Jump to content

  • Quick Navigation
Photo
- - - - -

Preventative Controls before the critical preventative process


  • You cannot start a new topic
  • Please log in to reply
3 replies to this topic

#1 jcieslowski

jcieslowski

    Grade - MIFSQN

  • IFSQN Member
  • 166 posts
  • 55 thanks
23
Excellent

  • United States
    United States
  • Gender:Male

Posted 17 August 2018 - 02:02 PM

I've managed to confuse myself with the change in terminology.

 

We've got final filters that were our CCP, now our process preventative control point.  Many steps earlier in our process we have more filters.  These are more for straining out impurities before processing, not screening foreign objects from finished food.  Under FSMA Food Safety Plans, what do I call this step?  Do I call it out as a process preventative control and then somehow delineate that it's not a critical point?  How do I list it in the hazard analysis?

 

Sorry I'm sure I'll know the answer once someone says it, I'm just having a food safety moment :)

 

 



#2 Ryan H.

Ryan H.

    Grade - MIFSQN

  • IFSQN Member
  • 166 posts
  • 54 thanks
38
Excellent

  • United States
    United States
  • Gender:Male
  • Interests:Sports, traveling

Posted 17 August 2018 - 03:58 PM

Hello jcieslowski,

 

You still will want to keep your CCP's the same. In the event your CCP's and your Process Preventive Controls are the same, label them as both. 

 

If your "controlling" something in which you reduce the hazard as to not pose a threat, or it you eliminate a hazard altogether than that is a CCP. 

 

Process Preventive Controls are meant to be preventive. Your preventing the hazard from occurring. One that i have heard a lot would be for example: label reviewing. This is important to ensure the proper label like allergen status, item item, etc. This would be a preventive approach for undeclared, missing allergen information.


All the best, 

 

Ryan Heavner 


#3 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 17,349 posts
  • 4832 thanks
942
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 17 August 2018 - 09:34 PM

I've managed to confuse myself with the change in terminology.

 

We've got final filters that were our CCP, now our process preventative control point.  Many steps earlier in our process we have more filters.  These are more for straining out impurities before processing, not screening foreign objects from finished food.  Under FSMA Food Safety Plans, what do I call this step?  Do I call it out as a process preventative control and then somehow delineate that it's not a critical point?  How do I list it in the hazard analysis?

 

Sorry I'm sure I'll know the answer once someone says it, I'm just having a food safety moment :)

 

Hi jci,

 

Similar older threads exist on this forum. I don't use FSMA so can only discuss conventional haccp responses. One might hope there is some linkage.

 

This is a classic conundrum in traditional haccp, similar perhaps to the use of preliminary magnetic screens followed by metal detectors at the end.

 

It clearly relates to (safety) risk assessment, ie what is the hazard ?. If screen not related to a definable hazard then presumably not haccp/harpc related.

 

If >1 screen/control measure is safety relevant, different authors have proposed various solutions, all of which could be justified (somewhere). Namely -

 

(a) always nominate the final screen. This is the most common interpretation used for metal detectors. IIRC there is also a modified decision tree to support this route.

But this option is not without published exceptions (well i can think of one authoritative one anyway).

(b) use multiple individual CCPs for the respective screens. Can get messy.

© define the combination of screens as one CCP. Specifically alluded to in iso22000, implied in Codex.

 

FSMA must surely have met this teaser already.

 


Kind Regards,

 

Charles.C


#4 redfox

redfox

    Grade - SIFSQN

  • IFSQN Senior
  • 481 posts
  • 155 thanks
21
Excellent

  • Philippines
    Philippines

Posted 18 August 2018 - 01:27 AM

Hello,

 

HARPC of FSMA reduces the number of CCPs due to its preventive control program. But is your case, I see it as CCP because this is the last step that control the physical hazard. 

 

regards,

redfox






0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users

EV SSL Certificate