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#1 shyshadow48

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Posted 13 August 2015 - 03:36 PM

Good Morning,

 

 

I am new here and i am hoping to find some guidance with an uprising issue.

 

I have been with this company for three months and i have a concern.

 

This company does muffins,cheesecakes, danish, etc.  We are located in California and the company is a FDA company in hopes to move foward to SQF. We just had our silliker audit. Our auditor recommended we remove our baking CCP. I am not sure if i should or not. IT is a hard decision. My question is:

 

IF i decide to keep it, how to a validate my decision. I want to take only one temp of the rack and document it. 

 

IF i decide to remove it, there's always that chance that they might try to challenge me.

 

We currently have baking as CCP1 and metal detection as CCP2.

 

I read other threads, but did not find an answer. Maybe someone can help me?

 

 

 

I would really appreciate the feedback.

 

 

 

Thank You.



#2 Snookie

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Posted 13 August 2015 - 05:44 PM

I am not a baking expert or at least professionally so my help is most likely going to minimal.  Hopefully someone will chime in shortly.  However that being said some basics still apply.  Auditors will always challenge you to defend your HACCP.  You could very well have the next auditor question why it was taken out.  Risk assessment is key to the decision.  


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#3 mandip

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Posted 13 August 2015 - 09:08 PM

I am also being pushed by one of my customers to make baking (in Breads) as my CCP, while i never had it as my CCP in my HACCP plan for the last 10 years.

I am baking to get the product baked but not sterile and why should i make it as CCP



#4 johntstuart

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Posted 13 August 2015 - 09:08 PM

Truth be told, it can go either way.  Many auditors are making the suggestion to change baking from a CCP to Process Control Point (or CP for short).   If your products are undercooked, it would be noticed immediately and they would likely be thrown out anyway for reasons such as being doughy, color being off, flavor being off, etc.  Also, baking steps are usually well in excess of the requirements to kill bacteria (though it does depend on your target bacteria).  For this and other reasons, the cookie company that I work for only has our metal detector as a CCP.

 

 

That said, baking is a perfectly valid CCP, so long as you can back it up and prove that you are meeting it.  If you can back it up with scientifically and technically valid sources, and if you can adequately monitor and verify it, then you can keep it if you want.

 

For some more insight, I'd recommend going through:

http://www.ifsqn.com...ccp-validation/

 

and

 

http://www.extension...dation-of-haccp



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#5 Charles.C

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Posted 13 August 2015 - 10:00 PM

Hi shyshadow,

 

There is another, shortish, thread on this forum approx. 1-2 yrs back  which somewhat mirrors your quest for specific validation as to the visual excuse for not making a CCP. No actual published examples/studies were claimed to exist (?).

 

The practical requirements, rack temperature monitoring etc are there discussed at some length. And argued over.

 

Unfortunately, IIRC the originator never posted back his ultimate findings.

 

Probably interesting if you can find it.

 

I suspect for many haccp users it's like Metal Detectors, conformity avoids hassles. Finance permitting. :smile:

 

PS - Welcome to the Forum ! :welcome:


Kind Regards,

 

Charles.C


#6 shelamaesilmogan

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Posted 14 August 2015 - 07:12 AM

In my point of view...

 

CCP is where we can eliminate and inactivate  Critically the Food safety hazard..If baking specific process where temperature and time is being controlled why not consider it as CCP 1?You can stand it by your self because you are consider as one of the process owner.As long as you can validate and have supporting details you can validate it by micro analysis if the temperature and time u applied is effective to eliminate the food safety hazard and landed on high physical attribute of your product..Baking is also a critical side on production side because you cannot re process the over baked lot.You mentioned Metal detection is your CCP 2 that is highly considered because it is depend on how your facilities contribute metal hazards.



#7 shelamaesilmogan

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Posted 14 August 2015 - 07:21 AM

There are times auditors well challenge the process owner on how you depend your HACCP Plan.

If time and Temperature is involved to control hazard as experienced can be consider as CCP. Its up to the process owner on how to validate it..

It will not matter on how your company designed what is the step to be a ccp.As long as you do HAZARD ANALYSIS RISK ASSESSMENT and when find what is the CCP the important is you can stand and validate it..



#8 mgourley

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Posted 14 August 2015 - 10:08 AM

Definition of CCP (per FDA):

 

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

 

Have you used a CCP decision tree to determine if baking is indeed a CCP?

 

As Charles mentioned above, there really is no empirical evidence that shows a "baking step" will kill any nasty bugs. The American Institute of Baking was working on a study, but that was a few years ago and I have not seen any published findings.

 

Marshall



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#9 mandip

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Posted 14 August 2015 - 02:20 PM

Hi Guys,

 D value for Salmonella  spp is 1.73 min at 60 0C and for B. cereus which is usually associated with Flours is also 1min.

So if baking is done at more than 150 0C for about 15 min, how would they survive?

and Baking is not designed to sterilize the product but to give it a proper mouthfeel and texture.



#10 Charles.C

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Posted 14 August 2015 - 08:35 PM

Hi Guys,

 D value for Salmonella  spp is 1.73 min at 60 0C and for B. cereus which is usually associated with Flours is also 1min.

So if baking is done at more than 150 0C for about 15 min, how would they survive?

and Baking is not designed to sterilize the product but to give it a proper mouthfeel and texture.

 

Hi mandip,

 

There is perhaps some confusion regarding typical core temperatures and vegetative / spore forms of pathogens?

 

eg this post et seq. in the link given previously -

 

http://www.ifsqn.com...ion/#entry58754


Kind Regards,

 

Charles.C


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#11 mandip

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Posted 17 August 2015 - 12:12 PM

HI Charles,

Thanks for the your valuable insight. I believe the core temperatures (95-96 oC) of the product are still sufficient to destroy these. And on the side how many food safety outbreaks have been heard of in past due to these culprits in breads. For more than  10 years in past, in my organization, never ever the baking temperature has been monitored as CCP (though it is one of the process controls which is monitored at scheduled frequency. Never had any recall been made as of now for such food poisining or outbreak. Occasional samples sent to third party labs have never been tested positive for these pathogens. In such circumstances what should be my justification to monitor it as CCP and not Process control point or Operational Process control point, all of a sudden.



#12 Charles.C

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Posted 17 August 2015 - 07:35 PM

HI Charles,

Thanks for the your valuable insight. I believe the core temperatures (95-96 oC) of the product are still sufficient to destroy these. And on the side how many food safety outbreaks have been heard of in past due to these culprits in breads. For more than  10 years in past, in my organization, never ever the baking temperature has been monitored as CCP (though it is one of the process controls which is monitored at scheduled frequency. Never had any recall been made as of now for such food poisining or outbreak. Occasional samples sent to third party labs have never been tested positive for these pathogens. In such circumstances what should be my justification to monitor it as CCP and not Process control point or Operational Process control point, all of a sudden.

 

Hi mandip,

 

It’s certainly correct that one needs to specify a product/process to make “definite” haccp opinions.

 

Here are some further comments / data –

 

Attached File  bacillus spp. in baking.pdf   637.47KB   40 downloads


Kind Regards,

 

Charles.C


#13 Leila Burin

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Posted 19 August 2015 - 11:38 AM

Hello al, under my experience, facilities that had baking (or frying) as CCP, the CL was the internal temperature of a random product from the line after the bake/fry process (the location of the sample in the conveyor belt was validated with statistics), was removed and only metal detector/X-ray is the CCP

best regards,

 

Leila



#14 shyshadow48

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Posted 20 August 2015 - 04:40 PM

Thank You all for your comments and useful information.

 

i have used the decision tree and based on the tree, it is a CCP.

 

Our baking products contain eggs, and dairy. I guess the main concern would be salmonella. I did create it as a CCP. but maybe someone can give me their opinions on how i wrote it? ( I had to write it as the following since our bakery bakes A LOT of products in a day, and so i wrote a general TIME AND TEMPERATURE. I am just not sure it will be suffiecient to the auditor.

 

Minimum Bake Time: 12 minutes Minimum Oven Temp.: 260F

 

 

As for my validation, i will use a scholarly articles which explains that salmonella is killed at 160F and we are well above that temperature, so there should no be issues there.

 

 

Can someone give me some input? (I am just starting at a QA Manager, i used to be a supervisor and didn't have so much responsibility, so i apologize in advance if i am a beginner)



#15 mgourley

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Posted 20 August 2015 - 10:02 PM

I guess I just have more questions.

 

1. If you are making cheesecake, and your internal temp was not hit and maintained, would your finished product then not be of acceptable quality? (And then be tossed out as waste?)

 

2. If you are making muffins, and your internal temp was not hit and maintained, would your finished product then not be of acceptable quality? (And then be tossed out as waste?)

 

I have worked in the baking industry for over 20 years (bread, buns, rolls, cookies). If product is not hitting required internal temp (over the temp that bacteria, etc. will be killed), the product will not be viable from a quality perspective. The product will then be discarded as waste. 

 

There is not much point, IMO, for having baking as a CCP, IF the product will not meet quality standards for finished goods.

 

Marsall






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