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FlotoYo

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Posted 30 May 2018 - 11:08 PM

 I've downloaded two versions of a decision tree from online and they indicate that EVERYTHING is a CCP. Not wearing gloves when packaging chocolate bars can transfer biological hazards.

 
the tree asks if it is "sufficient likelihood"?
 
Is the answer "NO" because I have prerequisite programs training staff to wear gloves or is the answer "YES" because it is sufficiently likely that an unwashed, ungloved hand holding ready to eat food will definitely transfer biological hazards to the food.
 
I've hired THREE consultants and NO ONE seems willing or able to give me a yes or no question to my answer on what a CCP is to an SQF audit.
 
Can someone PLEASE help me?
 
Is it a CCP to cook egg whites to a killing temperature if the egg whites arrive at my facility already pasteurized? Is it NOT a CCP because they have been pasteurized and just a CP because we want to kill anything that COULD grow in moisture but isn't a CCP because we don't need to worry about it already having a biological hazard?
 
I'm so frustrated right now. I can't finish any of my HACCP analyses until I have a better education on what a CCP is. And the "decision Tree" is worthless, it's COMPLETELY open to interpretation.
 
Can anyone help?


Charles.C

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Posted 31 May 2018 - 01:29 AM

Hi Flotoyo,

 

You have posted in SQF Packaging Forum but are talking about Food.

 

Please clarify the kind of Product/Process you are involved with.

 

HACCP tends to assume a technical background (ie BCPA familiarity) is available. Do you have this already ?

 

HACCP utilises Risk Assessment. HACCP is still evolving. Risk assessment is by definition subjective = you can expect  "experts" may not always agree.

 

There are many presentations available on "doing" a hazard analysis and determining CCPs, eg Codex, NACMCF, ISO. Which one are you attempting to implement ?.

 

Actually I suspect your difficulties have probably been experienced by most of the regular Posters here and many of us have had to choose a preferred "Way to Go" which is auditorially acceptable. However you will see many different but equally acceptable flavours of haccp utilised on this forum.

 

To illustrate yr problem, but not necessarily provide an instant solution, see these documents -

 

Attached File  ccp1 - Unlocking Control Measures in Food Safety.pdf   409.58KB   91 downloads

Attached File  ccp2 - Determining-control-measures in HACCP,Safefood.pdf   1.15MB   70 downloads

 

PS - as it happens, for traditional haccp, I have never, ever, used  Decision Trees to determine a Process CCP. But Consultants usually prefer them for training since they are, at least in theory, easier to use/formalise for routine purposes.

I use Risk Matrices directly but this also IMEX necessitates some selectivity so as to achieve logically consistent results.

 

PPS - Hint - afaik, in traditional haccp, Decision Trees (except dedicated raw material ones)  were/are intended to be applied to MANUFACTURING STEPS only. Hygiene related aspects are controlled by system-wide PRPs. (Some modern haccp treatments have expanded the use of PRPs to involve the Process also).

The newer Tree versions insert a Prerequisite query (= Not Significant Likelihood of Occurrence) at the beginning of Codex model chain.

 

P3S - the best haccp learning text I have found is "Practical Haccp" by Mortimore et al but no single volume is likely to answer all yr queries.


Edited by Charles.C, 31 May 2018 - 05:04 AM.
expanded

Kind Regards,

 

Charles.C


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Gerard H.

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Posted 31 May 2018 - 07:54 AM

Dear Floto Yo,

 

It seems that you are mixing the different steps and definitions during the development of your HACCP plan. That leads to confusion.

 

You need to take some distance sometimes and to go back to the definitions. And apply a step by step approach.

 

The answer for the gloves is NO CCP. By walking through your decision tree it will justly fall in the option that it's in your prerequisite program. There it stops. And then you pass to the next process step.

 

For the egg white, it can't be said from distance, without knowing any context. But here are some elements to consider:

  • The Risk = The risk that the hazard manifests itself at the consumer
  • The intensity of the risk. Is the risk sufficiently high (sufficient likelihood)?

Kind regards,

 

Gerard Heerkens



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Scampi

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Posted 31 May 2018 - 01:34 PM

Critical Control Point by definition is 

A critical control point (CCP) is defined as a step which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level, when there are no subsequent steps that would assist in reducing or eliminating the hazard to an acceptable level. 

 

To use your glove example

Are hands carriers of bacteria ----YES

Will a subsequent step reduce the hazard to an acceptable level---YES  (handwashing refer to your PRP)

Bam-your done

 

 

You may find this helpful. CFIA has a hazard database. It is a bit cumbersome (because it's HUGE) but covers all hazards (that are not site specific) related to either process step, ingredient or cross contamination point.

http://www.inspectio...9/1384900941583

 

CFIA combined form 8 (hazard anylsis and CCP decision tree together)

http://www.inspectio...035?chap=4#s8c4


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FlotoYo

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Posted 31 May 2018 - 02:05 PM

Thank you all for responses. Here again: One person says glove wearing IS a CCP and another says it is NOT.  

 

We are a food manufacturing facility, and I didn't know exactly where to post this question, we produce ready to eat (low risk) bars, and package them on site.

 

Is a CCP no longer considered a CCP if we have ample prerequisite programs in place to lower the "likelihood". It is very unlikely that a team member will go to the bathroom, not wash their hands, and touch a bar with their bare hands because I have GMPs in place, they all get food handler certified, and we maintain visual control with a team leader on the floor at all times.

 

Is it true that if I list something as a CCP, an auditor will require sufficient records and validation for that step? 



Scampi

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Posted 31 May 2018 - 02:42 PM

YES---CCP must be VALIDATED

 

All other PRPs need to be monitored regularly--like you said visual inspection with the team leader as well as annual training.

 

The portion of SQF that will look at CCPs in your HACCP portion, steps 1 through 12. 

 

CCP are CRITICAL control points

 

For example at my plant, pH MUST be below 4.6 (by law) and our threshold is actually 4

So, each batch has samples taken and pH is measured at 24-36 hours and again at 30 days. PRODUCT CANNOT LEAVE WAREHOUSE  until the 30 days have passed. We need to VERIFY that the pH meets Critical Limits. If it does not---product automatically needs reworked or condemned--as it cannot be guaranteed to be safe. Therefor a CRITICAL CONTROL POINT

 

Still using my plant as an example, employee A does not wash hands entering the plant, now it is still a non conformity, but it is not LIKELY to cause harm (due to the nature of our process)

 

 

https://myhaccp.food...rol-points-ccps

 

http://www.ifrj.upm....) 2017/(40).pdf

 

 

When you are trying to work through this---REMOVE SQF from your equation---CCP determination is a part of HACCP and as such is one step removed from 3rd party certification

 

CCP validation requires multiple worst case scenario data captures, say for blast chilling, or kill step, or employee hygiene (hand swabs) for high care/high risk and is a lengthy process. HOWEVER, each year you would simply need to validate that NOTHING in the process has changed since the original validation

 

Do you have formal HACCP training?


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FlotoYo

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Posted 31 May 2018 - 03:16 PM

YES---CCP must be VALIDATED

 

All other PRPs need to be monitored regularly--like you said visual inspection with the team leader as well as annual training.

 

The portion of SQF that will look at CCPs in your HACCP portion, steps 1 through 12. 

 

CCP are CRITICAL control points

 

For example at my plant, pH MUST be below 4.6 (by law) and our threshold is actually 4

So, each batch has samples taken and pH is measured at 24-36 hours and again at 30 days. PRODUCT CANNOT LEAVE WAREHOUSE  until the 30 days have passed. We need to VERIFY that the pH meets Critical Limits. If it does not---product automatically needs reworked or condemned--as it cannot be guaranteed to be safe. Therefor a CRITICAL CONTROL POINT

 

Still using my plant as an example, employee A does not wash hands entering the plant, now it is still a non conformity, but it is not LIKELY to cause harm (due to the nature of our process)

 

 

https://myhaccp.food...rol-points-ccps

 

http://www.ifrj.upm....) 2017/(40).pdf

 

 

When you are trying to work through this---REMOVE SQF from your equation---CCP determination is a part of HACCP and as such is one step removed from 3rd party certification

 

CCP validation requires multiple worst case scenario data captures, say for blast chilling, or kill step, or employee hygiene (hand swabs) for high care/high risk and is a lengthy process. HOWEVER, each year you would simply need to validate that NOTHING in the process has changed since the original validation

 

Do you have formal HACCP training?

 

Hi, thank you for your time! Yes, I received training. In retrospect it was not particularly good training, and even with the training, and hiring consultants, its really challenging to arrive at solid answers. So I really appreciate your time.

Most of our products are fairly low risk (ready to eat chocolate bars, all ingredients coming into our facility are pasteurized, QC controlled by suppliers, or blanched, before coming to my kitchen.) The main risks are allergen associated cross contaminations.It concerns me to have so few CCPS on my HACCp, I'm afraid it's wrong and will alert the auditor. I will do a risk assessment on all my ingredients, and list the controls I have in place for each, and hope that shows them I am conscientious about my process.

 

As a tiny company, it's really hard to provide clear validation. If glove use is a CCP, I have to validate my control, and my laboratory has not been built yet. Is 7 years of data showing no customer illnesses proof that we are doing things correctly? Some people say yes, and others no, so I hesitate to make glove use a CCP because I don't have microbial analysis data.

 

We are building a laboratory but it won't be ready in time for our first certification and audit.

 

Is a Certificate of Analysis showing that nuts arriving at my facility are pathogen free enough validation of low risk on nuts? they are treated before arriving, and I also have a secondary kill step (oven roasting). Is the subsequent step a Control Point? Some say it's a CCP because it kills pathogens, but others say it's just a CP because the nuts arrive to me with certificates showing pathogen levels are low/not present.



Charles.C

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Posted 31 May 2018 - 03:39 PM

It's strange how so many posters believe  their products are low risk.

 

As i understand you are directly handling pre-pasteurised RTE items with no further thermal treatment in yr own process ?

 

But perhaps I have guessed wrong as to yr specific process.


Kind Regards,

 

Charles.C


FlotoYo

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Posted 31 May 2018 - 03:56 PM

It's strange how so many posters believe  their products are low risk.

 

As i understand you are directly handling pre-pasteurised RTE items with no further thermal treatment in yr own process ?

 

But perhaps I have guessed wrong as to yr specific process.

 

Thank you, No, we have a secondary kill step. So, example, I receive blanched hazelnuts, with COA on each delivery (showing no negative microbial activity). I also then roast those in an oven for 30 minutes. That is a secondary kill step. But my auditing consultant has indicated we don't have to call it a CCP. He said we should call it a CP: we record the temperature of oven, roast time, sign each recipe each time, monitor calibration on ovens, wear gloves during handling, and train staff in GMPS on proper sanitary handling.

 

He thinks we can avoid having to send out sample batches of our roasted nuts because of all the PRPS we have.

 

Another example: egg whites come to us pasteurized, we store them frozen at all times until use, we monitor the thawing process, and in the cooking process we roast at high heat for 45 minutes. So he calls that, again, a CP and not a CCP

 

I'm hearing from most everyone that it is subjective. And I'm hoping that these kill steps and our monitoring of these additional controls indicate that the risk does not categorize it as "sufficient likelihood", and therefore is not a CCP.



Charles.C

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Posted 31 May 2018 - 04:48 PM

Thank you, No, we have a secondary kill step. So, example, I receive blanched hazelnuts, with COA on each delivery (showing no negative microbial activity). I also then roast those in an oven for 30 minutes. That is a secondary kill step. But my auditing consultant has indicated we don't have to call it a CCP. He said we should call it a CP: we record the temperature of oven, roast time, sign each recipe each time, monitor calibration on ovens, wear gloves during handling, and train staff in GMPS on proper sanitary handling.

 

He thinks we can avoid having to send out sample batches of our roasted nuts because of all the PRPS we have.

 

Another example: egg whites come to us pasteurized, we store them frozen at all times until use, we monitor the thawing process, and in the cooking process we roast at high heat for 45 minutes. So he calls that, again, a CP and not a CCP

 

I'm hearing from most everyone that it is subjective. And I'm hoping that these kill steps and our monitoring of these additional controls indicate that the risk does not categorize it as "sufficient likelihood", and therefore is not a CCP.

 

Yes, highly debatable IMO. A designated (final) killing step which is not a CCP. Very innovative.

 

Just for comparison, my process involves receiving cooked peeled shrimp which we steam again to "eliminate" any pathogenic bacteria. All our auditors require our thermal treatment to be identified as a CCP.


Kind Regards,

 

Charles.C


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Posted 31 May 2018 - 05:54 PM

Perhaps not a "final" kill step. The roasted nuts are then being introduced to other ingredients which could possibly recontaminate the final product which does not have a kill step, so I would also agree with Flotoyas consultant that the oven roasting of the nuts would not be a CCP as it is not the last step processing step for those/that ingredient and pathogens could be reintroduced.


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Charles.C

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Posted 31 May 2018 - 06:48 PM

Perhaps let the Codex Tree be the Process referee. = Q2 ?


Kind Regards,

 

Charles.C


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Posted 31 May 2018 - 07:06 PM

Hi bro,

I am also agreed with all Hand washing is not CCP, its rather covered PRP.

Records of PRP shall be the availability of hand washing facility with proper supplies of hand washing material; personal hygiene policy and training records.

 

Regarding Pastured egg is CCP or not, its looks like it is not but I can answer on YES or NO unless see the process; there are associated risk in the vicinity itself needs to be reviewed.

 

Kind regards

Muhammad Inamuddin 



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Posted 31 May 2018 - 07:38 PM


Please stop referring to me as Sir/sirs


Charles.C

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Posted 01 June 2018 - 12:05 AM

Hi Scampi,

 

This is why i never use the Codex Decision Tree. :smile:

 

Post 13 is probably the best answer IMO.

Insufficient data.

 

(1) Flowchart.

(2) Hazard Analysis

 

Back to Basics.


Kind Regards,

 

Charles.C


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Posted 01 June 2018 - 12:57 PM

Here here Charles!  Wouldn't it be nice if there was a universal HACCP standard?  


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Posted 01 June 2018 - 03:22 PM

This is the decision tree I use

 

Step#

Process Step/ Incoming Material

Hazard

B

C

P

Is this hazard fully controlled by a Prerequisite Program (SQF element) or GMP?

If Yes-indicate and proceed to next identified hazard.

If No-procede to Q1.

Q1. Could a control measure(s) be used by the operator at any process step?  If No – not CCP.  If Yes – description and next question.

Q2. Is this process step specifically designed to eliminate or reduce the likely occurrence of the identified hazard to an acceptable level?  If No- next question.  If Yes - CCP

Q3.  Is it likely that contamination with the identified hazard could occur in excess of the acceptable level or could increase to an unacceptable level?  If No –not a CCP.  If Yes – next question.

Q4.  Will a subsequent step eliminate the identified hazard or reduce its likely occurrence to an acceptable level?  If No – CCP.  If Yes – not a CCP.

CCP #


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IKE

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Posted 03 December 2018 - 01:27 PM

Hey guys, I'm coming late to the party, but the discussion is interesting and relevant to my current dilemma. I have hazards that i have deemed significant. 3 of them in total throughout the process, however, none of them are controlled directly by us, they are either controlled by a supplier, copacker, or customer. How do I address CCP in these instances? 

 

1. chemical hazard in an ingredient = It is monitored by the supplier and the COA indicates control. We require compliance with critical limits via COA verification in our receiving SOP. Is this adequately addressed as a prp or should i deem this COA step a CCP? Historically COA's have always indicated adequate control. 

 

 

2. physical hazard - metal - from process equipment = We have some control mechanisms on-site (magnet, de-stoner), however, we only take the product to WIP stage. It is then transferred to a contract miller who finishes the process of grinding to a powder. They have a metal detector designated as a CCP. Do I call this a ccp on my hazard analysis or consider it adequately addressed by the contract manufacturer qualification prp? (the contract manufacturer is SQF certified) 

 

3. biological hazard - vegatative pathogens - inherent risk in product. = We have no VALIDATED kill step, although we do cook it to parameters that would likely serve as a kill step, it just has never been validated. We don't claim the cooking step as a CCP for this reason. The risk is then passed on through the process to our customers and our product is sold as "raw" commodity with documentation clearly indicating such on the COA and spec sheet. (our product is sold as an ingredient and not available to the general public). 

 

to ccp or not? that is the question,

-and thanks to FSMA the entire process if further muddied. I chose to handle HARPC as a completely seperate hazard analysis with the above steps labeled as "preventive controls" but that definition is quite different from CCP



Scampi

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Posted 03 December 2018 - 01:39 PM

Hey guys, I'm coming late to the party, but the discussion is interesting and relevant to my current dilemma. I have hazards that i have deemed significant. 3 of them in total throughout the process, however, none of them are controlled directly by us, they are either controlled by a supplier, copacker, or customer. How do I address CCP in these instances? 

 

1. chemical hazard in an ingredient = It is monitored by the supplier and the COA indicates control. We require compliance with critical limits via COA verification in our receiving SOP. Is this adequately addressed as a prp or should i deem this COA step a CCP? Historically COA's have always indicated adequate control. 

Do you ever test these products to verify that the COA is accurate?  What are your receiving limits and what is your deviation procedure?

 

2. physical hazard - metal - from process equipment = We have some control mechanisms on-site (magnet, de-stoner), however, we only take the product to WIP stage. It is then transferred to a contract miller who finishes the process of grinding to a powder. They have a metal detector designated as a CCP. Do I call this a ccp on my hazard analysis or consider it adequately addressed by the contract manufacturer qualification prp? (the contract manufacturer is SQF certified) 

What does your customer demand from you?  Is there a threshold at which the foreign material is too large/frequent for them to take the materials......and your equipment should be checked at pre op for missing parts/pieces

 

3. biological hazard - vegatative pathogens - inherent risk in product. = We have no VALIDATED kill step, although we do cook it to parameters that would likely serve as a kill step, it just has never been validated. We don't claim the cooking step as a CCP for this reason. The risk is then passed on through the process to our customers and our product is sold as "raw" commodity with documentation clearly indicating such on the COA and spec sheet. (our product is sold as an ingredient and not available to the general public). 

YOur customer is clearly good with the level of the hazard in your finished good. 

 

 

to ccp or not? that is the question,

-and thanks to FSMA the entire process if further muddied. I chose to handle HARPC as a completely seperate hazard analysis with the above steps labeled as "preventive controls" but that definition is quite different from CCP

I would review the controls you have in place..........Canada accepts a form 9 (hazards not controlled by the establishment) where you can list out items that others are responsible for and why.

 

http://www.inspectio...0464660?chap=10

 

This allows you to mention the hazards and where in the PRODUCTS life these are controlled


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