Hi Charles,
Thanks for your feedback and the attached pdf.
After all this conversation above and after having read several HACCP examples in the Web in the past and recently, I will finally agree that HACCP is subjective rather than objective.
At the end of the day, it is about what one wants to prevent and why. So, if one does not (fully) trust (for whatever reason) the effectiveness of PRPs it is one's choice to work with more (rather than with less) significant risks (after the RA) and define more (rather than less) CCPs where critical limits exist and real time monitoring is possible.
Having said this, I guess I will insist on considering cold storage a CCP (e.g. for B) for the following reasons:
- There is a critical limit regarding the temperature (for example < 5 oC) and this is the beginning of the danger zone...
- Cold storage temperature can (and should) be monitored in real time and if any deviation occurs, then immediate corrections (and last but not least appropriate corrective actions) are required.
- The CCP definition includes also the word 'prevention' of a hazard, which is a fact in cold storage (the growth of pathogens is becoming very slow, in a way it is prevented, provided that the critical limit is not exceeded, otherwise ---> danger zone!)
- Now, although not a microbiologist myself, I do not want to play guess games with pathogens and their toxins or spores if cold storage is not controlled properly and strictly in real time and the danger zone is reached..... thus, even cooking is likely not to be effective if cooking temperature is only 75oC.....Pathogens and their toxins and spores cannot be monitored and measured in realtime (not yet, unfortunately). One more reason why I consider cold storage a CCP.
It is, finally, a choice isn't it?
So, I do not want to rely anymore (at least not fully) on any decision tree which (obviously) does not include all parameters that can appear in the real world.
Thanks for your response. I find this forum really great. A lot to discuss and to learn from.
PS: Thanks for suggesting ISO 22002-1. I do currently have ISO 22002-2. I will also obtain ISO 22002-1 sooner or later.
Hi loannis,
Another factor which has not been discussed here is haccp "politics". If you have a look at older haccp plans, eg ca. 1990 era, you will see that they typically contained a multitude of CCPs, sometimes at virtually every step of a Process (eg, see following pdf). The consequence was a documentation nightmare.
USDA haccp plan refrigerated foods,1994.pdf 218.41KB
17 downloads
Afaik the haccp concept of PRP was (subjectively),"tacitly" expanded so as to ameliorate the multi-CCP situation (ie reduce number of CCPs) around 2000 as can be seen in this list of PRPs in the well-known, foundational haccp system proposed by USFDA in 1997 -
Examples of Common Prerequisite Programs
The production of safe food products requires that the HACCP system be built upon a solid foundation of prerequisite programs. Each segment of the food industry must provide the conditions necessary to protect food while it is under their control. This has traditionally been accomplished through the application of cGMPs. These conditions and practices are now considered to be prerequisite to the development and implementation of effective HACCP plans. Prerequisite programs provide the basic environmental and operating conditions that are necessary for the production of safe, wholesome food. Common prerequisite programs may include, but are not limited to:
Facilities: The establishment should be located, constructed and maintained according to sanitary design principles. There should be linear product flow and traffic control to minimize cross-contamination from raw to cooked materials.
Supplier Control: Each facility should assure that its suppliers have in place effective GMP and food safety programs. These may be the subject of continuing supplier guarantee and supplier HACCP system verification.
Specifications: There should be written specifications for all ingredients, products, and packaging materials.
Production Equipment: All equipment should be constructed and installed according to sanitary design principles. Preventive maintenance and calibration schedules should be established and documented.
Cleaning and Sanitation: All procedures for cleaning and sanitation of the equipment and the facility should be written and followed. A master sanitation schedule should be in place.
Personal Hygiene: All employees and other persons who enter the manufacturing plant should follow the requirements for personal hygiene.
Training: All employees should receive documented training in personal hygiene, GMP, cleaning and sanitation procedures, personal safety, and their role in the HACCP program.
Chemical Control: Documented procedures must be in place to assure the segregation and proper use of non-food chemicals in the plant. These include cleaning chemicals, fumigants, and pesticides or baits used in or around the plant.
Receiving, Storage and Shipping: All raw materials and products should be stored under sanitary conditions and the proper environmental conditions such as temperature and humidity to assure their safety and wholesomeness
Traceability and Recall: All raw materials and products should be lot-coded and a recall system in place so that rapid and complete traces and recalls can be done when a product retrieval is necessary.
Pest Control: Effective pest control programs should be in place.
Other examples of prerequisite programs might include quality assurance procedures; standard operating procedures for sanitation, processes, product formulations and recipes; glass control; procedures for receiving, storage and shipping; labeling; and employee food and ingredient handling practices.
https://www.fda.gov/...tion-guidelines
The iso22002-X series further delineated/amplified the above in order to permit fssc22000 to be a GFSI-recognized rendition of iso22000.
Nonetheless, it is definitely still possible to find modern haccp plans which do retain chilled storage as CCP, eg -
haccp guide,2017.pdf 529.37KB
29 downloads
The FSMA approach afaik avoids using trees. An analogous methodology is IMO excellently illustrated by the detailed haccp plans on this website -
https://meathaccp.wisc.edu/
Many haccp tree users now implement later modifcations of the original Codex tree, eg Campden tree. This inserts a simple PRP query step prior to Codex tree which can be a great time saver.
Campden CCP tree.pdf 62.46KB
37 downloads
PS - referring back to yr last post, in the context of user's choice, it now seems an established approach in a risk assessment to concentrate on the likelihood of occurrence of the actual hazard > severity > mediation by any subsequent step > consumer risk. TBH when you initially mentioned "cold storage" I interpreted this as deep-frozen, -18degC storage, not chilled refrigeration at ca.2-5 degC.
For deep-frozen, I cannot recall ever seeing an instance in routine use of an actual hazard (ie micro.growth) occurring (after all the operational safety tolerance is enormous). And, from what I have so far seen in the Literature, the chilled scenario is not that much different in practice unless perhaps substantial storage times/shelf lives are targeted). So, if a low likelihood is historically-supported, the majority of risk matrices will IMO indicate a non-significant hazard.
Nonetheless I respect any decision to implement a CCP due to a particular situation/hazard. Ultimately, it's your haccp of course. 