Control based not source based. Hmm. Not sure I get your point here. We are after all all about defining the hazard in a way that the control measure is obvious are we not?
How I was taught HACCP, let's use two examples.
"Introduction of Staphylococcus aureus enterotoxin due to a slow vat as a result of incorrect starter culture addition".
Control measure. Correct starter culture addition and monitoring via total acidity testing of vat, correct temperature control of vat, (control would all be around the growth of the right culture to restrict the growth of S. aureus as well as other controls around hand hygiene etc in the area). Vat acidity development would be a CCP.
Or I could have.
"Presence of Staphylococcus aureus enterotoxin due to incorrect controls applied by cheese supplier."
Control measure. Correct controls applied by cheese supplier. Monitoring, delivery assessment of CoAs. Would not be a CCP.
Should either be in chemical or biological categories? What would you do? Would it change if it was a mycotoxin instead? Why?
Either way, does it actually matter as long it's being considered? Would you raise a non conformance if it was in the "wrong" category and you were auditing a supplier?
In the first case ,Introduction of Staphylococcus aureus enterotoxin due to slow vat I would view the hazard as biological, with controls clearly within the process (starter addition, temperature control, vat acidification). In that context, monitoring acid development as a
CCP makes sense because we are actively preventing toxin formation in-process.
In the second example (Presence of Staphylococcus aureus enterotoxin ) due to incorrect controls applied by cheese supplier the hazard, as assessed at intake, is the presence of a toxin, which is chemically stable and not something we can eliminate or reduce further through processing. Control therefore shifts upstream (supplier approval, CoAs, delivery checks), and I agree this would not be a
CCP. While the origin is biological, I would typically categorise the hazard as chemical at this stage because it is a pre-formed toxin.
I think this distinction becomes clearer with mycotoxins ,once present, they are universally treated as chemical hazards, regardless of their biological origin, precisely because control is preventative and supplier-based rather than process-based.
So to your broader question ,does the category matter? From a food safety outcome perspective, probably not what matters is that the hazard is identified, assessed appropriately, and effectively controlled. However, from an audit and
HACCP integrity perspective, I do think categorisation matters in sofar as it demonstrates understanding of where control actually exists,whether a
CCP is justified,
and whether controls are realistic and effective.
If I were auditing a supplier, I wouldn’t raise a non-conformance solely because a toxin hazard sat under a different category if the risk assessment and controls were robust. I would raise one if the categorisation led to inappropriate control decisions (e.g. treating a pre-formed toxin as something that could still be “controlled” later in the process).
So for me, categorisation is a tool ,not the objective but it should still logically align with the nature of the hazard and the point of control.
Happy to discuss further always good to sanity check these grey areas.
