Hi George.
Thank you for your explanation; that's all correct what you say, and Ozone is in place to reduce the organic content.
But I have headaches because chlorination is in place to kill bacteria (fecals and others), but is less efficient than ozone ! So it is questionable for me if is more important to figure as CCP the Ozonation-step to kill "bacteria" (which are hard-to-die with the NaClO alone, i.e. oocysts) or only a CCP for Chlorine.
The parameter "efficiency" can not justify a CCP-step ?
Thank you,
Joe
Hi Joe
I have to agree with Charles about the CODEX decision tree. For me it should consigned to the scrap heap of history and your post is simply more validation for me. Nonetheless, it is what we have to use and like all good subservient
food safety specialists we need to make it work in some way.
First of all 'chorination is less efficient than ozone'. Have you validated this claim? If so why not turn off the chorine pump and save a lot of money?
HACCP validation serves a purpose including the avoidance of operating a
CCP which is not required. I am sure there is a reason other than it has always been that way... In some regards your issue may not be the
CCP decision tree but the principle of validation, the need to review your
HACCP plan and so on.
The history of how this process design came into existence would be helpful. I assume the Chorination step was there first and then someone decided to address the issue of THM which led to the ozonation step. Now you are looking at it in a more comprehensive way and in the context of pathogenic bacteria.
Here is an other interesting point - if you were applying the Codex Decision Tree to the Ozone step and somehow managed to get to Question 4 ' Will a subsequent step eliminate or reduce the hazard to an acceptable level?' you may answer this as YES and therefore it is Not a
CCP. Problem solved. A later step (Chorination) is designed to address this. But then you might say to yourself is Ozonation specifically designed to address the pathogenic hazard? You may well say Yes - CCP. It can go a number of ways. (If CODEX had to actually use this decision tree maybe we would have had an improvement long ago
)
I think you need to ask yourself the following question? Do we need chorination to control the hazard?
If you do then you do not need ozonation as a
CCP. Ozonation was not put in place for this purpose or lets say it another way the process step was not specifically designed to control this hazard (as per the
CCP decision tree logic).It was designed (in your context) to control another hazard - THM. Keep it simple and true to the Decision Tree.
Now remember, you put in place the ozone stage to control THM. If you remove the chorination step then you will remove this issue of THM formation and therefore do not need the ozone step, at least for this purpose or design. You will need one or the other for pathogens. You may decided based on validation that you do not need the chorination step. This will give you one
CCP, one less expensive control step and reduce the risk of THM formation dramatically. On the face of it this looks like the sensible option for your
HACCP team to review, validate and make a decision on.
This is only general advice based on very limited information but I hope it helps you in your deliberations.
George
