14 replies to this topic

[B. Nowak]

hello,
does anyone can help me with this case.
I have implemented HACCP with one CCP which is temperature.
Now HACCP Team decided that according to technical lterature there is no need to keep this CCP.
In this situation should I remove all procedures connected with this CCP , I mean corrective action, monitoring procedure.
if i dont have any Critical Control Point should I keep any records

[oronogirl]

Should you consider keeping it as a control point - thus still monitoring and adjusting to spec/control as necessary? [and of course keeping records!]

[B. Nowak]

we decided to change it into Quality Control Point QCP.
of course we'll monitore temperatur but temeprature monitoring can be a part of quality control, production and storage procedure.
There is no need to keep separate procedure- temp. monitoring, right?
the same situation with corrective action.
we have a genaral producedure for this.

Should you consider keeping it as a control point - thus still monitoring and adjusting to spec/control as necessary? [and of course keeping records!]

[Charles.C]

Dear B.Nowak,

Out of curiosity, what is the product / process ?

At least it is good that yr process has no significant hazards.

Rgds / Charles.C

[Shyguy77]

Your HACCP team may have ruled out to"techanically" call that step a CCP, but if its still a step in the process it must continue be evaluated for all potential hazards. These hazards (if any) must be controlled with pre-requiste programs to elimate or reduce the harzard so as to not cause a food safety concern. This must then be documented and validated through your records to prove it.
If this applies to your product then really the only change in that step to the process is in the title of if its called a "CCP" or not.

[Charles.C]

Your HACCP team may have ruled out to"techanically" call that step a CCP, but if its still a step in the process it must continue be evaluated for all potential hazards. These hazards (if any) must be controlled with pre-requiste programs to elimate or reduce the harzard so as to not cause a food safety concern. This must then be documented and validated through your records to prove it.
If this applies to your product then really the only change in that step to the process is in the title of if its called a "CCP" or not.

Dear jpredmore,

Getting a little bit OT perhaps so my apologies to OP.

I agree with yr comment and it is true that some companies try to maximise use of PRPs wherever possible despite the seeming contradiction to (HA)CCP terminology (everything can be subjective in HACCP!).

However the necessary documentation for PRPs can vary substantially depending on the specific standard used for certification (if any) and sometimes local regulatory issues.
One of the early attractions in using PRPs instead of CCPs was precisely to avoid / reduce "awkward" HACCP paperwork, eg at process steps like receiving raw materials or (then) emerging hazards like allergens. Similarly, ISO 22000 does not require validation of PRPs, only verification (in the Codex sense) which is understandable inasmuch as some PRPs are not exactly readily validated anyway, eg handwashing.

Taken to the limits, using PRPs may make the CCP a redundant concept altogether. Exit HACCP perhaps ??

Rgds / Charles.C

[Mr. Incognito]

Keep your records of what you had as a CCP even if you chose to make it something else with your data backing you up.

The reason is that in case an inspector asks to see it. If you then tell them your destroyed them all they may be skeptical of the actual reason why you got rid of the CCP. I would keep that documentation as long as you normally would have if it was still a CCP. That way they can't say you downgraded it because you were not recording it properly.

Also if you had to initiate a recall on a certain date that was when this was a CCP it is important to have all the documentation from the day it was made to provide a complete picture of everything that happened when the product was made.

[George @ Safefood 360°]

Dear jpredmore,

Getting a little bit OT perhaps so my apologies to OP.

I agree with yr comment and it is true that some companies try to maximise use of PRPs wherever possible despite the seeming contradiction to (HA)CCP terminology (everything can be subjective in HACCP!).

However the necessary documentation for PRPs can vary substantially depending on the specific standard used for certification (if any) and sometimes local regulatory issues.
One of the early attractions in using PRPs instead of CCPs was precisely to avoid / reduce "awkward" HACCP paperwork, eg at process steps like receiving raw materials or (then) emerging hazards like allergens. Similarly, ISO 22000 does not require validation of PRPs, only verification (in the Codex sense) which is understandable inasmuch as some PRPs are not exactly readily validated anyway, eg handwashing.

Taken to the limits, using PRPs may make the CCP a redundant concept altogether. Exit HACCP perhaps ??

Rgds / Charles.C

Charles you are totally right regarding HACCP. The concept of a CCP is quickly getting lost and therefore undermining the whole basis of HACCP as the core of food safety management. It is not just the issue of PRP's. Here are some other things going on...

• Seperate allergen risk assessments. Controls esstablished are not CCP's but PRP's (or whatever non CCP term you want to use) and yet allergens currently account for the majority of product recalls
• Vulnerability Assessments (VA) A new wonderful concept from FSMA. A risk assessement and hazard management system by any other name yet appears to be independent of HACCP.
• RIsk assessment of systems in addition to hazards under GFSI
• HACCP failing to identify non-food safety issues leading to a crises in the industry - horse meat

Where to for HACCP now? Time for something new, better, smarter... The King is dead, long live the King?

George

[George @ Safefood 360°]

Is the Temperature related to a cooking or heat treatment process? Or is it environmental, storage or core product temperature?

In any event, the posters are correct you may find that everything will remain the same except for a name change. If you are BRC certified you will need to validate PRP's (If my memory serves me well). You also need to review them as part of HACCP so what is the difference?

We are moving towards a real understanding of food safety management. Appropriate controls need to be applied for a Hazard(s) based on risk and not because of CCP trees that defy all my attempts of rational logic. Call it a CCP, oPRP, QCP or what ever you are having yourself.


Hazard -> Risk Assessment (Significance) -> Application of the appropriate control / monitoring program -> Validate

Why are we making it so difficult? In the end this is what we are doing without knowing it.

George

[Barrie@RJT]

Is the Temperature related to a cooking or heat treatment process? Or is it environmental, storage or core product temperature?

In any event, the posters are correct you may find that everything will remain the same except for a name change. If you are BRC certified you will need to validate PRP's (If my memory serves me well). You also need to review them as part of HACCP so what is the difference?

We are moving towards a real understanding of food safety management. Appropriate controls need to be applied for a Hazard(s) based on risk and not because of CCP trees that defy all my attempts of rational logic. Call it a CCP, oPRP, QCP or what ever you are having yourself.


Hazard -> Risk Assessment (Significance) -> Application of the appropriate control / monitoring program -> Validate

Why are we making it so difficult? In the end this is what we are doing without knowing it.

George

I totally agree George.

I'm still struggling with my BRC-required 'HACCP', even though for our slaughtering process I have no CCPs, and only 2 or 3 max in our processing plant.

The terminology is now more confusing than helpful - I just wish I could concentrate on properly moving the business forward in relation to food safety, and not continually finding myself bogged down with whether I should call something a PRP, oPRP, CCP, or some other freshly dreamt-up acronym.....!!

(I guess you can sense my frustration......?!!)

Barrie

[George @ Safefood 360°]

I totally agree George.

I'm still struggling with my BRC-required 'HACCP', even though for our slaughtering process I have no CCPs, and only 2 or 3 max in our processing plant.

The terminology is now more confusing than helpful - I just wish I could concentrate on properly moving the business forward in relation to food safety, and not continually finding myself bogged down with whether I should call something a PRP, oPRP, CCP, or some other freshly dreamt-up acronym.....!!

(I guess you can sense my frustration......?!!)

Barrie

Yes Barrie, and your frustration is shared on a global scale. This is not about HACCP bashing! It is about taking the collective experience of those who are using the Principles, Steps and Decision Trees and using this to make it better which can only lead to safer food products. CODEX principles are now in such need of revision that they are begining to stink...

There is too much focus on jargon, terminology and too much opinion on something that does not in reality matter. Simply put - a hazard exists, it is of a certain significance, we put in place the appropriate control, validate its effectiveness, keep the records of monitoring and review it all on a scheduled basis. Call the system Mickey Mouse's Guide to Food Safety or whatever floats your boat but please let us get on with the job of making our food products safer free from all this pointless distraction.

[LBS]

Hi,

even if it is not a CCP it still a Control proint (CP) that mean you need to keep all the records for the control it is very helpfull

good luck

[MCIAN]

I had the same issue here with Nowak.

Our original version of HACCP study included 1 CCP (molds) for the finished products.

The said HACCP study was 'scrutinized' by a food safety auditor during one of our second party audits and as a result, we conducted a general review of the hazard analysis and it turned out that the 'likelihood' based on past records is minimal. So everybody in the review panel agreed to downgrade the CCP to OPRP.

Right now, we are still monitoring the telltale humidity of the warehouse and provided the controls needed to bring it down to non-critical level for mold growth.

I believe the 'name' (CCP, PRP, OPRP) is not that important as much as the recognition that you identified it as a hazard and has actually done something to control it.

Let's live the spirit of the standard, not just the letters.

[Charles.C]

I had the same issue here with Nowak.

Our original version of HACCP study included 1 CCP (molds) for the finished products.

The said HACCP study was 'scrutinized' by a food safety auditor during one of our second party audits and as a result, we conducted a general review of the hazard analysis and it turned out that the 'likelihood' based on past records is minimal. So everybody in the review panel agreed to downgrade the CCP to OPRP.

Right now, we are still monitoring the telltale humidity of the warehouse and provided the controls needed to bring it down to non-critical level for mold growth.

I believe the 'name' (CCP, PRP, OPRP) is not that important as much as the recognition that you identified it as a hazard and has actually done something to control it.

Let's live the spirit of the standard, not just the letters.

Dear MCIAN,

Thks for the input.

I deduce your company are using ISO 22000.

As you no doubt know the topic of the difference between CCPs and OPRPs is still highly subjective after 8 years of the unrevised original standard. Possibly even more subjective than CCPs.

I won’t query yr FS assessment team’s conclusion since it depends on the specific details however I should just mention that some opinions exist that a hazard which is considered to have an insignificant risk (Lik. x Sev.) is not suitable to be categorised as either a CCP or an OPRP.

Perhaps a QCP is equally appropriate since IMHO, this label, in the most general sense, can be applied to a (non-Codex ) "hazard" of any type, whether related to safety or not.

Rgds / Charles.C

PS - @B.Nowak, Regarding yr original query, I think George's post# 9 is the key, it really depends on the details, eg what hazard the temperature control is relating to ?

[B. Nowak]

thank you all for response.
the process is storage, packing vegetables, wholesale fruits and vegetables.