Can we just determine CCP with hazard analysis?

Dear Charles;

Can we just determine CCP with hazard analysis?

Do we have to be asked of Decision Tree?

Rgds / Ahmet

Dear Ahmet,

 I assume this query is for traditional Codex-type methodology. For ISO/FSSC-22000 the answer would be expanded due to the possibility of  aspects like designated  PRPs / OPRPs etc.

 

Can we just determine CCP with hazard analysis?

Yes you can except that the method has to, typically, be auditorially regarded as “logical”. For example, if based on  a determination of  "significant hazards"  it will likely be necessary to detail  how,  eg via a risk matrix/ defined criteria for a CCP.

Do we have to be asked of Decision Tree?

The choice of using/not using a Tree is normally up to you. This option is implied in the Codex haccp Guidelines.  However I have (rarely) seen use of a Tree  specified in an official  standard in which case probably no choice.

Rgds / Charles.C

Thank you Charles....

I did our HACCP plan on https://myhaccp.food.gov.uk

Very simple to use and every detail you need is completed, including decision tree.  You download your final report as a pdf document.

I did our HACCP plan on https://myhaccp.food.gov.uk

Very simple to use and every detail you need is completed, including decision tree.  You download your final report as a pdf document.

Dear Mi55v,

Thks yr input.

I agree that this link does have some useful material.

Of course the analytical work in some typical CCP methodologies (eg  hazard analysis + risk assessment matrix + decision tree ) may be decreased if the 3rd component is excluded.

There is some  discussion/extracts on the FSA/UK approach in this thread, mainly posts (5-15) -

http://www.ifsqn.com...ery/#entry77547

Rgds / Charles.C

Charles wrote "Yes you can except that the method has to, typically, be auditorially regarded as “logical”. For example, if based on  a determination of  "significant hazards"  it will likely be necessary to detail  how,  eg via a risk matrix/ defined criteria for a CCP."

Hi Charles.  This subject is very topical for me at the moment..... 

So far, every food manufacturing site I have seen uses some form of decision tree or table which helps the HACCP team determine which process steps are CCP's.  Sure enough, last week I audited a site that has no such formal (objective, documented and enduring) approach to CCP determination, and instead, simply works by convening a meeting of the HACCP team where CCP's are determined by discussion.  Any comment on that approach?  Personally, it raised my eyebrows......

Hi swanswal,

The audited Standard / specific situation may have some relevance.

Wellll, "Brainstorming" , IIRC, is mentioned as a possible option in (at least) one of the traditional haccp references for performing  hazard analyses.

But i doubt that  "hearsay" would solely be considered adequately logical from a Validation POV.

How are the CCPs / critical limits resulting from the "discussion"  documented / Validated?

Well Charles, the Validation/Verification piece was not tested (yet) as the discussion around CCP determination left me feeling well....concerned that they may not have determined the CCP's in an objective and consistent manner.  I therefore halted the audit.  I was concerned that the whole FSP may just be a reflection of how management saw risks in their business last year, and if a different group moves in, the new group could see things differently.  (I might add that I was conducting a 2nd party audit here, not 3rd party certification).

Laying my cards on the table, I believe it is important to understand clearly how an organisation determines important HACCP steps such as CCP determination, and I have difficulty accepting a group of managers getting into a room, discussing the process, and then deciding where CCP's need to be after necessary discussion.  I am not saying that they are not capable; I think they are.  It's more that the outcomes (at least in my view) are less predictable, and vulnerable to influence by more 'senior' people. 

I am encouraging them to review this practice and think about having a more structured and objective process in place; one that can be clearly articulated to anyone from the outside.  I however only can reflect on my views and hence my desire to get other opinions from my learned colleagues.

Hi swanswal,

TBH I would have said that the Validation step quantifies the objectivity of the HACCP process with respect to  the determination of CCPs/Critical Limits/etc.

I have encountered the approach you mention in HACCP Workshops but only as a precursor to a documented formal, logical, validatable, hazard analysis. If the methodology you describe resulted in an absence of such evidence I agree with yr opinion.

To put it another way, too many boxes likely to be unticked. :smile: