HACCP and the Shipping Step
We have been informed that the USDA does not have jurisdiction over the product once it leaves our back door. We have also been told that is not true, that as long as we have possession of the product USDA has jurisdiction. Our HACCP states that "Refrigerated delivery trucks are kept at temperatures that will not allow for hazardous pathogen growth. Daily truck logs are kept to record temperatures at each delivery stop." (Not Product temperature. We do not state a CCP at this step. Does anyone have any experience with this? Can we remove this step from our HACCP plan?
Dear Jcchaser,
It depends upon you product and risk assessment. Are there other refrigeration steps to minimize micro growth? Is their a heat treatment, pasteurization, retort etc of the product? Companies that store and ship refrigerated do not recognize refrigeration of trucks as a CCP. You may have to revise your statement but it does depend upon your risk assessment.
Dear jChaser,
Our HACCP states that "Refrigerated delivery trucks are kept at temperatures that will not allow for hazardous pathogen growth.
Yr product range / temperatures are unstated but, for example, if L.monocytogenes is one of the potential resident micro. species, the above comment implies that yr trucks' refrigeration systems are, at a maximum, maintaining both environment / product temperatures below 0degC. Really ?
Rgds / Charles.C
Good day,
I am new to this forum and I am based in South Africa.
I am not familiar with USDA requirements. In our company's HACCP system, cold chain maintenance is a PRP and not a CCP. Fridge temperature records are only reliable if your truck fridges are properly designed and packing is done as spelt out in the design. The fridge temperature can be taken as the product temperature when an equilibrium has been reached (Its important to validate equilibrium times for different products).
Your HACCP scope, flow diagram and HACCP plan are all linked together and a change to your scope affects other areas. If your scope includes delivery then truck temperature recordings form part of you HACCP verification.
Regards,
Dear Jcchaser -
All the above comments are valid HACCP concerns; however, from a US regulatory standpoint, USDA FSIS expectations are that you consider any food safety risks that may arise before, during, or after your processing activities. 'After' is particularly important when you still own the product that is being transported or stored. If you ship to a cold storage facilty - yours or public - you normally also have that storage activity shown as a HACCP step also. Typically, USDA inspection has allowed me to no longer consider product as mine when ownership has passed to the next downstream step - broker, customer, cold storage warehouse in someone else's account, etc. If you are using refrigerated delivery trucks, then I assume that the product is still yours until unloaded and the BOL is signed, thus responsibility would also still be yours.
You do not have to specify any food safety hazards if none are identified during your Hazard Analysis...but you do have to show that you did assess. It appears form your question that someone in the past considered the potential for pathogenic biological growth to be a potential hazard; and therefore, temperature monitoring is required. If your hazard analysis does not support this determination, then you can change your HACCP program accordingly to match your decisions.
Dear KTD,
Rather fascinating info., especially for the non-USA reader, I'm sure. Thank you.
I would suspect FSIS's position is out-on-their-own on this one. Including USFDA. However if haccp is, as frequently stated, correctly (safety) applied at the point of consumption then they do have a "point". :smile:
From an operational POV, it appears FSIS expect the processor (and QA) to have powers of King Canute proportions.
Rgds / Charles.C