4 replies to this topic

[Charice]

Hello everyone, I have read on HACCP Codex Standard and saw noted bellow CCP Tree Decision can not apply for slaughter or seafood product. Plz help me some ideas of your to know more about this. Thanks so much!

[Madam A. D-tor]

Dear Chericevu,

 

I do not see why you can not use the decision tree of the codex for slaughteries and seafood producers.

 

 

Personnally I dislike the decision tree of the codex. It will leave you with a lot CCPs. Even for processes that are obvious GMPs. I normally advice companies to make their own decision tree, but most auditors and almost all food safety authorities, wants you to use the decision tree of the codex.

 

I have seen companies both in slaughter process as in seafood processors use this decision tree.

 

If there is a specific issue that you are strugling with, you can ask for the opinion of the members of this forum.

[Charles.C]

Hello everyone, I have read on HACCP Codex Standard and saw noted bellow CCP Tree Decision can not apply for slaughter or seafood product. Plz help me some ideas of your to know more about this. Thanks so much!

Dear charicevu,

 

I am guessing you are partly referring to the caution in sec.7 in the haccp portion of the well-known Code Hygiene Guidelines.

 

CCP is a concept derived from risk assessment. Unfortunately not all levels of risk are black/white in making a logical decision. Additionally the use of CCP in haccp is (typically) also within a larger  framework with potentially overlapping  items like PRPs.

 

The Codex tree  may give confusing or inappropriate results when applied in certain ways / situations. 

 

Just as one example, some (haccp) users apply the 4 tree questions  directly to the process steps of the flow chart. Due to the terminologies used, the intended chain of analysis is somewhat obscure in the Codex  document however the emphasis is clearly on initially categorising significant hazards if one follows the parallel US/ NACMCF version of haccp or the logic in iso22000. The results will often be the same but  not in all situations. One possible error is due to the occurrence / choice of Prerequisites. To allow for this, recent versions  of the Codex tree add a precursor stopping step / requirement that the control measure relating to the hazard of interest should not be implemented within a  PRP program. However this latter decision may itself also depend on the specific standard / product / process involved. Allergenic hazards are a well-known example. A particular motivation for the preceding modification is to minimise the total number of CCPs in the process.

 

Slaughter industry not my area of expertise but i hypothesise that the difficulties may relate to the decision of some authorities to implement regulatory CCPs where the precise ability to match to a decision tree result is debatable.

 

I don't think i have ever seen any specific reference to a seafood related incompatibility. Perhaps you can elaborate. 

 

Rgds / Charles.C

[HACCP Mentor]

A Charles said - it is all in the risk assessment. As an auditor, this is the most poorly done area of the HACCP plan. There needs to be a full understanding of what hazards exist, their likelihood and the consequence. For the Codex decision tree, you should not be ending up with more CCPs if you have used the tool correctly. A lot of people answer Question 2 incorrectly (Is the process step specifically designed to reduce or eliminate the likely occurrence of a hazard to an acceptable level?) with "YES" which then leads to a CCP being identified. The question refers to the process step not the actual control measure that you want to put in place. There are really only a handful of process steps that are designed to "reduce or eliminate the likely occurrence of a hazard to an acceptable level" eg. cooking, pasteurization, metal detection, chlorination, addition of preservatives. When using the Codex CCP tree it is imperative that your flow process chart is correctly documented with all of your process steps otherwise your hazard analysis and use of CCP decision tree will be incorrect.

[Charles.C]

Dear charecivu,

 

If you are interested in a detailed explanation of the intentions within the steps of the Codex Tree i suggest you have a look at the (probably) no.1 best-selling text on HACCP due to Mortimore and Wallace. The book (various editions but I think fairly similar for this aspect barring perhaps the increasing use of prerequisites) is viewable as a Google Book.

 

Rgds / Charles.C