4 replies to this topic

[Konstantinos]

Through the HACCP study (Blending juices), we have identified the filtration as CCP (to remove contamination particles).
- We use different size of filters for blending the juices or purees. However, we can not justify our decision for going 4mm or 2mm or even 10mm in some cases. Several auditors have challenged the selection of the filters.
- During the winter time, due to viscosity of the products certain filters can not be used. Can we produce something alternative plan/filter selection for the winter?
There is no option of heating the product. Can anyone help on this matter, please?

[George @ Safefood 360°]

Is this a case of justifying the completely obvious? Sometimes when it comes to HACCP it is. I have experience with this area of inline filters for juice products and the simple fact is you go as fine on the filter size consistent with being able to produce the product efficiently. When production comes to a hault and pumps start burning out then you have your justification.

But this area drives auditors of HACCP crazy because the mesh size is ultimately driven by issues other than what should be in place to ensure product safety. It is not straight forward like a time and temperature specification to kill Salmonella. When you tell an audit that viscosity of juice determines the size of a physical contaminant in a product they get very uneasy.

Over the years I got tired of auditors giving their opinon on this area and more over I got tired of changing the HACCP plan for this step every time we had an audit. Why, because at the end of the day it never changed the fact that a 4mm mesh filter had to be used on a particular product due to it's viscosity - regardless of my own or any auditors take on it.

Eventually I determined the step as NOT A CCP and saved myself a lot of pain. The product was still the same standard and the world did not come to any end.

In this case you need to justify the control and mesh size based on the technical limitations of the step. Tesco for example recognise this in their standards. There are limitations but you are bringing down the risk to an acceptable level. This is the approach you need to take.

[Cobus]

I agree with George completely.

You define the scope and the critical limits of your CCP within the limitations of your process. It might not completely address the specific hazard but you could use a combination of other controls to reduce the likelyhood of the hazard. We can only do the best we can. The world can do with a lot more practical HACCP.

Cobus

[D-D]

I assume the issue with filter size is related to purees rather than juices which are fairly low viscosity if not concentrated (?).
Just out of curiosity, if you worked it out of the plan by saying it wasn't a CCP, what was in place for foreign body control? I suppose you could say filtration was a prerequisite if you do it for everything as a matter of policy but wouldn't you still need to justify the filter size as consistent with recognised studies in this area e.g. 7 mm control for FDA / 2 mm for Dutch work. Not my area, just interested to learn more.

[Charles.C]

Dear George,

Sort of extension of previous post.

Not my area also so I’m somewhat unclear if the “contamination” is typically metallic, natural, or simply generic. (if metallic I would hv thought a later MD would become the CCP anyway?). Similarly the actual contaminant size expected here is not mentioned though I can understand an auditor fixating on some “validated” sieve reference aperture.

“Filtration” as a CCP is a source of endless, unresolved, debates, here and elsewhere. Not unlike metal detectors. As you intimated, the inclusion into the haccp plan or “demotion” to prerequisite seems to be often a matter of expedience rather than risk assessment (eg need at least one manageable CCP / codex tree-friendly). Whether a prerequisite can logically be associated with a significant risk hazard is also debated but the zigzag thereby avoiding awkward critical limits / validation, etc is certainly well entrenched (eg allergens, to name but one of many).

Couldn’t find any mention of filter limits in TFMS ver.4. I deduce the viewpoint is that for the type of system under discussion, they simply accept “contamination” > 4mm is “unsafe”. Perhaps even >7mm ? This seems uncharacteristically nice of them even if “force majeure” prevents haccp validation.

Rgds / Charles.C