Can Recall procedure be considered as a CCP?

Hi everybody,

Heard an interesting point of view / proposal today that a company's recall procedure should be classified as a CCP!

Has anyone else come across similar views or does anyone do this in practice?

Given the definition of CCP as "CCP : A step where control can be applied and is essential to prevent, eliminate or reduce a food safety hazard ro acceptable levels" .... surely treating product recall as a CCP is like trying to shut the stable door after the horse has bolted and is an admission of failure that you haven't control your process properly?

Anyone any views on this?

Thanks!

DP2006

Hi everybody,

 

Heard an interesting point of view / proposal today that a company's recall procedure should be classified as a CCP!

 

Has anyone else come across similar views or does anyone do this in practice?

 

Given the definition of CCP as "CCP : A step where control can be applied and is essential to prevent, eliminate or reduce a food safety hazard ro acceptable levels" .... surely treating product recall as a CCP is like trying to shut the stable door after the horse has bolted and is an admission of failure that you haven't control your process properly?

 

Anyone any views on this?

 

Thanks!

 

DP2006

Dear DP,

It’s in  a grey area but other than a pure corrective action, in traditional haccp I think it’s usually categorized as a PRP if anything (sort of facility-wide / support program?), but  it may depend on the individual viewpoint, eg  –

Pro-PRP

nn2 - prp recall.png   35.25KB   5 downloads

nn1 - JIFSAN PRPs for GMP.pdf   893.88KB   40 downloads

Con-PRP

·  Should a recall procedure be part of the PPs?

A: The industry may choose to include its recall procedure in its HACCP system but this is not a requirement of the Grade "A" PMO. The plant must be able to quickly remove product from commerce when it is injurious to health or it is otherwise adulterated.

 

http://www.fda.gov/F...P/ucm121259.htm

Or were you trying to involve iso22000 ? :smile:

Rgds / Charles.C

Hi Charles,

Thanks for your reply.

I will add that ISO22000 is also part of the picture!

From your experience and point of view, how do you see this changing the scenario?

Thanks,

DP

Just off the top of my head it sounds strange to me. 

I've always considered CCP's to be part of the regular process. Wouldn't be so great if recall's were a regular part of your day.

Hi Charles,

 

Thanks for your reply.

 

I will add that ISO22000 is also part of the picture!

 

From your experience and point of view, how do you see this changing the scenario?

 

Thanks,

DP

Dear DP,

Well, in iso22000, recall (nominally included within “withdrawal”) has its own entry (7.10.4) but as per PAS220 it is clearly categorized  as a prerequisite for FSSC22000. Moreover the two sets of requirements are overlapping.

Not quite sure where that leaves one ? Ignore PAS220 for the first and cover both for the second ?? :smile:

Rgds / Charles.C