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How to set critical limits for something that hardly ever happens?

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QARegulatoryProfessional

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Posted 06 April 2017 - 02:44 PM

We are a facility that receives bulk spices and teas. We rely on our suppliers to send us treated products free of foreign objects but there is always the likelihood a stone, piece of wood, burlap packaging, etc.being found when processed through our bulk bagging machine. I am stating this as a CCP in our HACCP plan - how do I set critical limits for an object that is hardly ever found but it has happened? Will my critical limits be the size of the object? 



Charles.C

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Posted 06 April 2017 - 02:56 PM

We are a facility that receives bulk spices and teas. We rely on our suppliers to send us treated products free of foreign objects but there is always the likelihood a stone, piece of wood, burlap packaging, etc.being found when processed through our bulk bagging machine. I am stating this as a CCP in our HACCP plan - how do I set critical limits for an object that is hardly ever found but it has happened? Will my critical limits be the size of the object? 

 

 

What is the control measure ? Eyes ?

 

Apparently rare.

 

>> risk = low x medium = Low

 

Difficult to see how you can justify as a CCP unless you use a highly risk-averse matrix


Kind Regards,

 

Charles.C


Charles.C

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Posted 06 April 2017 - 03:26 PM

addendum

 

You could employ a little subjective risk assesssment to support a CCP as commonly employed for metal detectors but you will still need a control measure of some sort/somewhere., eg a sieve.


Kind Regards,

 

Charles.C


FurFarmandFork

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Posted 06 April 2017 - 05:31 PM

Same as above. Wouldn't see it as a CCP. You might have a quality check during your runs that identifies a certain number of foreign objects that results in rework-reinspection for removal (e.g. something happened where a torn up bag was dumped into the equipment). Otherwise this is just monitor and document the risk to safety when it occurs. Kind of like a pest finding. It's not a CCP, rarely occurs, and you deal with it incident-by-incident.


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foodsafety4all

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Posted 07 April 2017 - 12:59 PM

We are a facility that receives bulk spices and teas. We rely on our suppliers to send us treated products free of foreign objects but there is always the likelihood a stone, piece of wood, burlap packaging, etc.being found when processed through our bulk bagging machine. I am stating this as a CCP in our HACCP plan - how do I set critical limits for an object that is hardly ever found but it has happened? Will my critical limits be the size of the object?

Good question

Thanks for raising this issues

First of all refer your maximum permissible foreign matter defined by local legal requirements of that particular products.
And practical maximum achievements of foreign matters by regular trend analysis.
3rd your expectations to fulfill customer requirements.
1st and 3rd definitely determine your critical limits.
Zero tolerance of foreign matters means CCP limit of foreign matters (any) shall be nil
Control measures shall be anything
1. Manual sorting
2. Mechanical sorting
3. Metal separator

One more thing in any condition or circumstances limit shall not be more than or less than of legal requirements

I hope you would have been satisfied with the reply.

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Charles.C

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Posted 07 April 2017 - 01:29 PM

Good question

Thanks for raising this issues

First of all refer your maximum permissible foreign matter defined by local legal requirements of that particular products.
And practical maximum achievements of foreign matters by regular trend analysis.
3rd your expectations to fulfill customer requirements.
1st and 3rd definitely determine your critical limits.
Zero tolerance of foreign matters means CCP limit of foreign matters (any) shall be nil
Control measures shall be anything
1. Manual sorting
2. Mechanical sorting
3. Metal separator

One more thing in any condition or circumstances limit shall not be more than or less than of legal requirements

I hope you would have been satisfied with the reply.

Sent from my E2363 using Tapatalk

 

Hi fs4a,

 

This is a HACCP-related query.

You need to refer to safety-related  hazards.

But thanks anyway.


Kind Regards,

 

Charles.C


foodsafety4all

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Posted 07 April 2017 - 03:10 PM

Hi fs4a,

This is a HACCP-related query.
You need to refer to safety-related hazards.
But thanks anyway.

Please don't mind

I knew this is haccp related query and safety aspect is foreign contamination like stone, pebbles, stems, dry parts of plants of same or other agricultural commodity.

They have already discussing of CCP limits for received materials. they have following option
to change the supplier to make approved supplier or
giving food safety training to them what they are expecting from them or
Apply control measures themselves as mentioned in above post

I have talked about the implementation part of haccp not of documentation type





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Charles.C

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Posted 07 April 2017 - 03:15 PM

Pls refer Post 2

Thanks


Kind Regards,

 

Charles.C


CMHeywood

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Posted 13 April 2017 - 05:11 PM

Risk Level = Frequency x Severity.  This is not the same as a critical limit?

 

Isn't a critical limit what level of contamination you would accept?  None?  Anything less than 2mm in diameter is acceptable?  Nothing detectable by visual inspection?





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