Hi Sha
The objective of
HACCP is to identify and control food safety hazards. In order to use the principles of
HACCP (CODEX in the case of the BRC) it is important to understand the product and the various intrinsic and extrinsic characteristics that make the product safe or unsafe.
Your process concerns the packing of a pasteurized juice product using a TetraPak system. You do not state clearly if the process is aseptic but there is sterilisation of the packaging prior to forming, filling and sealing.
An important point about this process. The primary objective is one of shelf life extension (Non Food Safety). Juice products are inherently subject to short shelf life from yeasts and moulds (low pH). The pasteurization process coupled with aseptic packing is an effective means of extending shelf life of these citric juice based products without the need to use chemical preservatives e.g. SO2. The temperature you are using to pasteurize will tell you a lot about its objectives.
Pasteurization is typically 72oC for 15 secs to obtain a lethal reduction of a specific target pathogen. If you are up to 90oC the objective here is to kill various yeasts than can cause spoilage i.e. shelf stable product. Of course it will also kill pathogens in the process since it will more than exceed a 5-log reduction in most target pathogens. In short depending on the temperature of heat treatment it may be a
CCP. If the treatment is for a 5 log reduction included it as a
CCP. If heat treatment is designed to produce shelf stable product you can consider leaving it out.
I think it is more than acceptable to deal with CIP as a operational PRP and not as
critical control points.
Other
CCP's that may be included are patulin, residual chemicals or heat stable toxins associated with yeasts and moulds. But strictly speaking these are issues relating to primary production and harvesting and should be addressed prior to you receiving the whole fruit / concentrate whichever is applicable. I would need to know more about your process scope to advise further.
The FDA Juice
HACCP Reg is a useful document. But you should be aware that the Regulation does not always follow the principles as set out in CODEX (BRC cited) This is not unusual for regulatory bodies who prescribe
HACCP rules for various product groups e.g. meat and seafood.
In summary you will be looking at 1-2
CCP's with heat treatment most likely being one of them.
In my opinion CIP will not be part of your
CCP's
George