HACCP CCP Yes or No?

HI Folks,

Apologies if this query has been covered elsewhere but I was looking for opinions please on whether a particular step is a CCP or not.

The scenario is of a chicken processor who receives whole chilled chicken carcasses which are then portioned into fillets, thighs, legs etc and then packaged and sold on. At one stage the chicken fillets pass through X ray to determine if they still contain bones and then proceed on to packaging if they dont. 

I have been challenged as to whether this x ray stage should really be identified as a CCP in the HACCP plan. My instinct says it depends on the supplier specification- if assurances are made to the customer that fillets are truly boneless fillets then yes, but if not the X ray stage should not be a CCP, because the customer must have some reasonable expectation of intrinsic physical contamination i.e. bones however small.

I am looking for a reasoned critique of this logic please - would you agree or disagree with the above?

Thanks

Regards

Stephen 

Hi,

I would say that the supplier check is part of the Pre requisite/Control Point (CP) rather then a CCP due to the fact that there are further processes (X ray) which will pick up the bones - I would have thought the X ray is the last point you will be able to see/find out if any bones are still in the product so this would be the CCP.

Hope this helps.

Regards

Chris

Thanks Chris, I guess what I am trying to link in here is the importance of supplier specifications in the CCP decision making process - if the specification ( to the customer) is that the fillets are boneless then sure it would be a CCP but if there is no guarantee to the customer that the fillets are boneless (they should therefore have reasonable expectation of intrinsic physical contaminant i.e. bones) does the X Ray still count as a CCP?

In my opinion yes, as either way this is your control on the material from the supplier - they can give you assurances regarding the product being free from bones but this will still not be anything in your control. 

This is why I would have supplier approval as a Pre-req - as information from suppliers (SAQ/ Specifications/HACCP/ Contamination controls in place and  statements etc) will give you this information you are right, but due to X rays being further in your process - this will stop/ eliminate any bones if controlled properly were as Supplier approval will not.

If this was the issue regarding bones in chicken if stated they wont be in the product that is when you move away from supplier. (eliminate issue)

Regards

Chris

Hi Stephen,

CCPs are based on risk assessment.

HACCP 101.

You need to decide whether the detector is "eliminating" a significant hazard to the consumer.

Hi Stephen,

 

CCPs are based on risk assessment.

HACCP 101.

You need to decide whether the detector is "eliminating" a significant hazard to the consumer.

Thanks Charles-  I do understand the importance of risk assessment- and not meaning to toy with semantics but are bits of bone in a chicken fillet a "significant" hazard to the customer, should the customer not have a reasonable expectation of bone/bone fragments if not otherwise stated to the contrary?

Like Charles said if you risk assess and cant guarantee the absence it may be you look at stating to customer - may contain chicken bones. etc. it depends on the size of the bone and the people that may eat it, i think there are Standards on what constitutes a foreign body hazard limit- (FDA touch on it)

I would see that from your HACCP scope you will have looked at who the product is to be suitable/ aimed at - and you will have looked at the physical/ chemical etc etc.. so your Hazards will be raised from this point which will complete a basis for your risk assessment.

Regards

Chris 

Thanks Charles-  I do understand the importance of risk assessment- and not meaning to toy with semantics but are bits of bone in a chicken fillet a "significant" hazard to the customer, should the customer not have a reasonable expectation of bone/bone fragments if not otherwise stated to the contrary?

Hi Stephen,

Based on the Codex definition of a CCP, You need to decide if it is essential for the consumer's safety to remove hazardous bones from the finished product.

If you think the answer is No, can remove the X-ray detector.

If you think the answer is Yes, the X-ray detector has "value" if it can eliminate hazardous bones and IMO would then be a CCP (assuming a likely occurrence).

Of course you first need to define a hazardous bone (IIRC various defs do exist for fish but chicken no idea).

https://www.fda.gov/.../ucm074554.htm 

This is FDA site but gives you background information to help your case regarding this...

https://www.fda.gov/.../ucm074554.htm 

 

This is FDA site but gives you background information to help your case regarding this...

Hi beadle,

Thks but in FFox the link is working but only goes to "index". Probably FDA changed it.

Ok, well here is a extract from this for instance regarding size:

Hard or sharp natural components of a food ( e.g. bones in seafood, shell in nut products) are unlikely to cause injury because of awareness on the part of the consumer that the component is a natural and intrinsic component of a particular product. The exception occurs when the food="s" label represents that the hard or sharp component has been removed from the food, e.g., pitted olives. The presence of the naturally occurring hard or sharp object in those situations (e.g., pit fragments in pitted olives) is unexpected and may cause injury. FDA has established Defect Action Levels for many of these types of unavoidable defects in other Compliance Policy Guides and therefore they are not subject to the guidance in this document.

Ok, well here is a extract from this for instance regarding size:

 

Hard or sharp natural components of a food ( e.g. bones in seafood, shell in nut products) are unlikely to cause injury because of awareness on the part of the consumer that the component is a natural and intrinsic component of a particular product. The exception occurs when the food="s" label represents that the hard or sharp component has been removed from the food, e.g., pitted olives. The presence of the naturally occurring hard or sharp object in those situations (e.g., pit fragments in pitted olives) is unexpected and may cause injury. FDA has established Defect Action Levels for many of these types of unavoidable defects in other Compliance Policy Guides and therefore they are not subject to the guidance in this document.

Thks.

I think the link is -

https://www.fda.gov/...l/ucm074554.htm

looks same as yours to me but ..........

Indeed, i hv seen similar arguments for fish fillets but i always included bone as a significant hazard regardless of labelling. User-friendly. :smile:

(in contrast I doubt that i would consider shell or olive pits as significant hazards)

addendum

hi Stephen,

If you really wanted to keep the x-ray in the line, i suppose you could simply claim that it was present for quality purposes only (ie removing "non-hazardous") bones so could simply ignore it in the hazard analysis (ie no hazard due bones at X-ray step).

I predict that auditors will be doing a bit of head-scratching though.

Chicken fillets should not have bone......are you using the tender only or boning out the whole breast into fillets?  Either way, (as a poultry person myself) the Xray should stay as a CCP....when the consumer is buying chicken fillets the expectation is that they are boneless, just like if i'm buying a strip loin steak; I know it was cut off a bone at some point, but DO NOT expect there to be bone fragments on it as it is a BONELESS steak.

You are opening yourself up to a nightmare by making it "customer specific" in your plan. 

Either leave it as a CCP or remove it from the facility altogether

Again, fillets are boneless....there is NO expectation of the consumer that they contain bone fragments

and to be honest, depending on your packaging speed, the operational verification shouldn't take but 2 minutes at each check. Just run your set point slides through the detector, ensure that they were all rejected by the xray, record and move on

Thanks Folks very illuminating,

Much appreciated

Are the current controls effective? i.e do you detect pieces of bone at the x ray stage If the answer is No, then you could argue that the x ray equipment is not critical for food safety. Sometimes we get tied with the semantics of what we call  the step rather than asking the question - are the current controls effective? Either way, you need to  justify your decision based on objective evidence - nothing detected at the Xray stage and no customer complaints of bone will provide the evidence that the supplier has effective controls in place. 

Are the current controls effective? i.e do you detect pieces of bone at the x ray stage If the answer is No, then you could argue that the x ray equipment is not critical for food safety. Sometimes we get tied with the semantics of what we call  the step rather than asking the question - are the current controls effective? Either way, you need to  justify your decision based on objective evidence - nothing detected at the Xray stage and no customer complaints of bone will provide the evidence that the supplier has effective controls in place. 

Hi Ken,

Nice to hear from you. 

From a purely safety POV, it comes back to the hazardous bone concept IMO. And the target consumer.

I suspect the FDA viewpoint quoted in Post 11 is partially intended to obviate the US draconian adulteration add-on which entraps, for example, contamination due small metal particles.

No idea about chicken but definitions for "hazardous bones" exist in the seafood industry and may be considered to identify a significant hazard, particularly where larger fish sizes are concerned.

Some Standards/Companies use a scoring method + X-ray data which attempts to combine Quality with Safety. 

I agree customer complaints are relevant but I suspect under-reporting for this "hazard" is prodigious (myself for one).