Help with determining a CCP?

Hello,

I am a certified HACCP implementer through SGS with over 5 years of food safety and quality experience, but I am now with a company that is starting up an oat processing plant where we will be producing oat groats (which will be sold as-is, but mostly used in-house as an ingredient) and steam-rolled oats (made from the oat groats).

This is my first time writing a complete food safety/quality program from scratch (this company had literally NOTHING in place when I was hired), and we are looking to become certified in a GFSI-approved scheme (we're still deciding between SQF and BRC...so any advice on that would be helpful as well!) - either way, we're going to need a HACCP plan in place as well.

My conundrum is this - we will have two potential steps in the process that might be considered as CCPs, but I am leaning toward them NOT actually being CCPs...rather, they are just CPs, in my estimation:

1.  The first is a process step wherein the oat groats will be steamed at 220+ degrees F for 15 minutes.  Now, this is simply designed to be a processing step (softens the oat groats and denatures an enzyme in them to reduce rancidity as well as enable them to be steam-rolled efficiently), but it, by default, is also a "kill step" for microbes because it is above boiling temperature.  We are not considering it as a kill step for our purposes...but should we be?  And if so, should it be a CCP?

2.  We will also have a metal detector through which all finished product will flow, though it is highly unlikely that there would be any metal (or any FM) in the product by that time, because it will have been screened and sifted multiple times from receiving through the end of the process.  Really, it's just a last-minute check to ensure that machine parts haven't gotten into the product (again, highly unlikely, and controlled by the Preventive Maintenance Program).  So, it's likely not even necessary...and as such, should it be considered a CCP?

Another point is that we will be making these products to be sold as animal/livestock feed only for at least the first year (while we get our ducks in a row and get GFSI-certified), and then we will be switching to food grade.

Thoughts?  Opinions?  I welcome them all!!

Thanks,

Brian

Hi Brian,

It depends on Risk Assessment / some preliminary input, eg -

For the specific process/consumer to be assessed -

(a) Is the product classified as RTE ?

(b) Any particular FS standard intended?

(c) what is yr specific methodology for hazard analysis/RA ?

(d) What specific methodology do you intend to use to determine CCPs ?

(e) How do you define your PRPs ? eg as per ISO 22002-1 ?

Then one possible route is (briefly) that the haccp procedure might continue as per   - 

For yr para (1,2) what is the hazard(s) ?

Based on the hazard / RA, is the hazard  "significant" ?

Is there an appropriate control option available ?

if Yes (x2) > CCP ( assuming "significant" has accounted for non-PRP/no later equivalent control step/non-ISO haccp)

Or if Yes (x2) > CCP/OPRP (assuming as previous line except for iso-haccp)

if no > no action/find a control option respectively

Wow, thanks Charles!!  I have never seen the thought process laid out so detailed before.

I appreciate your help on this!

Brian