Dear All,
I suggest the last two posts are both feasible and reflect alternative viewpoints on implementation of PRPs. Consider -
I. Determining CCPs
In general, CCP determination involves identifying and characterizing the hazards, the control measures, and the processing steps where control is applied. Thus, it is imperative that the HACCP team revisit and re-evaluate the Hazard Analysis as well as the Flow Diagram.
If a significant hazard that is reasonably likely to occur is identified in the Hazard Analysis, it must be controlled somewhere in the food processing and handling system. Due to the rigorous HACCP requirements for setting appropriate CLs and monitoring, there are certain hazards in certain situations which are more appropriately controlled by prerequisite programs. This has been the subject of some debate and has led to two approaches in dealing with such hazards. While they differ philosophically, the end result of these two approaches is similar.
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Approach A: This approach is used by some HACCP auditors in the regulatory and private sector. It dictates that a hazard deemed significant in the Hazard Analysis must be controlled at a CCP. It then follows that a hazard which is, in fact, managed by a prerequisite program is considered not "reasonably likely to occur" because of the prerequisite program.
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Approach B: In this approach, prevention and control of identified significant hazards can either be at a CCP or through rigorously applied prerequisite programs.
No set number of CCPs is required in HACCP. Rather, CCPs must be determined for each specific food processing and handling system and be appropriate to that specific system. Having too many CCPs could unnecessarily encumber and burden the implementation of the HACCP plan. Conversely, having too few CCPs could jeopardize food safety.
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FSHN07-04_FS140_ Hazard Analysis.pdf 57.03KB
75 downloads)
Going back to the metal detector- specific customers ask that this be a CCP but the cleaning and maintenance SOP's and records should eliminate this a CCP point since with regular and detailed cleaning and maintence there should be no metal shavings/bits present in the machinery that could get into the product
See section D in above attachment.
Additionally, in some industries, eg seafood, the USFDA's prescriptive approach virtually defines that a step where possible
metal contamination is appropriately controlled is a
CCP for specified process operations/equipment.
I think the reality is that there are a lot of possible permutations in the presentation of hazard analyses / selection of
CCPs. The parallel use/definition of SOPs, SSOPs, GMP, GHP etc can further overlap/blur the issue.
Rgds / Charles.C