9 replies to this topic

[jtang]

So I came to learn that, there are Food Safety classes taught to food service providers (here in BC, Canada, they are called FOODSAFE I and II). They essentially are very simplified models of HACCP taught to food service and restaurant managers.

 

Question: so for all of us who are familiar with the global food safety standards, BRC, SQF, etc., we know that generally the cooking step is a kill step and is a CCP.  ANYONE HAS SEEN ANY HACCP PLANS WHERE ALL STEPS AFTER A CCP ARE ALL CCPS??

 

I am taking the courses so that I can start teaching the courses, however, I have been told that for a process example (very simplified):

Mixing --> Baking --> Decorating --> Packaging --> Storage

 

Since Baking is a CCP, all the steps after Baking are ALL CCPs.

Here is my instructor's response:

 

"A CCP is a step or point in a process after which no further
action can be taken to eliminate, prevent or reduce a hazard. Baking is a CCP (it kills pathogens). If a
hazard is introduced at the decorating step the question to ask 'is there a subsequent step that will eliminate
the hazard? The answer is NO. Packaging doesn't kill pathogens, therefore decorating is a CCP. There are
no steps after packaging that would eliminate a hazard therefore packaging is also a CCP.
So, the steps BEFORE baking are safety steps and baking and all steps AFTER baking are CCP's."

 

Please give me some insight and feedback. I do not agree with this!!??? I find it very contradicting.

[Simon]

It doesn’t make sense to me either.  The hazards need to be assessed at each step to see if any are CCP’s.  You don’t naturally assume that every hazard at every step after a CCP is a CCP.  Not to my limited knowledge.

 

Regards,

Simon

[Charles.C]

Hi jtang,

 

It looks like yr instructor is applying a "narrow" interpretation of a CCP as compared to, say, Codex or NACMCF. 

 

This approach is (of course) likely to generate (relatively) numerous CCP counts. More typical of old-style haccp plans.

[trubertq]

As Simon says you need to risk assess each step to see if a hazard can be introduced at that stage. So your instructor is confused and needs to be recalibrated.

 

 

Ask him/her what hazard is being introduced at decoration?  see where that leads

[RALH]

As Simon says you need to risk assess each step to see if a hazard can be introduced at that stage. So your instructor is confused and needs to be recalibrated.

 

 

Ask him/her what hazard is being introduced at decoration?  see where that leads

[jtang]

As Simon says you need to risk assess each step to see if a hazard can be introduced at that stage. So your instructor is confused and needs to be recalibrated.

 

 

Ask him/her what hazard is being introduced at decoration?  see where that leads

THANK YOU!!!

And guess what... the instructor is a health inspector. Not all inspectors are instructors for this course, but alot of them are.

 

For passing purposes... I will submit it according to her old style HACCP. I think it's too over simplified meant to teach food service managers only.

 

However, the course material is taught to all instructors...........and they are asked to teach that way.

As a HACCP team leader..... i don't know what to say.

 

I'm taking the course to become an instructor (they need 90%), and I do not want to teach my students the wrong way.

[jtang]

By the way, here is her response, after I have explained how her way of assigning CCP is contradicting:

 

 

 

"The question to ask yourself is this:

If baking doesn't eliminate pathogen is there another step that will eliminate them?  NO. Baking CCP

If a hazard is introduced at Decorating is there anohter step that will eliminat the hazard? NO. Decorating CCP

If a hazard is introduced during packaging is there another step that will eliminate the hazard? NO. Packaging CCP

When you have identified a step in a process is a CCP then all further steps in that process are also CCPs."

[jtang]

I even pointed out that... the hazard introduced at packaging is a physcal hazard.................

how does that even apply..............

 

oh my.

[Charles.C]

Hi jtang,

 

Below is an example (2007) of how misinterpretations of HACCP procedures might occur.

 

Compare the first extract from the General Procedure and the following extract from the actual SOP. Notably “f”.

 

 HACCP - Questionable.pdf   27.04KB   28 downloads

 

Basically, IMO, yr instructor has an insufficient  understanding of the meaning of "significant".

 

It would be interesting to know the source of her CCP Guideline. It's called Validation.

 

Even Codex IMO blurs the Hazard Analysis stage by failing to elaborate the terms "potential" and "identified". Examples should have been included.

Textually,  IMO, NACMCF's explanation of hazard analysis is better presented than Codex. (Unfortunately  its section on CCP determination / Trees is IMO potentially confusing. It's examples may now also be factually out-of-date in some places.)

 

 NACMCF hazard guidelines.pdf   1.17MB   41 downloads

[SLadd]

Aside from my assumption that this instructor has never actually worked in a food industry and has no concept of the amount of work that goes into monitoring, verifying and validating CCPs, it seems they are starting their CCP decision process at question number 4 in the CCP Decision Tree and skipped the questions leading up to that ultimate decision. The first 3 questions are discussing control measures at the step, it doesn't start with looking at subsequent steps for elimination. First you have to determine if a control measure exist at that step. Such as baking or pasteurization, those are control measures. If decorating doesn't contain a control measure, if you're not adding preservatives to the icing to prevent growth, it would never be a CCP. I beg you, please don't conform to this teaching method. Think of those of us who have to verify all this paperwork, and what on earth we would be documenting at the decorating step. What is the critical limit for decorating? What science supports that limit? CCPs have to have measurable critical limits! Oh the humanity! This is the stuff that makes health inspections stressful. Not the inspection itself, but inspectors armed with half information.