9 replies to this topic

[J Young]

Hi

I am getting myself slightly confused regarding the pH of the cultured products within the dairy.

Whilst target levels are set for incubation periods and pH and therefore the risk is managed by positive release to a given criteria. The purpose for the pH is to achieve a quality attribute although the beneficial side affect is that at the given pH (4.5) the product shelf life can be extended past the duration of a fresh cream product due to the acidification causing a hurdle to certain micro-organisms.

Therefore to achieve the required shelf life and therefore control micro-growth / germination the pH is critical although the same could be said for the temperature control of chilled goods.

So i'm really sitting on the fence as basics like temperature control of fridges come within the prerequisites and GMP ongoing monitoring. Just not to sure wether the pH is within the critical CCP factor. Using the HACCP decision tree you can go down the route of critical to control growth or micro organisms!

Our production sheets are signed off with incubation periods and final pH so it is being monitored and recorded.

Would be really interested on other views and help.

Thanks in advance.
Justin

[Charles.C]

Dear J Young,

I assume you mean something like yoghurt.

You don't mention whether any particular standard is relevant. This can relate.

The yoghurt production thread below may interest you, this is oriented to haccp development under ISO 22000 -

http://www.ifsqn.com...dpost__p__39585

The haccp plan which I hv currently posted in above thread does invoke a pH-related control measure similar to that which you are referring. I set it as CCP for the risk logic reasons shown. In the published literature, designations as CCP or not vary, sometimes even depending whether a batch or continuous process is involved.

It also may depend on how you are specifically concluding that a control measure (or step) is associated with a CCP. Although i didn't use the Codex tree myself, would seem to me that this could support a CCP if applied.

As to the possibility of how / whether PRPs can interact with a haccp plan, this can IMO get quite subtle, particularly with respect to yr own definitions and over-riding haccp interpretations. i hv occasionally been criticised here for frequently describing the situation / conclusion of such aspects as highly subjective but that is still my prevailing opinion . You can see some discussion of "PRP/CCP" interplay in the yoghurt case in another thread. (Although the comments are iso 22000 directed, the same principle can apply to a traditional haccp plan) -

http://www.ifsqn.com...dpost__p__50725

If you are asking whether maintenance of low temperature for yoghurt is a PRP or a CCP (eg product environment after pasteurisation), most published opinions I hv seen do not give CCP (for reasons like the typical definition of PRP / it is not limited to one process step, etc) but again there is not 100% agreement. Similar queries occur for chilled storage of RTE raw vegetables.

Sorry if you are even more confused than before posting.

Rgds / Charles.C

[Tony-C]

Hi

I am getting myself slightly confused regarding the pH of the cultured products within the dairy.

Whilst target levels are set for incubation periods and pH and therefore the risk is managed by positive release to a given criteria. The purpose for the pH is to achieve a quality attribute although the beneficial side affect is that at the given pH (4.5) the product shelf life can be extended past the duration of a fresh cream product due to the acidification causing a hurdle to certain micro-organisms.

Therefore to achieve the required shelf life and therefore control micro-growth / germination the pH is critical although the same could be said for the temperature control of chilled goods.

So i'm really sitting on the fence as basics like temperature control of fridges come within the prerequisites and GMP ongoing monitoring. Just not to sure wether the pH is within the critical CCP factor. Using the HACCP decision tree you can go down the route of critical to control growth or micro organisms!

Our production sheets are signed off with incubation periods and final pH so it is being monitored and recorded.

Would be really interested on other views and help.

Thanks in advance.
Justin

Hi Justin

There are 3 critical factors here:

1. The final pH after incubation

2. The speed of acidification - normal incubation times/pH profiles should be established for microbiologically sound product. If a 'vat' is 'slow' then there is a risk of Staphylococcus aureus growth and toxin production which will not be removed by a subsequent step and as such any 'slow vat' should be held and investigated.

3. Cooling to refrigeration temperature - If held at incubation temperature there is potential for Yeast & Mould growth and again toxin production.

Subsequent chill chain control is normally considered a PRP

Regards,

Tony

[J Young]

Thanks all for the response, i think as mentioned the codex tree can be interpreted with slightly different opinions dependent on the designers risk management and interpretation of specific controls. Some would say that all controls post pasteurization should be CCP's as no further treatment is carried out on the now RTE product and others may assume that they can be effectively controlled by the PRP - this is where there is little clarity and auditors also have their opinions !!
Which side of the fence to lean on - well the PRP could be less hassle perhaps to manage although if you go down the CCP route then you could be over cautious but at least all bases are covered and the product has a strict managed production path (which i know it should have anyway!).
It would seem its down to own interpretation and potential control measures.

[Tony-C]

Thanks all for the response, i think as mentioned the codex tree can be interpreted with slightly different opinions dependent on the designers risk management and interpretation of specific controls. Some would say that all controls post pasteurization should be CCP's as no further treatment is carried out on the now RTE product and others may assume that they can be effectively controlled by the PRP - this is where there is little clarity and auditors also have their opinions !!
Which side of the fence to lean on - well the PRP could be less hassle perhaps to manage although if you go down the CCP route then you could be over cautious but at least all bases are covered and the product has a strict managed production path (which i know it should have anyway!).
It would seem its down to own interpretation and potential control measures.

Just so you don't confuse other members there are quite clear CCP's for fermented dairy products in relation to pH and speed of acidification. From memory there is a JS policy on the 'Control of Staphylococcus aureus in fermented dairy products' that you will find useful - if you can't find it on the forums I will see if I can find an old copy to post.

Regards,

Tony

[Charles.C]

Thanks all for the response, i think as mentioned the codex tree can be interpreted with slightly different opinions dependent on the designers risk management and interpretation of specific controls. Some would say that all controls post pasteurization should be CCP's as no further treatment is carried out on the now RTE product and others may assume that they can be effectively controlled by the PRP - this is where there is little clarity and auditors also have their opinions !!
Which side of the fence to lean on - well the PRP could be less hassle perhaps to manage although if you go down the CCP route then you could be over cautious but at least all bases are covered and the product has a strict managed production path (which i know it should have anyway!).
It would seem its down to own interpretation and potential control measures.

Dear J Young,

I am still not sure what CD products you are primarily referring. I presume we are referring to Non-ISO haccp.

The reasons for choosing (assuming a free choice) of how to incorporate PRPs within a haccp system are varied. One important reason for the introduction of PRPs, per se, was to reduce the number of "generic" CCPs, eg sanitation-related, and thereby improve focus on specific, significant process hazards. (But equally not to lower the criticality of the PRPs themselves).

I believe PRP terminology did not exist at the haccp "beginning".

There is at least one post-2000 text book on CDP whose haccp system chapter contains zero PRPs as currently defined although they do (frequently) mention GMPs.
There are companies whose expressed policy (philosophy?) is to use PRPs to control risks wherever possible.
And others who state that some significant risks can only be controlled by PRPs.

Your reference to caution rightly implies a risk calculation is considered relevant. However yr comment also implies that PRPs are not be used to handle significant risks. This is not a uniformly followed rule. It might be argued that the choice is irrelevant, the objective is to permanently control significant risks although this obviously requires a rather flexible interpretation of the usual definition of a CCP.

There are existing haccp plans for some CDPs which only contain 1 CCP. And others with a lot more. And it surely also relates to the actual items involved.

I sort of agree with yr last sentence if you replace "own" by "probable risk".

Rgds / Charles.C

[J Young]

Thanks for all your comments its always interesting to hear other peoples comments. The system we use is very controlled and all the accountable measures (pH, incubation time, strike temp/time, cooling period etc) are detailed and recorded through data loggers and manual checks / sign off. I was just really looking into whilst the production is safe and control measures are in place would the finial pH be a ccp or just controlled through PRP/GMP? The reason i ask is that we have the final distribution temperature cold store as a ccp and i note that others would have this as a PRP.
Could someone clarify this to me as the finished product will be high risk short shelf life i would assume that the pre-dispatch storage temperature is a ccp?
would be grateful of your comments as ever. thanks.

[Charles.C]

Dear J Young,

would the finial pH be a ccp

I think you are getting confused. A (traditional) CCP is a point or something similar, eg step, in a process. Perhaps you meant critical limit.

Tony has given his a general opinion in post #5 if you are referring to a (product unspecified) fermentation step. In my own survey of (located) yoghurt haccp plans, I found a mixture of Yes/Nos.

You have referred to CDF as high risk. This is open to interpretation.

For illustration see these variously sourced compilations / interpretations of the risk status of some dairy / general foods -

 relative risks of dairy products.png   151.6KB   9 downloads
 Potentially hazardous and non-potentially hazardous foods.doc   28.5KB   30 downloads
 Compilation of Lower and Higher Risk Foods.doc   31KB   27 downloads

I have little doubt that other opinions can be found elsewhere.

Rgds / Charles.C

[Tony-C]

The reason i ask is that we have the final distribution temperature cold store as a ccp and i note that others would have this as a PRP.
would be grateful of your comments as ever. thanks.

Hi Justin

Whilst pH and acidifcation rate is a CCP, storage and distribution temperatures would normally be PRP's.

Regards,

Tony

[Charles.C]

Dear J Young,

Yr posts have contained musings regarding the philosophical aspects of CCPs / PRPs.

Historically, the timeline tendency in HACCP has been to implement control activities for “hazards” via PRPs rather than at CCPs. This, de facto, requires a re-interpretation of the meaning/usage of PRPs in some cases, eg with respect to hazard risk status. ISO 22000 recently added one more (intermediate?) option via OPRPs.

I have found the two links below to contain quite useful (and rare IMEX) insights into the subtleties of (traditional) CCP / PRP discrimination issues. It is also a reality that some publications contain examples which are directly contrary to their suggested guidelines.

http://edis.ifas.ufl.edu/fs140

http://www.ifsqn.com...h__1#entry16133

Rgds / Charles.C