12 replies to this topic

[Skye]

I would be interested in people's views on whether freezing ready meals and snacks should be a Critical Control Point or be controlled as part of the company's prerequisite programme.

[Charles.C]

Dear Skye,

 

I assume a typical interpretation of the word "freezing".

 

Accordingly, IMO, the freezing process is neither a CCP nor a PRP.

 

Rgds / Charles.C

[cazyncymru]

When you say freezing, do you mean blast freezing?

 

Cazx

[Skye]

Yes Caz,

The product is blast frozen down to -7°C within 4 hours and is then allowed to freeze down to -18°C to -22°C.

Skye

[cazyncymru]

Then I would say its a CCP if your saying it has to be -7 in 4 hours

 

Cazx

[Charles.C]

Yes Caz,

The product is blast frozen down to -7°C within 4 hours and is then allowed to freeze down to -18°C to -22°C.

Skye

Dear skye,

 

Perhaps you could validate the implication  that this criterion is necessary for producing a microbiologically safe food?

 

Rgds / Charles.C

[Skye]

Dear Charles,

The cooking and blast chilling stages of the process are CCPs and blast freezing has always been identified as a CCP. However, the freezing process is not continuously monitored so as the stage is essentially to prolong the product shelf life the company want it to be a PRP rather than a CCP. I have validated the freezing process as part of the HACCP system.

Skye

[Charles.C]

Dear skye,

 

I could provide some,  qualitative support for a CCP  for the “freezing process” (one can justify almost anything given enough time ) but, AFAIK, the current consensus is typically the opposite (although my experience is mainly limited to certain product areas).

I think a freezing CCP was a more common occurrence in older haccp plans where multiple CCPs  were relatively encouraged with/without detailed risk assessments. And often without validations.

At one time, freezing (overnight +?) in Cold Stores was also quite popular. Cheap but not exactly recommended.

 

I think a sort of related debate occurred in the RTE, cooked-chilled meat business (not my expertise) which AFAIK do tend to have some official microbiological cooling control times/temperatures. In fact, I think decently powered, un-overloaded,  air-blast freezers were the only way to routinely match some of the critical limits involved, despite not being an exactly standard restaurant feature perhaps. i suppose in theory such data could be the initial control requirements for a freezing procedure.

 

Regardless, I cannot at the moment recall ever seeing any numerical, “officially” validated, critical temperature / time limits for a freezing process. Hence my query.

I would think the auditors might pose the same question ?

 

Rgds / Charles.C

 

PS - I suspect the validation of freezing as a PRP will not be so easy either.

(don't see any mention in PAS220 ?)

 

(added)

 

PPS - i suppose the (strictly HACCP) decision inevitably comes back to things like the Risk Assessment / interpretation of the context requirements for a CCP (and maybe OPRP) / any pre-defined factors (eg local regs. /  Prerequisite Programs).

 

Risk assessments should be locally driven, eg  known antique equipment could cause abnormally slow freezing speeds and thereby a validatable increased likelihood of significant pathogenic microbial growth. However this would presumably indicate that a PRP (equipment maintenance) program has already failed and requires appropriate modification / corrective action.

[Charles.C]

Dear Skye,

 

After some searching, here is an example of temperature-time limits which could be used to validate the possibility of a significant microbiological hazard for certain RTE seafood products / freezing processes.

 

IMEX, typical freezing procedures will readily comply with the above data (AFAIK,  these limits are for cumulated process steps).

 

Nonetheless, I can recall a few factories where, in order to minimize electrical costs, batch freezers were only initially activated after complete loading. This might have generated a significant hazard.

 

 Seafood, pgs 417-18,420-21.pdf   176.03KB   165 downloads

 

Rgds / Charles.C

[Skye]

Hi Charles,

Thank you for your very helpful advice. I have decided to make freezing a PRP and have validated and verified the process step as such for each product group. I think that I now have enough information to back up the decision if necessary.

Best Regards
Skye

[Charles.C]

Hi Charles,

Thank you for your very helpful advice. I have decided to make freezing a PRP and have validated and verified the process step as such for each product group. I think that I now have enough information to back up the decision if necessary.

Best Regards
Skye

Dear Skye,

 

Thks yr feedback.

 

I think many “experts” will say it’s a question of “perspective”. Fancy term for a “matter of opinion”.

 

Just as an illustration, I hv enclosed extracts from 3 general haccp resources, the first I infer as not agreeing with yr decision for PRP, the second, implicitly, in favour.

 

(1)  pr1 - CCPs vs PRPs (and OPRPs).pdf   100.68KB   177 downloads

 

(2)(i)  pr2 - HACCP - Prerequisite Programs.pdf   60.83KB   159 downloads

 

(2)(ii) (a corollary from GMP segment of  2i) –

 

All food manufacturing, including packaging and storage, shall be conducted under such conditions and controls as are necessary to minimize the potential for the growth of microorganisms, or for the contamination of food. One way to comply with this requirement is careful monitoring of physical factors such as time, temperature, humidity, aw, pH, pressure, flow rate, and manufacturing operations such as freezing, dehydration, heat processing, acidification, and refrigeration to ensure that mechanical breakdowns, time delays, temperature fluctuations, and other factors do not contribute to the decomposition or contamination of food.

(    pr3 - Code of Federal Regulations - 21CFR110.80(b)(2).pdf   68.67KB   77 downloads  )

 

None of the above documents discuss risk assessment issues as related to PRPs which can be important (and subtle) (“2i” does in a subsequent document). Nonetheless,  perspective 2 does IMO seem more adapted to existing FS systems assuming their are no (validated) risk assessment oppositions ( some FS "perspectives" still utilise / justify PRPs even where a risk assessment does yield a significant hazard !). It's probably not too relevant to UK but perhaps PAS220 / ISO equivalent requires some further expansion(s) ?

 

Rgds / Charles.C

 

Ps - one drawback IMO to this logic process is that it encourages the creation of an encyclopedia of PRPs / SSOPs / SOPs whatever.

This is surely a plus to FSSC22000 since it offers a minimal generic list, ready-to-quote as required. Personally, i would hv avoided any PRP programs to specifically cover freezing on this basis and no identified hazard. (clearly BRC 6.1.4 is a potential nuisance ).

I wonder if BRC are comfortable to encounter it as a standard reference.?

[Skye]

Hi Charles,

Thank you for the additional information. Can you let me know the source of the CCPs v PRPs (and OPRPs) document?
Best Regards
Skye

[Charles.C]

Hi Charles,

Thank you for the additional information. Can you let me know the source of the CCPs v PRPs (and OPRPs) document?
Best Regards
Skye

Dear Skye,

 

Main link is here (quite nice haccp resource) –

 

http://fscf-ptin.apec.org/training/

 

see section 3.4

 

Just for information, this mini-compilation of additional freezing  refs may be of interest –

 

 Extracts - Freezing,PRP,CCP,neither.xls   1.14MB   154 downloads

 

Rgds / Charles.C

 

PS - BTW, my thoughts in this current, unrelated thread/post are slightly analogous to current query, particularly (1).

http://www.ifsqn.com...ge-2#entry66042

 

The fact is that the scope of "referenceable" PRPs is almost infinite but it's presumably appreciated by an auditor if some relevant basis is attached.