i personally find this a rather bizarre procedure but it happens.

Rgds / Charles.C

Just coming back to the original question of this post, is there a prefered way of documenting and justifying a CCP -> CP downgrade?
Historically, we have had 2 CCPs for our low risk, liquid products: checking the container and filtration. More than one auditor has told me that checking the container is not something that can be measured properly and is not a CCP but rather, a supplier assurance pre-requisite.
If we tighten up on the supplier guarantee that containers are supplied free of foreign bodies, we would still check them a control point but not as a CCP any more. If that is documented at a HACCP review meeting would that be sufficient? Thanks.

There is some mistakes, even by auditors...

If you define something is a CCP, it must stay. If you can't check it properly, you have to find an other way to check it.
Some people say "I can't check it, so it is not a CCP", it's a wrong way.

Into ISO 22000, you have CCP and oPRP. The major difference is that CCP has a critical limit : it is correct or not. For example, fridge temperature is not, for me, a CCP : If the fridge comes to 4.2°C, microbiological contamination of meat may stay under limits. Germs need some time to grow.
(note : i'm not saying temperature would not be checked...)

Dear D-D,

It's easy. You simply update the haccp system.

Theoretically this should be done at planned intervals (ie verification) but it is permissible (and presumably re-commended) to do it any time if you hv a valid reason (ie you suspect something's changed, eg yr viewpoint ). It involves explaining / re-validating the reasons for change. I've done it innumerable times, especially after audits.

This is one reason for the existence of the first page of yr manual, ie the revisions page. i hope you hv one.

I believe in ISO 22000 it's politely called "updating the FS management system", 8.5.2. ?

Rgds / Charles.C

Dear rotiboy,

On your question - the correct way to remove a CCP from your HACCP system? The following is an example of how things might work but needless to say it all depends on the actual process, risk etc which only you know best:

1. Redo your hazard analysis and risk assessment for the process step under question. (I'm assuming you already have one).

2. Ensure your assessment includes a) frequency of occurrence and b) adverse impact to give you your final RISK

3. In your case this will be the most likely reason for the removal of the CCP - in other words the risk has been reduced from HIGH or MEDIUM to LOW and therefore does not need to enter the CCP decision tree.

4. If this is the case you now need to support the above decision. For example, the CCP addressing foreign body contamination in containers could be supported by a review and analysis of the historical CCP checks i.e. the frequency of contamination detected in past checks. If this is low or non-existent then you can justify the reduction of the frequency of occurrence in your risk assessment. Produce a summary report on this analysis and include it in your HACCP review report. If the analysis, on the other hand shows a high frequency of contamination from the containers then you need to address the issue with the supplier, change your supplier or introduce a (critical) control step such as container pre-rinsing. This might be covered under the ‘Modification of the Step' in the decision tree.

5. In any event it is best practice to document and record in detail the steps taken in the review including HACCP team minutes, report and supporting analysis. These should be available to the auditor in a format that is easy and logical to follow.

George.