5 replies to this topic

[Wallie]

Dear Forum,

 

We are a wine bottling facility, that have two listed CCP's that I inherited from the previous QA Manager. From what I understand, based on other bottling facilities, one does not need to have CCP's. My question, how can I go about changing the HACCP plan to remove the CCP's and implement only CP's instead? Is this acceptable?

 

 

[jcohen246]

My understanding is that you should do (and document) a risk assessment to determine if it should rightfully be a CP or CCP.

[Charles.C]

Dear Forum,

 

We are a wine bottling facility, that have two listed CCP's that I inherited from the previous QA Manager. From what I understand, based on other bottling facilities, one does not need to have CCP's. My question, how can I go about changing the HACCP plan to remove the CCP's and implement only CP's instead? Is this acceptable?

 

it's called revalidation.

[Irishlass105]

Hiya,

 

I was in the same boat and had 1 CCP (the only CCP on site) in my HACCP plan and it actually isn't a CCP at all, it is a quality control. During the HACCP review I just kept getting no on the decision tree and the other members of the team backed me up.

 

I just completed BRC and they noticed the CCP was removed. They were more than happy as I was fit to justify why it wasn't a critical control point, I had flow challenges completed by all HACCP members and all relevant information was noted on the HACCP review minutes.

 

The auditor and his witness both said they have no right to tell me whether or not it is a CCP - if i can justify it, they cant argue it.  Have your story straight and maybe back it up with industry knowledge and you wont have any issues.

 

Good luck,

IL

[trubertq]

Yep, as Irishlass said, carry out a HACCP review, document the changes and the reasoning and you're all good.

[Charles.C]

Hiya,

 

I was in the same boat and had 1 CCP (the only CCP on site) in my HACCP plan and it actually isn't a CCP at all, it is a quality control. During the HACCP review I just kept getting no on the decision tree and the other members of the team backed me up.

 

I just completed BRC and they noticed the CCP was removed. They were more than happy as I was fit to justify why it wasn't a critical control point, I had flow challenges completed by all HACCP members and all relevant information was noted on the HACCP review minutes.

 

The auditor and his witness both said they have no right to tell me whether or not it is a CCP - if i can justify it, they cant argue it.  Have your story straight and maybe back it up with industry knowledge and you wont have any issues.

 

Good luck,

IL

 

I would add one caveat. If yr process is one which is frequently audited elsewhere and a stage which you consider is not a CCP is generally in the auditor's experiences designated otherwise, auditors will IMEX not be readily "satisfied". Metal detectors are a classic example. Or, in the contrary situation, the lack of.

 

The reality is that both opinions may be (haccp)  justifiable but auditors IMEX go for "consistency".

 

The trend to expand the scope of PRPs has also increased the chance of disagreements.