15 replies to this topic

[aps]

Hi

 

Advice needed for all you Seafood experts.......

 

As this is a new territory for me, I was wondering if anybody can clarify if you think stock received for frozen seafood i.e. Prawns, fish, lobster etc would you say that this is a CCP or not?

 

Help would be appreciated 

 

[aps]

Just to clarify.....

 

We are a Storage and distribution centre, we do not process only receive, pick and ship to who ever orders.

 

Thanks 

[RG3]

Hi aps,

 

   It would be who of you to look this over and download it http://www.fda.gov/d...n/UCM251970.pdf

 

It is a fantastic guide on how to build your CCP's via process, via product...the thought process behind it and how well it is written can also be used by those not in the seafood industry.

[Charles.C]

Hi

 

Advice needed for all you Seafood experts.......

 

As this is a new territory for me, I was wondering if anybody can clarify if you think stock received for frozen seafood i.e. Prawns, fish, lobster etc would you say that this is a CCP or not?

 

Help would be appreciated 

 

 

We are a Storage and distribution centre, we do not process only receive, pick and ship to who ever orders.

 

Dear aps,

 

As I understand your process has 3 stages, receive frozen goods, store FG, ship FG.

 

I assume for the 3 stages that the  item is continuously, "fully" packaged and unopened, remains undamaged / un-cross-contaminated, and that an appropriate cold chain, eg <=-18degC is maintained.

 

Not quite sure which of first 2 steps you are querying? Also might depend on where yr responsibility ends, ie exit of cold storage or arrival at customer.

 

Regardless, IMEX, nowadays, for the majority of typical haccp plans for above process (but perhaps not in 100% cases),  all 3 stages could be regarded as controlled, from a FS POV,  by  Prerequisite functions. So no CCPs. ( if you look long enough you can probably find some haccp plans with any of the 3 as CCPs ).

 

Rgds / Charles.C

[trubertq]

I agree ... no CCP .... pre-requisite and I work in seafood

[RG3]

I agree ... no CCP .... pre-requisite and I work in seafood

Hi trubertq, what if one of the items he is receiving "fish" is a scombrotoxin (histamine) forming species? As a consumer, you're ok with this not being a CCP?

[trubertq]

He's not processing the fish, he's just receiving , storing, picking and dispatching.... If he were receiving fish for freezing or further processing yes histamine is a hazard but not in this particular instance, since he is not opening the cartons or doing anything with them .

[cazyncymru]

Not being a seafood person, I'd agree with Trubertq. He's not processing only receiving, storing and distributing ( in it's packaging ). 

If histamine is to be a problem, then there needs to be a strict spillage/ clean up procedure if there was a spillage. 

Caz x

[Snookie]

As someone who is HACCP certified in Seafood, I see this one  both ways.  While I can see this as a CP, I can also see this as CCP.  Even though nothing is being done, the cold chain here is so critical.  For most people a bit of extra histamine, is not going to be a big deal and is more a nuisance, however for someone who may be sensitive such as an asthmatic, it could be disastrous.  As someone who has seen someone nearly die from this type of reaction, I understand all to well the risks.  The problem is that the cold chain is critical from beginning to end and three CCP's seems overkill and makes it easy for people to ignore them.  However making a CP may give staff a false sense of security and not cause to react as they should if the cold chain is broken. 

 

http://www.fda.gov/F.../ucm2006801.htm

 

Critical Control Point: A step at which control can be applied and is essential   (emphasis added) to prevent or eliminate a food safety hazard or reduce it to an acceptable level.  

 

Think the choice is most likely governed by how good your refrigeration, processes and staff are. 

 

[Charles.C]

Dear All,

 

Re-histamine. An analysis could involve an interesting  combination of, for example, Product, Process, Location, Risk Assessment, Scope of HACCP Plan, Standard, terminologies, COAs. You name it.

 

Theory

 

Clearly histamine is a potential hazard for some input seafood species. Does the Receiver have any control over a particular lot of  incoming Raw Material, potentially with  unsafe levels of  histamine ? If frozen RM, yes - time would permit an accept / reject sampling/analysis. So a possible CCP.

 

However, many (but not all)  haccp methodologies have nowadays adopted a Prerequisite approach which includes “Receiving” by definition (as against a “pure” Hygiene concept). So the control then, nominally,  becomes more like a part of QA, ie excluded from CCP status. This convenience IMO was not entirely accidental.

 

But, just as an example, the USA (at least in their 2011 Seafood Guideline manual) seems to be a possible exception since they specify histamine CCPs for receiving frozen input.

 

For UK I’m unsure regarding their use of Prerequisites but, from memory, I seem to recall an FSA “official” example for some random (non-frozen?)  inputs which implied  COAs for Received Goods could  anyway self-justify raw material had “no significant hazard”  > no CCP (a semi-zigzag perhaps).

 

Life was not made to be easy.

 

Rgds / Charles.C

 

PS – Presumably repeated failure of a histamine PRP would justify a re-evaluation of its status. Elevation to a home-made OPRP perhaps.

[aps]

HI

 

Mixed feelings I see!!!!!

 

 

B / C hazards for freezing seafood (Fish, Mollusc, Chicken, Crustaceans, Breaded Product) following Q2 on the CODEX decision tree, is this step not designed to reduce growth making it a CCP. If this is wrong please help me understand the risk by going through CODEX decision tree.

 

Thanks

[rrana]

Hi All:

           I am not seeing any CCP, well Temp is critical for the warehouse, receiving, storage and distribution(dispatch), and has to be continually monitored and there should be a contingency plan, in case any failure happen to the controls I am not sure why histamine is a concerned as the package is received in frozen stage and dispatch as frozen stage, worst case scenario is evaluated by risk assessment.

[aps]

Temperature can be elevated if left out on loading bay!

 

The way the process is -

 

Unloads in ambient - then moved to Freezer - Picked and moved to ambient - loaded onto trailers, temperature controlled.

 

So not only histamine, surly other nasty's will double in growth? as loading bay is a concern of mine

 

 

I think I may of answered my previous post regarding CCP. I may believe this can be controlled by a subsequent step like freezer breakdown procedure.

 

What your thoughts people

[Charles.C]

Dear Aps,

 

It might help if you could supply a little more data.

 

have you checked the temperatures at reception / input to the cold store ?

do you know how long it takes from receive to get into the cold store ?

is the product B/F, semi-glazed, IQF ? or ?

typical net weights ?

 

Rgds / Charles.C

[trubertq]

The way I would see it is, that intake temperatures and holding temperatures are pre -requisites as rrana says.... the process is intake holding picking and dispatch,  with the attendant temperature checks ( hopefully continual) and procedures for breakdown and calibration and what not.

 

Different story if it's fresh fish coming in.... 

[Charles.C]

Dear All/aps,

 

I would like to point out a few variables -

 

(1) The first stage of a HACCP plan is conventionally to state the Scope.

(2) With respect to (1), aps private FS standard, if any, is unknown.(for example FSSC22000 would probably define this stage as a PRP).

(3) Regardless of (2), Regulatory factors trump a Private Standard (if any). The location is apparently UK. Is there any Regulatory ?? (eg, if USA , a CCP is FDA  defined for this situation, ref.post #10).

(4) If no PrivateStandard/no Regulatory factors exist   (or, typically, probably even if a Private Standard does exist), then IMEX (Codex?) of generic HACCP,  this situation can be  (eg via ISO2202-1) user categorised as a PRP  but the choice must be validatable (verifiable). If the latter cannot be consistently carried out, generically (Codex? ISO22002-1?) the haccp plan is required to be revalidated with a possibility that the  PRP be upgraded to CCP. This was the reason i suggested aps / aps's OP needs some more data. Ideally, such data would be available prior to generating the HACCP plan from routine QA but aps seems to be at present in "hypothesis mode" only (?).

 

Rgds / Charles.C