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 :)
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.