4 replies to this topic

[Dharmadi Sadeli Putra]

Dear All,

Do we need to do hazard analysis on retorting step for low acid canned fishery products as it already covered by LACF Regulation (21CFR 113). On FDA Fish and Fishery Products Hazards and Controls Guidance (4^thed) chapter 16, it states that retorting step is controlled by 21CFR113  ( http://www.fda.gov/d...n/UCM252435.pdf ). Does it means that retorting step not included in HACCP Plan? Please advise

Edited by avila muncar, 29 April 2014 - 04:32 AM.

[Charles.C]

Dear avila muncar,

 

It likely depends on whomsoever has local legislatory control of canned products at yr location. Or maybe the ultimate destination of finished product. Or maybe both.

IMEX low-acid canned materials are usually under legislatory control at many (most?)  European / N.American locations. Asia not so sure ?

 

Rgds / Charles.C

[Dharmadi Sadeli Putra]

Dear Charles,

Most of products are exported to US and retorting step is CCP in HACCP Plan. So far no questions from auditors (FDA & BRC). Feel a bit confused about the above statement. Thanks  

Rgds

[Charles.C]

Dear Charles,

Most of products are exported to US and retorting step is CCP in HACCP Plan. So far no questions from auditors (FDA & BRC). Feel a bit confused about the above statement. Thanks  

Rgds

 

Dear avila muncar,

 

For example (Canada) see this post -

http://www.ifsqn.com...ge-2#entry71674

 

A critical step is the aspect of  validation of the thermal process, eg by a Process Authority.

 

Perhaps yr local situation is completely different.   

Another aspect is the (internal) legislatory responsibility which may devolve onto yr importer in USA. again, sorry.

 

Rgds / Charles.C

[Charles.C]

Dear Charles,

Most of products are exported to US and retorting step is CCP in HACCP Plan. So far no questions from auditors (FDA & BRC). Feel a bit confused about the above statement. Thanks  

Rgds

 

Dear avila muncar,

 

AFAIK, to export canned low-acid goods to USA, yr facility/process has to be registered with USFDA. This involves items such as in my previous post, eg -

 

http://www.fda.gov/F...n/ucm125439.htm

http://www.fdaimport...anned_foods.php

 

My (HACCP) query was directed to who is yr current haccp plan for ? ie who is the intended auditor ? local FDA ? BRC ? USFDA? I deduce the third.

 

Assuming the third, I think the answer to yr specific HACCP question is covered on page 256 of guidance manual. And appears to be YES. But regarding details of the controls - NO since they are mandated by LACF (for which i presume your controls must be in compliance).

 

I should add that not recently in canned fish business so any direct users only too welcome to correct / expand / whatever on the above.

 

Hopefully now less confused.

 

Rgds / Charles.C