6 replies to this topic

[scppvjune]

Hello,

I got question about the timeframe to review CCP records.

Based on 'Fish and Fishery Hazards and Controls Guidance, 4th edition' from US-FDA website, it seems the timeframe to review CCP records is "within one week of preparation".

Based on 'Code of Practice for LACF (CAC/RCP 23/1979)' from US-FDA website, it seems the timeframe to review all processing and production records is "not later than one working day after the actual process".

Therefore, I would like to ask your comments/ideas what timeframe should be stated in the HACCP plan for record reviewing (one of the verification methods).

Thanks in advance for all comments/ideas.

[Charles.C]

Dear scppvjune,

 

Yr direct / local interest may well be over-ridingly relevant as per yr examples (presumably neither example was validated ?).

 

Generally It may minimally depend on what you are specifically talking about, eg the CCP monitoring frequency, eg one measurement per day.

Theoretically  I suppose the timeframe is related to above, the specific item / known consistency / potential consequences etc, ie risk-based. Just like everything else.

 

Regardless most people / organisations  seem to quote one number / maximum period. I don't recall offhand whether most private standards specify. i suspect not.

 

I usually implement a mixture of ongoing / 24 hrs but state the latter to avoid arguments.  In reality, this can on occasion have a (+)  tolerance. In practice, from memory i have seen up to one week quoted, this always seemed rather futile to me but still seemed to pass auditorial scrutiny unless specifically out of textual compliance. Maybe other more intangible factors can be involved, eg siesta.

 

Rgds / Charles.C

[Mr. Incognito]

scppvjune,

 

I worked in a pasta factory where the operators filled out their CCP record every 4 hours plus one at startup and shutdown, I believe, on a 12 hour shift there were about 5 entries on each sheet.

 

At the end of the work day (two shifts) the supervisor collected them all and then dropped them off with our CP sheets to the quality lab in the morning.  Every day we reviewed all of the CCP and CP records to ensure that there were no errors.  

 

The reason we did it daily was because if you violate your CCP your system is out of control for that line and the product was potentially dangerous to consume.  So one of the quality techs, typically the 2nd shift person, would review all of the records from the day before and stamp, sign, and date them then file them away in our records cabinet.

 

If it's possible I suggest that CCP records, at least, are checked daily.

[Tony-C]

Hello,

I got question about the timeframe to review CCP records.

Based on 'Fish and Fishery Hazards and Controls Guidance, 4th edition' from US-FDA website, it seems the timeframe to review CCP records is "within one week of preparation".

Based on 'Code of Practice for LACF (CAC/RCP 23/1979)' from US-FDA website, it seems the timeframe to review all processing and production records is "not later than one working day after the actual process".

Therefore, I would like to ask your comments/ideas what timeframe should be stated in the HACCP plan for record reviewing (one of the verification methods).

Thanks in advance for all comments/ideas.

 

Hi there,

 

"not later than one working day after the actual process" seems reasonable but I would specify before product release as whenever possible I like to positive release product.

 

Regards,

 

Tony

[Mr. Incognito]

That's an important point to drive home.  When you are releasing your product into the food stream your are expected to know it's safe to be eaten.  Without the knowledge if CCPs were performed correctly and passed you cannot be sure that your product is safe.  Otherwise we would be living in the reactive food safety environment that existed before food safety standards.

[scppvjune]

Thank you for all feedback.

I asked due to one of the buyer auditors comments to change the review frequency to 'within one week' according to the hazard guide. The original timeframe on the HACCP is daily. The auditor said the reason is the authorized person might not be able to follow the timeframe (daily) during the weekend or long holiday, so one week will allow enough time.

Then, another one comments that the timeframe should be within one day since the products are canned seafood.

So it is kind of a bit confused. :)

[Urban Explorer]

Any records pertaining to CCPs must be reviewed prior to shipment, so you would look at this at your pre-shipment review.

 

Regs state minimum of weekly.  However, if you produce today and ship tomorrow, then it would be daily.

 

Generally, state in your plans what the regs say and you can always do things more frequently if needed.  Because if you say daily and you miss a day, then you've just violated your plan.