10 replies to this topic

[Tschneider]

Hi there folks!

 

I am working on our HACCP program for a Coconut Oil production line.

 

One of the ardent discussions we had was if bulk receiving should be a CCP or not.

The FDA defines a CCP as "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." I've also heard it explained as "if you were to miss this control could it introduce significant risk?"

 

Given that I don't know what happens to the bulk during transport and that it is conceivable that the packaging gets ruptured and a foreign substance or object is introduced to the bulk (e.g. whatever is found on the forks of forklifts) I would argue that it is critical and the acceptable measure would be zero damaged bulk packaging.

Or if I don't verify what exactly the shipment is and I receive peanut oil instead of coconut it could cause introduction of a high risk allergen. Or some lot that expired 5 years ago.

 

Super likely no, but significant risk yes imho.

 

So to me that would seem a CCP or am I missing something? I mean to me that would almost always automatically be a CCP come to think of it.

 

Conversely Metal Detection is often listed as a CCP but there I for instance see much less of a likelihood of metal being introduced from the packaging machinery because there are no screws on the hopper or positioned anywhere above that could even fall in and if something else was to come loose it would be much more likely to disable the whole machine rather than get into the product undetected.

I would of course always rather err on the side of caution and run the stuff through a metal detector but it doesn't seem more critical to me than the Receiving Inspection.

 

Anyway I would really appreciate some enlightenment on this topic . 

 

Thanks!

 

 

[Charles.C]

Hi Tschneider,

 

welcome to the forum !

 

For "Receiving" step (and other haccp hazard decisions), yr query relates to the fundamentals of risk assessment (RA) as applied within haccp and has been argued round and round for the last 20 years or so within textbooks and the FS community. I daresay you are well aware of this already.

 

A simple but not very satisfactory comment is that the interpretations within  RA are  always subjective, eg how do you define "Significant" ?.

 

One solution (maybe aka a "workaround") which is implicitly proposed in the classic US haccp publication of NACMCF is to define receiving operations as a PRP, an option subsequently adopted by many, many people and FS Standards.

 

Metal detectors (MDs) are another RA  vexed case but classically considered slightly different to"receiving" in that they are regardable as a designed elimination control step. The well known 4-5 step decision trees have a query built into their chain specifically to generate a CCP for such cases. Again this can be regarded as a workaround in a purely RA oriented context.

 

MDs are also alternatively handled as PRPs, OPRPs amd monitors by some groups of haccp users. A question of RA interpretation.

 

The pragmatic answer to yr query is that yr choice is often determined by the FS Standard involved. Which is ?

 

PS - If you would like some reading time, i can recommend Mortimore et al's famous book on Practical haccp to read about this topic. but i can assure you that there is no black/white answer.

 

PPS - JFI, FSMA apparently do not conceptually agree with the PRP option  due, as i understand, particularly to the practical results with respect to recall statistics.

[Tschneider]

Thanks Charles!

 

I will look into the recommended reading materials.

 

Well, I guess this is indeed a bit of a can of worms (of course perfectly food safety controlled ones)...

 

One of my concerns was that our management more or less says that there are no CCP's for that product and I'm worried that this may be a little lax and if the good people from Siliker come by they wouldn't like it. We have a GMP audit coming up.

On the other hand the likelihood of metal being introduced is indeed very low, just as is the risk of bulk contamination. Which I suppose is overall a good thing.

I'm just not sure if I'm unduly worried or if maybe my boss is a bit too relaxed about this audit thing which we haven't had in years.

[QAGB]

Hi there folks!

 

I am working on our HACCP program for a Coconut Oil production line.

 

One of the ardent discussions we had was if bulk receiving should be a CCP or not.

The FDA defines a CCP as "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." I've also heard it explained as "if you were to miss this control could it introduce significant risk?"

 

Given that I don't know what happens to the bulk during transport and that it is conceivable that the packaging gets ruptured and a foreign substance or object is introduced to the bulk (e.g. whatever is found on the forks of forklifts) I would argue that it is critical and the acceptable measure would be zero damaged bulk packaging.

Or if I don't verify what exactly the shipment is and I receive peanut oil instead of coconut it could cause introduction of a high risk allergen. Or some lot that expired 5 years ago.

 

Super likely no, but significant risk yes imho.

 

So to me that would seem a CCP or am I missing something? I mean to me that would almost always automatically be a CCP come to think of it.

 

Conversely Metal Detection is often listed as a CCP but there I for instance see much less of a likelihood of metal being introduced from the packaging machinery because there are no screws on the hopper or positioned anywhere above that could even fall in and if something else was to come loose it would be much more likely to disable the whole machine rather than get into the product undetected.

I would of course always rather err on the side of caution and run the stuff through a metal detector but it doesn't seem more critical to me than the Receiving Inspection.

 

Anyway I would really appreciate some enlightenment on this topic . 

 

Thanks!

 

 

Hi Tschneider,

 

I agree with Charles; your receiving operation would be considered a PRP.

 

You should be getting a wash ticket or some sort of incoming report which states the previous commodity on the tanker prior to your receipt of coconut oil. That (in theory) should prevent you from receiving allergenic product. People in the receiving area need to know what to look for as far as what previous commodities are accepted; and what to do in the event when the previous commodity is not accepted.

 

As far as foreign material detection, we have an incoming filter between tankers and our oil lines. We check them after receiving each load. It's very course, and it's just the first line of defense in case we receive something unusual. We have 100 mesh filters with rare earth magnets inside just before filling bulk and retail oils to catch foreign materials. Our 100 mesh filters are our only CCPs in our oil processing area.

 

You would need to provide a risk assessment to show why you aren't using filtration or metal detectors in your process. Receiving is not where you would be eliminating or reducing your foreign material hazards, so you would need to look further downstream in your process in regarding to those hazards.

 

QAGB

[YACOOB]

If the coconut oil coming in is crude and still has to be processed then you can make the receiving step a QCP(QUALITY CONTROL POINT) because at this stage the material will be checked by the lab to confirm its coconut oil and not any other product and instructions then given for the offloading.

when the crude coconut oil goes through the process of refining the ccp's can then be defined as these are now the critical steps needed to ensure  a safe edible final product to be used .

[Charles.C]

Hi Yacoob,

 

Offhand, i don't recall "QCP" being mentioned in either Codex/haccp or NACMCF/haccp.

 

Where did it originate ?

[QAGB]

Hi Yacoob,

 

Offhand, i don't recall "QCP" being mentioned in either Codex/haccp or NACMCF/haccp.

 

Where did it originate ?

 

 

Hi Charles,

 

I have heard people who are under SQF certification use the QCP term (or very similar) to describe control points to reduce hazards for food quality; not necessarily food safety. For instance, controlling browning or crystallization in the sweetener industry. Neither of these two are food safety issues, but they would be food quality issues.

 

QAGB

[Tschneider]

If the coconut oil coming in is crude and still has to be processed then you can make the receiving step a QCP(QUALITY CONTROL POINT) because at this stage the material will be checked by the lab to confirm its coconut oil and not any other product and instructions then given for the offloading.

when the crude coconut oil goes through the process of refining the ccp's can then be defined as these are now the critical steps needed to ensure  a safe edible final product to be used .

Thank you all for the guidance!

 

As far as the coconut oil, it is virgin and unrefined but it will remain that way all the way to the consumer. It will come with CoA obviously but other than that nothing. I want to definitely at least put a screen in before the machine so that there is at least something that can catch contaminants and not just trust the supplier that the stuff is a-ok. 

[YACOOB]

_{QCP not terminology  generally found in the books, but  one we use to show auditors that we have control measures in place( more like prp's) where its not critical for food safety as yet but more quality as ccp's will only be put in place where the food safety measures are needed and for these you have to have more evidential proof like ,metal detectors.pressure and temperature monitors which some auditors insisted on being electronic to be able to print records,etc. and these are generally during certain processes  and at the last stage before it goes to the consumer.}

 

_thanks

[Charles.C]

_{QCP not terminology  generally found in the books, but  one we use to show auditors that we have control measures in place( more like prp's) where its not critical for food safety as yet but more quality as ccp's will only be put in place where the food safety measures are needed and for these you have to have more evidential proof like ,metal detectors.pressure and temperature monitors which some auditors insisted on being electronic to be able to print records,etc. and these are generally during certain processes  and at the last stage before it goes to the consumer.}

 

_thanks

 

Hi Yacoob,

 

Thks for reply.

 

Out of curiosity I also had a look round the IT.

 

QCP seems to be a very versatile entity. It even has its own (slightly confusing) decision tree (No.6) which looks remarkably similar to that of Codex. Some of its interpretations appear directly opposite to others.

 

(1) Your "CCP" labelling/packaging is likely to be such an oPRP (or 'Quality Control Point'), as it does not reduce or eliminate hazards, but ensures that already eliminated hazards (in previous processes) do not re-appear in the product, ether through chemical, physical or microbiological contamination or the outgrowth of surviving microorganisms.

http://www.ifsqn.com...ery/#entry46580

 

(2) A Quality Control Point is a control measure essential in order to control quality, service and business risks.It is used in various standards including the Woolworths Standard (WQA) for Manufactured Foods V8. In this standard, quality risks are provided almost equal importance as food safety.

http://www.asiafoodj...ntrol-measures/

 

(3) A Quality Control Point, commonly known as a QCP or CQP is a point, step, or procedure at which controls can be applied and a food quality hazard can be prevented, eliminated or reduced to acceptable risks.

http://www.foodindus...t-details?Id=65

 

(4) For each step, whether the ingredients/packaging supplies or the processing hazard analysis, we identify the biological, chemical and physical hazards and mechanisms for their control. You can then utilize a hazard evaluation summary to assist in identifying whether those mechanisms fall under prerequisite program (QCP) or are CCPs.

http://www.foodsafet...s-camera-haccp/

 

(5) QCP: Quality Control Point - A step in the process where a quality parameter may be controlled.

http://www.iopp.org/...g_HACCPPlan.pdf

 

(6) QCP Decision Tree

 QCP decision tree.png   88.29KB   0 downloads

www.intechopen.com/download/pdf/23468

[YACOOB]

Thanks, I can at least challenge a few auditors who question this and show them proof

thanks again very informative and helpful

 

thanks

 

Yacoob