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#1 harrypotterOZ

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Posted 25 May 2017 - 06:37 AM

Hi guys,

I have just joined a thermal processing plant and our team is currently revamping the HACCP plans and have now hit a road block.

 

Is this risk assessment valid?

 

We have a pressure vacuum monitor (PV monitor) that kicks out DUD (leakers/low vacuum) cans post process. In the past this step has been a QCP (potential hazard being the risk of outgrowth of spoilage micro-orgs) – last line of defense/point of check for the DUD cans.

 

Now pre-process, we do have a CCP - the 4 hourly can seam checks at the fill stations – and the control measure for this CCP is the PV monitor.  

So when we complete a risk assessment, if we mention the PV monitor to be a control measure for the can seam checks, do we still risk assess the PV monitor as a QCP or as a PRP?

 

I believe this is a QCP (set of the PV monitor and the hourly challenge test we do), but my team think this should be downgraded to a PRP - justification being the PV monitor itself does not introduce any hazard.

 

Been hitting my head on the wall with this for days now.. may be am over thinking but definitely need a bit of help.. Help please guys?

 

Thanks:)



#2 GMO

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Posted 25 May 2017 - 10:20 AM

First of all, this is HACCP so all mention of QCPs shouldn't be there.  If you have control points for quality, I strongly suggest they are put into a separate summary to avoid this kind of situation.

 

A monitor doesn't have to introduce hazard to be considered a CCP or a PRP, I don't know canning processes but it is worth considering whether non spoilage pathogenic micro organisms could be present at this stage if there is a seam failure.  Then you have your hazard; i.e.:

 

Hazard:  Presence of pathogenic micro organisms which could subsequently grow in the can, e.g. xxx due to inadequate can seam.

 

Control measure: Adequate can seam

 

Monitoring:  4 hourly seam checks and PV monitor

 

I am no expert but I would say both of these are monitoring your seam?  Is that not correct?  I don't think the PV monitor in itself is the control measure?  The control measure is having a good seam, the monitoring is then how you check that is the case?  Now on whether either or both of these are CCPs or PRPs, just take them through a decision tree.



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#3 Charles.C

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Posted 25 May 2017 - 12:07 PM

Hi Harry,

Is this relating to WQA Standard or ??

Pls inform.


Kind Regards,

 

Charles.C


#4 FurFarmandFork

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Posted 25 May 2017 - 03:22 PM

I would consider can seams to be a hazard inherent to your product if your product is Low-acid. The CCP could instead be like metal detection, where your requirement is to make sure the PV monitor is working correctly at a proper interval, and if you found it to be not working what would your corrective actions be? E.g. rework all cans through PV monitor once functional, dispose, etc.


QA Manager and food safety blogger in Oregon, USA.

 

Interested in more information on food safety and science? Check out Furfarmandfork.com for more insights!

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#5 harrypotterOZ

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Posted 25 May 2017 - 11:33 PM

Hey Charles,

 

No not for a WQA std.



#6 Charles.C

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Posted 26 May 2017 - 03:08 AM

Hey Charles,

 

No not for a WQA std.

 

Hi Harry,

 

It's difficult to address yr query because there is limited context.

 

You may get more directly useful answers if you can supply a little more detail, eg -

 

What Standard (if any) is yr haccp plan going to be audited to ?

 

What is the product ?

 

What is the basic flowchart ?

 

To illustrate the reasons for above queries, here is a (very) brief haccp timeline (cnn0) for canned fish followed by a few random examples of development stages noted in cnn0 -

 

Attached File  cnn0 - brief history of development of haccp plans for canned fish.pdf   65.28KB   20 downloads

Attached File  cnn1 - Canning haccp Checklist.pdf   139.24KB   23 downloads

Attached File  cnn2 - canned flowchart-CCP.pdf   36.63KB   15 downloads

Attached File  cnn3 - haccp plan,bottled cucumber.pdf   842.09KB   21 downloads

Attached File  cnn4 - fao haccp anaysis-plan,canned mushrooms.pdf   730.2KB   27 downloads

 

PS - i mostly concur with GMO's analysis. IMO the QCP is a "red herring" unless perhaps SQF Lvl3 is involved. or some other Aussie speciality. :smile:


Kind Regards,

 

Charles.C


#7 Tony-C

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Posted 26 May 2017 - 04:34 AM

Hi guys,

 

Now pre-process, we do have a CCP - the 4 hourly can seam checks at the fill stations – and the control measure for this CCP is the PV monitor.  

 

Help please guys?

 

Thanks:)

 

I am a little confused by your assessment and explanation. 

 

So there is a potential hazard of microbiological (including pathogens) contamination of faulty cans. You have two control measures in place:

a. Seam checks pre-process

b. PV Monitor post-process

 

Using a traditional decision tree the CCP would be the last step in the process where control is exerted (PV Monitor) but it could be a combination of these control measures.

 

Also assuming that the PV Monitor works and you can validate it works, it would also seem that this control measure is the more effective monitoring tool with 100% inspection when compared to the seam check every 4 hours.

 

Kind regards,

 

Tony



#8 harrypotterOZ

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Posted 26 May 2017 - 05:02 AM

I am a little confused by your assessment and explanation. 

 

So there is a potential hazard of microbiological (including pathogens) contamination of faulty cans. You have two control measures in place:

a. Seam checks pre-process

b. PV Monitor post-process

 

Using a traditional decision tree the CCP would be the last step in the process where control is exerted (PV Monitor) but it could be a combination of these control measures.

 

Also assuming that the PV Monitor works and you can validate it works, it would also seem that this control measure is the more effective monitoring tool with 100% inspection when compared to the seam check every 4 hours.

 

Kind regards,

 

Tony

Yes you are right with point a & b and how PV monitor is the last line of defense in the process and hence technically should be a CCP. And yes, 100% inspection is more effective than the 4 hourly seam tear downs. But this is what triggered the whole "confusion" in the team. 

But then this would mean the seam checks are not the last line of defense and hence not a CCP and we DEFINITELY do not want to downgrade seam checks to a CP.



#9 harrypotterOZ

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Posted 26 May 2017 - 05:10 AM

Hi Harry,

 

It's difficult to address yr query because there is limited context.

 

You may get more directly useful answers if you can supply a little more detail, eg -

 

What Standard (if any) is yr haccp plan going to be audited to ?

 

What is the product ?

 

What is the basic flowchart ?

 

To illustrate the reasons for above queries, here is a (very) brief haccp timeline (cnn0) for canned fish followed by a few random examples of development stages noted in cnn0 -

 

attachicon.gifcnn0 - brief history of development of haccp plans for canned fish.pdf

attachicon.gifcnn1 - Canning haccp Checklist.pdf

attachicon.gifcnn2 - canned flowchart-CCP.pdf

attachicon.gifcnn3 - haccp plan,bottled cucumber.pdf

attachicon.gifcnn4 - fao haccp anaysis-plan,canned mushrooms.pdf

 

PS - i mostly concur with GMO's analysis. IMO the QCP is a "red herring" unless perhaps SQF Lvl3 is involved. or some other Aussie speciality. :smile:

Thanks Charles, canned mushroom doc is quite informative- love it!!

Working to SQF LVL3 std..

Product - Soup (Low acid food)

Basic process flow: 

1. Receivals

2. Blending (Metal detectors, magnets, sieves etc are the CCPs)

3. Filling (Metal detector, check weigher, can closer, can coders are the CCPs)

4. Cooker (CCP)

5. Xray (CCP)

6. PV monitor (QHP currently)

7. Labelling line

8. Packers



#10 Tony-C

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Posted 26 May 2017 - 05:33 AM

Yes you are right with point a & b and how PV monitor is the last line of defense in the process and hence technically should be a CCP. And yes, 100% inspection is more effective than the 4 hourly seam tear downs. But this is what triggered the whole "confusion" in the team. 

But then this would mean the seam checks are not the last line of defense and hence not a CCP and we DEFINITELY do not want to downgrade seam checks to a CP.

 

I don't see a problem with having both as CCP's my main concern would have been that you had the PV monitor as a QCP. I don't think you can be criticised for having tight controls based on history/experience.

 

Kind regards,

 

Tony



#11 Philip Jones

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Posted 13 November 2018 - 07:44 PM

Hi,

Retired and not logged on very often, so I hope this response is still relevant.

 

I think there is considerable confusion here and missing the point.  For a CCP you have to have an absolute limit beyond which you will not go.  For the canning operation, this is typically the thermal processing and the achievement of a critical Fo value (for a botulinum kill). The critical limit applies to every can, not just the ones that are or could be checked.

The 4 hourly seam checks are just that 4 or 6 or whatever number of cans every 4 hours and this is used to predict trends in the performance of the seamers. This check is therefore a operational pre-requisite (or whatever jargon you are used to).  A similar arguement applies to kicking out faulty cans.  While it is desireable to kick out every can that may be faulty, there is no critical limit applicable. You may set 2 inches of vaccuum, but that isn't to say that every can wit 1.9 inches would be kicked out, or indeed that it was necessary. 

At the end of the day, the ruling authority is you, or more specifically how you have defined what is a CCP from your CCP decision tree.

If you want to make seams a CCP, for example, and you have a check that exceeds a dimensional CCP limit, you will have 4 hours of reject product to deal with - NO OPTION because it is a CCP failure. 

Think through a CCP and ask if you are happy (and I mean happy) to reject on that CCP failure when the time comes.  Better to be pragmatic and thoughtful in setting the CCP in the first place so you do not finish up rejecting tonnes of product unneccessarily.  I would have no hesitation dumping tonnes of product if one can might not have achieved Fo 3 even if most of them obviously had.  I would hesitate to automatically reject on a seam check, not saying I wouldn't, but I would want to analyse the situation and my data.  You shouldn't have that option with a CCP failure.  






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