10 replies to this topic

[tharinduth]

Hi everybody,

 

In our process we have a regulation from competent authority to keep our product's temperature below 60 degrees of Celsius at drying process. The reason for that is to maintain it's nutritional values. Since the start, temperature monitoring of drying step is the CCP.

 

While reviewing HACCP, we identified the real measurement is moisture level of the product which has direct influence for food safety.

 

My doubt is, can we change temperature to moisture as CCP while keeping temperature as OPRP?

 

We have scientific data to validate the moisture level as CCP at the process. 

 

Your prompt reply will be much appreciated . 

[Linekela]

I think you can as it came from your HACCP review and you have data to support that its moisture and not temperature that has an impact on food safety. 

[Jaskaran Singh Saini]

You can use moisture as a CCP in your food safety plan because microorganisms also depends on moisture value in food for growth

[FurFarmandFork]

Moisture is not the proper measurement for controlling microbial growth. You want to make sure you are measuring water activity, as lower moisture foods can still support the growth of microorganisms. If indeed you get your water activity low enough to prevent the growth of pathogens of concern then the temperature does not matter.

[Charles.C]

Hi everybody,

 

In our process we have a regulation from competent authority to keep our product's temperature below 60 degrees of Celsius at drying process. The reason for that is to maintain it's nutritional values. Since the start, temperature monitoring of drying step is the CCP.

 

While reviewing HACCP, we identified the real measurement is moisture level of the product which has direct influence for food safety.

 

My doubt is, can we change temperature to moisture as CCP while keeping temperature as OPRP?

 

We have scientific data to validate the moisture level as CCP at the process. 

 

Your prompt reply will be much appreciated . 

 

Hi tharinduth,

 

IMO, to provide a meaningful comment you need to explain how you have defined CCP/OPRP for yr iso-hazard analysis (sec.7.4.4) plus the logic used to validate activity (or perhaps moisture) as a specific CCP/OPRP.

 

I doubt that nutritional value is a safety-related criterion ?

 

There are so many different implementations of iso-haccp which are equally, auditorially, acceptable.

[tharinduth]

Hi tharinduth,

 

IMO, to provide a meaningful comment you need to explain how you have defined CCP/OPRP for yr iso-hazard analysis (sec.7.4.4) plus the logic used to validate activity (or perhaps moisture) as a specific CCP/OPRP.

 

I doubt that nutritional value is a safety-related criterion ?

 

There are so many different implementations of iso-haccp which are equally, auditorially, acceptable.

 

Hi Charles,

 

Well I prefer CCP as a major step in process which needs to control in order to prevent food poisoning by various hazards. In this drying step, I take moisture level as the control point and hopefully it may control unwanted microorganisms growth.

 

Nutritional value is not a safety related criterion which it may loose some vitamins if temperature is not controlled. Lack of those vitamins does not effect to the consumer's health.

 

I think that we were following wrong CCP which is temperature of product  (When we consider health effects) and I need to change it to moisture level. Scientific literature explains that control of moisture has direct influence of growth of microorganisms.  

 

So can I change CCP like that? 

 

Thank you for your comment and support. 

[tharinduth]

Moisture is not the proper measurement for controlling microbial growth. You want to make sure you are measuring water activity, as lower moisture foods can still support the growth of microorganisms. If indeed you get your water activity low enough to prevent the growth of pathogens of concern then the temperature does not matter.

 

Hi,

 

I accept your point. But still my doubt remain same. As I explained on above post, I need to know whether I can change CCP at same process step?

 

In a nutshell, 

 

Before                                                         Now

 

Temperature (CCP)                                     Temperature (OPRP)

Moisture                                                       Moisture (CCP)

 

 

Thank you for your comment and support. 

[Sean Archer]

Hi tharinduth,

 

Your intention is partially correct provided the authorised body accepts it. However, the intention suffers two distinct issues. Nutritional value of a food product is not a safety concern so you can freely move the control measure to a less stringent environment, like a process plan. You don't have to include it in a OPRP plan unless you have food safety concerns related to temperature.

 

So, to be brief, the authorised body ordered you to control the temperature. Their sole concern is nutrional value of your final product.

Your concern is bacteria and you want to control the moisture.

So what is the relation between the two? Why exchange? Do you think that you cannot control the temperature while you will control the moisture? Are you limited with the number of control points?

 

Kind regards,

[Charles.C]

Hi Charles,

 

Well I prefer CCP as a major step in process which needs to control in order to prevent food poisoning by various hazards. In this drying step, I take moisture level as the control point and hopefully it may control unwanted microorganisms growth.

 

Nutritional value is not a safety related criterion which it may loose some vitamins if temperature is not controlled. Lack of those vitamins does not effect to the consumer's health.

 

I think that we were following wrong CCP which is temperature of product  (When we consider health effects) and I need to change it to moisture level. Scientific literature explains that control of moisture has direct influence of growth of microorganisms.  

 

So can I change CCP like that? 

 

Thank you for your comment and support. 

 

Hi tharinduth,

 

With due respect, it's all about the specifics, not generalisations. Including  Validation.

 

For example hv a look at this excel / model hazard/haccp analysis for fssc22000 -

 

http://www.ifsqn.com...ge-4#entry50651

[tharinduth]

Hi tharinduth,

 

Your intention is partially correct provided the authorised body accepts it. However, the intention suffers two distinct issues. Nutritional value of a food product is not a safety concern so you can freely move the control measure to a less stringent environment, like a process plan. You don't have to include it in a OPRP plan unless you have food safety concerns related to temperature.

 

So, to be brief, the authorised body ordered you to control the temperature. Their sole concern is nutrional value of your final product.

Your concern is bacteria and you want to control the moisture.

So what is the relation between the two? Why exchange? Do you think that you cannot control the temperature while you will control the moisture? Are you limited with the number of control points?

 

Kind regards,

Hi Sean,

 

There is no relationship between two reasons behind temperature monitoring and moisture level. But it is a regulatory requirement to maintain temperature in specific limit.

 

Unfortunately, it was the CCP step when this process was certified. Since CCP is related to food safety, I tried to analyse and found out it should be changed.

 

We can not go over 60 degree Celsius (Due to regulatory requirement). If we can pass the limit, we can reduce the moisture level further.

 

My doubt is can we change the already certified CCP point in our process in to OPRP point? (In presence of validated and verified evidence) 

 

Thank you

[Sean Archer]

Hi tharinduth,

 

Sorry for delayed reply. When a regulatory requirement is concerned about food safety, you assign a control measure to comply with the requirement. The control measure (selected and evaluated as such) must be managed according to your food safety system. Any other regulatory requirement not concerning about food safety is not of interest to your food safety system. If you have a critical limit for the purpose of food safety and at the same time for a technological purpose, then you can manage the control measure in both environments. 

 

In your case, the temperature is required to be limited to max. 60 C because of nutritional value of the final product. You have to evaluate it further. If you think you'll have a food safety concern when the temperature drops below certain point, then you should manage it with your food safety plans, either HACCP plan or OPRP plan, depending on the severity and consequences of the food safety hazard.