Removing a CCP
Hello I am the Quality Control Director at a fresh apple packing plant in Upstate NY . We have a HACCP program in place with our dump tank being our CCP the team has been discussing for the past 2 years if we really need a CCP because none of the local packing facilities in our area do not have a CCP we all work for the same sales Company and have many of the same customers and have the same Consultant which we have questioned again why do none of the other packing facilities have a CCP. Has anyone removed a CCP before and is it even possible to do since its been a part of our program for about 8 years now?
I would say yes you can remove a CCP, however it is not going to be easy. Other than "because they don't have one" what is your basis in removing it? Someone thought it was a CCP 8 years ago, what has changed in order to not make it one now?
Hello I am the Quality Control Director at a fresh apple packing plant in Upstate NY . We have a HACCP program in place with our dump tank being our CCP the team has been discussing for the past 2 years if we really need a CCP because none of the local packing facilities in our area do not have a CCP we all work for the same sales Company and have many of the same customers and have the same Consultant which we have questioned again why do none of the other packing facilities have a CCP. Has anyone removed a CCP before and is it even possible to do since its been a part of our program for about 8 years now?
As I understand the dump tank is an initial stage for washing the produce while maintaining a minimum level of chlorine or some other sanitizer. I presume the sanitizer level is yr CCP ?
The exact haccp status of such a stage depends on yr risk assessment (RA). The precise RA for such stages is occasionally debated in textbooks as to whether a CCP or not.
I also believe it is often considered desirable in Fresh Produce haccp plans to have a minimum of one CCP which this stage frequently fulfils ?.
Is it possible that other packers have a different process set-up ? If not, it may mean that their risk assessments or haccp methodologies are different to yours. Same Consultant ?
Interesting to know yr Consultant’s reply as to the reason why other packers have no CCP ?
Logically, as implied in previous post, you will require a (validatably) changed RA to justify "demoting" the CCP.
We knew it would not be easy to remove a CCP we were advised by our sales agency consultant which handles educating the pack houses on changes in the Industry years ago when we had 2 major audits a year the BRC and PRIMUS the consultant "felt" that it would be a plus for the PRIMUS audit if we had a CCP we chose the dump tank in our operation because we were already monitoring it on a daily basis when production was running.
The sanitizer level is our CCP. The other packing facilities that pack for our sales agency have basically the same set up: Water flume with Chlorine as a sanitizer
Operating level is 720-850mV with CCP of 650 this is pretty standard. We also record ph level and record temp of water
There is a alarm that sounds when levels are out of range. (I have been employed at this facility for 20+years and have NEVER heard the alarm during production)
When we asked the Consultant why the other packing facilities do not have any CCP it was stated that after a risk assessment was done they felt the risk to be low to none. So than our HACCP team has questioned it ever since if we actually need the CCP at all. We take our food safety program serious were not trying to do "less work" we would just like to focus on areas that need that "Extra" attention. Since paper work is privileged we have never seen any RA from any of the other facilities or seen any documentation they used to exclude the water flume as the CCP.
We realize that it will remain a CCP but the question is always there "why don't the other pacing houses have at least 1 CCP"
Hello from a fellow Upstate NYer... though what is considered Upstate can be quite large lol!
Well if you look back, or search, a long time ago there was a very long thread on if you have to have a CCP in your HACCP plan. And there were many people who said yes and many people who said no. Like many things in food safety you'll find that there is no concrete agreement on much.
It sounds like you have a CCP because someone once said "Hey, We should have at least one CCP!" And maybe it wasn't the right thing at the time.
Run your risk assessment on the CCP and have your food safety team (or whomever does your HACCP plan maybe the HACCP team) come up with an answer they believe is the right one that they can defend properly. If you haven't had any CCP failures, withdrawals or recalls (as appropriate) based on that CCP, and your team find the likelihood/severity under the level they believe requires a CCP then downgrade it. Keep notes on your meetings so you can defend it to an auditor.
Hi bafro,
The decision as to a CCP or not may result from a variety of factors. These frequently involve (1) the specific haccp methodology, (2) the specific risk assessment technique (and often the specific risk matrix), (3) the interpretation of the definition of a CCP ( in present case, this may be relevant).
Comments
(1) ISO22000 haccp methodology would also offer the possibility of an OPRP but afaik, yr haccp is based on Codex.
(3) Some texts consider a CCP as theoretically inappropriate at this step due no hazard elimination or defined reduction of a hazard to an acceptable level at this step. This can be a question of interpretation / validation.
(2) I suspect this is the most likely reason for the difference between yourself and other packers.
I don’t know how you currently make yr decision as to CCP but, just as an example, can study this file which illustrates the subjective capabilities of risk matrices –
Risk Based Decisions.pdf 5.86MB 172 downloads
Based on yr comments so far, I daresay Figs 1-3 would probably give you 2/3 CCPs, fig 4 probably a definite CCP and Fig 5 “problematic” ?. Other, less risk adverse, users might get 4 No CCPs. Or use yet another permutation.
A variety of other possible matrix permutations / conclusions exist.
It might be useful if you could post yr method for deciding a CCP ?
PS - It is generally acccepted that a HACCP Plan with zero CCPs is acceptable if justified/validatable/verifiable by the risk analysis, etc .However some locations/industries have their own "Standards". in some cases there are Regulatory HACCP requirements also. i have no idea as to your specifc case but your Consultant should obviously know and the existence of other co-located packers having closely similar processes with no CCPs would suggest there is no specific restriction.
Hello:
I found this thread highly interesting. I have been teaching HACCP since 1995 at the state level as a regulator and independently, and have developed over 100 food safety systems and have audited about 300 operations under GFSI standards; I also develop BRC systems as well as those to comply with PGFS and other similar standards.
Several areas of missing scientific information, specifically the efficacy of any antimicrobial treatment, confound the issue of setting CCP in the packing of fresh produce. There are currently no registered antimicrobials for human pathogens on whole fruits and vegetables. This is because to meet the standard as a sanitizer under FDA rules, the application must result in a 5-log or greater reduction in target organisms on the plant material. Many existing studies only reference about a 1-2 log reduction, about the same as plain potable water rinse. Since the definition of a CCP is that it is step that will eliminate, prevent or reduce a significant hazard to acceptable levels must be met, we cannot scientifically require a CCP for human pathogen reduction by applying an antimicrobial, unless we have peer reviewed publish studies relevant to the process. But then, the problem arises as such studies can conflict, one showing efficacy while others under similar laboratory conditions showing infectiveness, and all of this is highly dependent on the plant material itself, as well as many variables in the application, time, temperature, coverage, concentration, pH, on and on.
The mandated use of HACCP for fresh produce puts operations in jeopardy since and auditor can rule either way in an evaluation of the need for a CCP. If one tries to rely on the hazard analysis as justification, you run right up against the same problem of significance, what one person considers likely, and what another person considers likely is subject to all sorts of bias.
What we can say, however, is that when water is reused (re-circulated) we can find a CCP for the treatment of the water. We can in-fact eliminate harmful bacteria that build up in reused water through application of several registered products (registered for water treatment).
Thus the dump tank issue constitutes a significant hazard for cross contamination and growth of bacteria, if the tank water does not retain antimicrobial qualifies. Additionally, if produce is cut, exposing vulnerable plant tissue, colonization of the plant material is likely if re-circulated water quality is not maintained, thus strengthening he argument for a CCP.
Such cut plant material can also grow harmful bacteria, and the FDA Food Code for example requires processed produce to be maintained at below 41 degrees in storage, thus we have a CCP that is legitimate and valid for cold holding of processed fruits and vegetables.
Finally, metal detection comes up as a CCP when inclusion of metal is likely, when cutting with saws, blades or other mechanical methods.
It is worthy to note that FSMA preventative controls say nothing about CCP. This is a political answer to the difficulties of scientific validity for claiming a CCP in whole produce as found in the private standards.
The application of HACCP to the packing of whole fruits and vegetables is a terribly biased and uneven field and has placed the industry under GFSI requirements in a very vulnerable spot, and unfairly so.
Hi Roy Costa
Welcome to the Forum ! :welcome:
Many thks for yr detailed input. I also enjoyed your (I presume ?) related article –
http://www.foodsafet...r/#.VZSP8I5NJnI
Such cut plant material can also grow harmful bacteria, and the FDA Food Code for example requires processed produce to be maintained at below 41 degrees in storage, thus we have a CCP that is legitimate and valid for cold holding of processed fruits and vegetables
.
This process afaik has always been a disputed topic from a haccp POV.
I accept that the treatment described for the wash water facilitates control of the quality and minimises cross-contamination to fresh input. For example –
wash tanks.pdf 181.6KB 82 downloads
However afaik, the FDA have never regarded this stage as a CCP (or any of the linked process stages from memory) ? They seem to prefer to discuss safety-related control for this produce within the terminology of “minimisation”. Possibly due to reasons of validation again ?
I also noted that the Canadians seem to classify their washing stage as a (Modern Generation) Prerequisite program but do incorporate a specific “antimicrobial” stage –
http://www.inspectio...10?chap=4#s10c4
(their process may involve less recirculation, unclear)(validation of their "antimicrobial" stage is not shown)
Regardless the thrust of the OP was that various facilities using (stated) equivalent processes have been successfully audited with zero CCPs.
Would this be acceptable to yourself ?
PS @ bafro - apologies for slightly hijacking yr thread
PPS - I have also seen a (rare) Performance-based article for fresh produce where an antimicrobial reduction of around 2log was claimed to be adequate within an overall calculation of the pathogen profile for the given input > output path. Validatory data was included (from memory).
Hi Charles C. and Roy Costa
Thank you very much for all of your input. We have a new consultant who agrees that our Facility does need a CCP and I found your one article Roy Costa "The Packinghouse: Safety and Uses of Process -Water extremely helpful!! When we made our dump tank a CCP years ago we did not Micro-test, we now have employees that are trained by Pace International to monitor and log ORP levels, Free Calcium Hypochlorite ppm-Manual, pH, and water temp. Our cleaning procedures have been "amped up" adding foaming Cleaning\sanitizers to remove biofilm in the dump tank and drains (we did not use a product like this before). We will continue to scour the internet for more articles on re-circulating water systems to back up our decision to do away with our CCP. Thank you again for all the information :spoton:
Hello:
I found this thread highly interesting. I have been teaching HACCP since 1995 at the state level as a regulator and independently, and have developed over 100 food safety systems and have audited about 300 operations under GFSI standards; I also develop BRC systems as well as those to comply with PGFS and other similar standards.
Several areas of missing scientific information, specifically the efficacy of any antimicrobial treatment, confound the issue of setting CCP in the packing of fresh produce. There are currently no registered antimicrobials for human pathogens on whole fruits and vegetables. This is because to meet the standard as a sanitizer under FDA rules, the application must result in a 5-log or greater reduction in target organisms on the plant material. Many existing studies only reference about a 1-2 log reduction, about the same as plain potable water rinse. Since the definition of a CCP is that it is step that will eliminate, prevent or reduce a significant hazard to acceptable levels must be met, we cannot scientifically require a CCP for human pathogen reduction by applying an antimicrobial, unless we have peer reviewed publish studies relevant to the process. But then, the problem arises as such studies can conflict, one showing efficacy while others under similar laboratory conditions showing infectiveness, and all of this is highly dependent on the plant material itself, as well as many variables in the application, time, temperature, coverage, concentration, pH, on and on.
The mandated use of HACCP for fresh produce puts operations in jeopardy since and auditor can rule either way in an evaluation of the need for a CCP. If one tries to rely on the hazard analysis as justification, you run right up against the same problem of significance, what one person considers likely, and what another person considers likely is subject to all sorts of bias.
What we can say, however, is that when water is reused (re-circulated) we can find a CCP for the treatment of the water. We can in-fact eliminate harmful bacteria that build up in reused water through application of several registered products (registered for water treatment).
Thus the dump tank issue constitutes a significant hazard for cross contamination and growth of bacteria, if the tank water does not retain antimicrobial qualifies. Additionally, if produce is cut, exposing vulnerable plant tissue, colonization of the plant material is likely if re-circulated water quality is not maintained, thus strengthening he argument for a CCP.
Such cut plant material can also grow harmful bacteria, and the FDA Food Code for example requires processed produce to be maintained at below 41 degrees in storage, thus we have a CCP that is legitimate and valid for cold holding of processed fruits and vegetables.
Finally, metal detection comes up as a CCP when inclusion of metal is likely, when cutting with saws, blades or other mechanical methods.
It is worthy to note that FSMA preventative controls say nothing about CCP. This is a political answer to the difficulties of scientific validity for claiming a CCP in whole produce as found in the private standards.
The application of HACCP to the packing of whole fruits and vegetables is a terribly biased and uneven field and has placed the industry under GFSI requirements in a very vulnerable spot, and unfairly so.
It would seem that if the water sanitizer does not have validation at a 5-log reduction of human pathogens that a recirculated water dump tank would not be a CCP but a very important CP
there are many confounding factors, e.g. water sanitizer labels many times have dwell/contact times - if the goal is to sanitize the water then why should a dwell time matter - but maybe in a practical sense there is some "washing" of the product in the tank
another challenging item with CCPs and CPs is what should the corrective action be - if you fall out of the CL range must the product be quarantined and if the sanitizer is just sanitizing the water then re-running the product may not be helpful
coming in way late on this thread but hope to see additional interest and responses
It would seem that if the water sanitizer does not have validation at a 5-log reduction of human pathogens that a recirculated water dump tank would not be a CCP but a very important CP
there are many confounding factors, e.g. water sanitizer labels many times have dwell/contact times - if the goal is to sanitize the water then why should a dwell time matter - but maybe in a practical sense there is some "washing" of the product in the tank
another challenging item with CCPs and CPs is what should the corrective action be - if you fall out of the CL range must the product be quarantined and if the sanitizer is just sanitizing the water then re-running the product may not be helpful
coming in way late on this thread but hope to see additional interest and responses
Hi NPEP,
The "modern" viewpoint is (something like) that a CCP can be justified on the basis that appropriate chlorination of the water acts as a control measure which prevents cross-contamination between cleaned produce and incoming "unclean" material. There are discussions over this in the Literature.
https://naldc.nal.us...wnload/1763/PDF
Here is another article to support the removal of the CCP that aligns with ROY COSTA
The chemical agent does little to remove pathogens from the fruit, but does work to keep the bacteria load in the wash water low
It's frustrating to say the least when an audit/consultant uses the phrase "everyone else does/has/uses" XYZ and forces your hand to add something to your process that simply does not belong
https://naldc.nal.us...wnload/1763/PDF
Here is another article to support the removal of the CCP that aligns with ROY COSTA
The chemical agent does little to remove pathogens from the fruit, but does work to keep the bacteria load in the wash water low
It's frustrating to say the least when an audit/consultant uses the phrase "everyone else does/has/uses" XYZ and forces your hand to add something to your process that simply does not belong
Hi Scampi,
Actually i think the previous RC post was more suggesting a realignment of the CCP.
Here are a few recent "Pro-CCP documents -
postharvest washing stage,Hoorfar,2014.pdf 250.62KB 27 downloads
Washing vegetables,2016.pdf 1.9MB 38 downloads
HACCP Generic Model for Fresh produce, Ready-To-Eat Fresh-Cut Vegetables, CFIA.pdf 427.04KB 38 downloads