2 replies to this topic

[DavidAR]

What is the definitioin of a process step under HACCP?

 

i argue that it is anything product related from goods in ( mixing, changing tape, films,) to consumption.

 

am i right?

 

the production manager and MD have descided that they wish to add a 2 day holding period for products as a precautionary measure due to some complaints as a result of high aW levels.

 

This i argue is a systme failure and although i agree the course of action is probably right, would be a process change by definition from the normal process and require an HACCP review.

 

He argues it does not because its not a process change. and belvies if anything its a PRP which i think is rubbish?

 

thoughts anyone?

 

 

 

 

[trubertq]

Well.... say for example the holding is taking place in a chill then the process step is chilled storage and the length of time is defined in the SOP.

 

I agree that adding a 2 day hold is a change to your process and does require a HACCP review IMO. It's hard to tell when we don't know the product or the process involved but  for example if my shellfish processors decided to add an extra icing step or and extra chill storage step then this would indeed initiate a HACCP review.

 

Anyway, this needs to be discussed with your HACCP team at a minuted meeting so that everyone knows what is happening and why. And it needs to be documented as corrective action for the complaints.

[DavidAR]

Exactly as i put it to the team.

 

Thanks for the reply, il give some more info here might help also.

 

the product is made of flour and water only, sometimes colour is added the end product is dry ambient stable with an aW range of .3 to .75

 

this alows the product it be packed in to food grade cardboard cases for distribution at wholesalers for restraunts etc.

 

we had one complaint for a particular batch of product that has mould in it. we withdrawed all product from distributors for this batch not recalled and instigated investigation.

 

we identified an issue with a piece of equipment where by current testing methods failed to pick it up by identifying higher than normal aW levels which lead to the mould growth.

 

equipment fixed aW back incontrol but as a precautinary measure they are testing aW on day of manufacture and holding it for 2 days to ensure it conditions at the defined perameters as a kind of extra layer of safety blanket.

 

This addtional hold is by definition to me a HACCP process step and requires the appropriate actions of HACCP review regardless of whether or not its a needed step or not to address whether this extra step carrys with it any addtional potential risks not previosuly considered.

 

They argue it does not as its not a process step and that process steps are only related to manufacturing the product which i totaly disagree with! ( and i blasted them with some nice FDA , FSA guideline snipetes from the net along with this :)