8 replies to this topic

[julianne.bell4711]

Hello everyone,

 

I receive a lot of haccp documentation showing that reception of raw material is a CCP; however, I have learned that it is not typically deemed a CCP. Does anyone have any insight here? My vendor has answered the first two questions on the CCP decision tree as yes, leading them to the assumption that this is a CCP step; however I still am not sure if the measures implemented (supplier approval, preliminary testing) is enough to truly eliminate any likely hazards present to a low enough level.

[jdpaul]

It can be a CCP if you rank your supplier as high risk (for instance they produce multiple allergens). If your high risk supplier produces gluten as well as an ingredient used in a gluten free product you may make it a CCP because in order for the raw material to be released you perform an ELISA method where you test for any gluten (usually 10 or less ppm)

[Charles.C]

Hello everyone,

 

I receive a lot of haccp documentation showing that reception of raw material is a CCP; however, I have learned that it is not typically deemed a CCP. Does anyone have any insight here? My vendor has answered the first two questions on the CCP decision tree as yes, leading them to the assumption that this is a CCP step; however I still am not sure if the measures implemented (supplier approval, preliminary testing) is enough to truly eliminate any likely hazards present to a low enough level.

 

Hi julianne,

 

(1) It might depend on what the specific hazard is that is responsible for the claimed CCP ?

(2) It might also depend on which flavour of haccp you are taslking about ? Codex-type ? FSMA-type? iso-type ?

 

IMEX, for traditional haccp, most raw material "hazards" considered to be reponsible for CCPs are usually either classified as PRPs or as "controlled at later process stages".

 

Some textbooks even end up with "CCPs" for the raw material supplier !

 

PS - Just as an example from iso22002-1 (a reference list for Prerequisite Programs for fssc22000 )-
 

 

9.1 General requirements Purchasing of materials which impact food safety shall be controlled to ensure that the suppliers used have the capability to meet the specified requirements.

The conformance of incoming materials to specified purchase requirements shall be verified.

 

9.3 Incoming material requirements

(raw/ingredients/packaging)

………

Materials shall be inspected, tested or covered by COA to verify conformance to specified requirements prior to acceptance or use. The method of verification shall be documented.

………..

 

[Gerard H.]

Hi Julianne,

 

Other examples of where it could be a CCP:

• Presence of residues of antibiotics
• A legal temperature requirement
• Presence of pesticide residues

It depends on your own process and on the correct use of the HACCP decision tree.

 

Kind regards,

 

Gerard Heerkens

[dinysusy]

It can be a CCP if you rank your supplier as high risk (for instance they produce multiple allergens). If your high risk supplier produces gluten as well as an ingredient used in a gluten free product you may make it a CCP because in order for the raw material to be released you perform an ELISA method where you test for any gluten (usually 10 or less ppm)

If it is considered high risk, it is a oPRP. How can you continueous monitor gluten in raw material? You can only take some samples to verify the gluten control measure is still valid.

[MDaleDDF]

Always check the dates of the last post!   Lol.   Welcome to the forum...

[dinysusy]

Thanks! It is a quite good topic. I searched google and directed me here.In my previous company, maybe because they applied ISO standards, PRP or oPRP is normally the way they control RM. But very good discussion.
 

Always check the dates of the last post!   Lol.   Welcome to the forum...

[GMO]

Always check the dates of the last post!   Lol.   Welcome to the forum...

 

Genius Dale.  

 

 

Since this thread first passed on the first of its 9 lives... a new codex version has been published but I think even the one before had the first question around (I'm paraphrasing) "look dude, are you already managing this well enough with your prerequisite plan?"  

 

You get the idea.

 

And the answer is "yes mate, yes I am".

 

I've worked in dairy and yes, antibiotic residues are a risk but I still wouldn't have it as a CCP.  While we did intake testing for them, that was only verification of the controls around the raw milk suppliers.  It wasn't accurate for some antibiotics but the farmers knew that if we found one out of spec they were paying for everyone else's milk which was a big disincentive.  Same with temperature and pesticides.  The incoming check isn't actually the control, it's verification of control in my view (if you're even checking the pesticides).

 

I'm trying to think of a situation where you had such little trust in your suppliers, and I can't help but think "get better suppliers".

[dinysusy]

Real good answer, dude!

Genius Dale.  

 

 

Since this thread first passed on the first of its 9 lives... a new codex version has been published but I think even the one before had the first question around (I'm paraphrasing) "look dude, are you already managing this well enough with your prerequisite plan?"  

 

You get the idea.

 

And the answer is "yes mate, yes I am".

 

I've worked in dairy and yes, antibiotic residues are a risk but I still wouldn't have it as a CCP.  While we did intake testing for them, that was only verification of the controls around the raw milk suppliers.  It wasn't accurate for some antibiotics but the farmers knew that if we found one out of spec they were paying for everyone else's milk which was a big disincentive.  Same with temperature and pesticides.  The incoming check isn't actually the control, it's verification of control in my view (if you're even checking the pesticides).

 

I'm trying to think of a situation where you had such little trust in your suppliers, and I can't help but think "get better suppliers".