Are CCPs really necessary in a HACCP Plan?
I am currently working on a HACCP plan for a customer who is basically packing a product (dry beans) with only physical hazards. There is no water used in the facility and the beans are cleaned before entering the plant. They currently do not have any CCPs because the product is for further processing (sent to a processor to be cooked or straight to the consumer to be cooked). The are GAP/GHP certified but a customer wants a HACCP plan. Does my HACCP plan have to contain CCPs or can I just have control points? If I don't have CCPs does that make it not a true HACCP plan?
Well right wrong or otherwise (and I believe there is a thread on CCP's in HACCP) we are a starch drying facility (take in bagged customer A starch, enzyme modifiy it, dry it, and send it back to customer A for further use) and we do not have CCP's as traditionally used. With that said however we are moving towoard using our sifter screens as our CCP. That does change how we currently use them.
So in short we do not have a CCP in our Haccp plan, (again right, wrong, or otherwise.)
G
The reference topic is located here: No CCPs in a Haccp Plan - Can This Be Possible?
It is one of our oldest and most popular polls / discussions and it is very long.
To save time I think the answer if yes you can have a HACCP plan without CCP's.
Regards,
Simon
The simple answer is yes you can have a HACCP plan w/o a CCP, as long as you can show you conducted a thorough risk assessment and your pre-req's and operations control the risks sufficiently.
In plants where there is no actual "kill step" and no definite FB removal step, HACCP can be implemented without identifying CCPs.
However, it is worth noting, that one of the great advantages of adopting the ISO 22000 methodology is the requirement to identify oPRPs, which, in my opinion, have the same preventive power as CCPs when properly implemented.
In summary, in ISO 22000 certified organizations we expect to see CCPs and/or oPRPs.
In plants where there is no actual "kill step" and no definite FB removal step, HACCP can be implemented without identifying CCPs.
However, it is worth noting, that one of the great advantages of adopting the ISO 22000 methodology is the requirement to identify oPRPs, which, in my opinion, have the same preventive power as CCPs when properly implemented.
In summary, in ISO 22000 certified organizations we expect to see CCPs and/or oPRPs.
Or Neither.
You write that the beans after packing might be send straight to the consumer to cook. You write that you have potential physical hazards. I assume this points to foreign bodies, either coming from your installation or from the environment.
Let's take the example if you would have glass as a hazard, is this covered by your pre-requisites program?
Let's take the example if you would have metal scraping or a bolt, or other metal hazards in your equipment or environment, is this covered by your pre-requisites program?
If there are no good programs, or they do not work (look at your complaints for instance) then you might need to think of x-ray (glass/metal) / metal detection, (as you can not measure the result via checking small sieze sieve.)
(for checmical/micro risks have you got your raw material (beans) covered by a supplier approval pre-requisite program and/or good QC testing/reliable COA, have you reviewed the HACCP plan of the cleaning of the beans (them being GAP/GHP certified helps!)
NB. you do not write what type of packaging is used for the beans. Do not forget to take this into consideration too for the hazard/risk assessment.
Hi..
I have some fundamental questions.
1. OPRP is a part of the process, where we CONTROL the hazard
2. CCP is a part of the process where we eliminate a Hazard, or bring it down to an acceptable limit.
3. The END product according to ISO 22000, is the product that undergoes no further processing by an organization (No matter, it may be processed further by the next organization in the food chain)
Now the question - If there is no CCP in the plan where are we eliminating the hazard? This is because, each organization has to ensure that the end product they make is free from hazards and risk to consumer?
Request response...
Hi..
I have some fundamental questions.
1. OPRP is a part of the process, where we CONTROL the hazard
2. CCP is a part of the process where we eliminate a Hazard, or bring it down to an acceptable limit.
3. The END product according to ISO 22000, is the product that undergoes no further processing by an organization (No matter, it may be processed further by the next organization in the food chain)
Now the question - If there is no CCP in the plan where are we eliminating the hazard? This is because, each organization has to ensure that the end product they make is free from hazards and risk to consumer?
Request response...
Hi pubh,
Yr interpretation of OPRP/CCP is perhaps a little debatable.
Maybe compare this thread -
http://www.ifsqn.com...een-ccps-oprps/
i suppose one response could be PRPs in their ISO22002 upgrade.