7 replies to this topic

[rosanna@060208]

Hi Guys, 

 

Please can you advise me. 

 

My cold store gets audited for the FSA audit as well as ISO audit. 

 

We recieved a finding in the FSA audit. That are CCP's are not justified. However, we were fine in our ISO Audit. 

 

Our CCPs are temperature during the recieving, storage, dispatch and distribution. 

 

Please can you let me know if temps would be a CCP or not. 

 

Our product arrives frozen and is stored at -26 degrees celcius. 

 

Thank you

 

 

[FSQA]

Hi Guys, 

 

Please can you advise me. 

 

My cold store gets audited for the FSA audit as well as ISO audit. 

 

We recieved a finding in the FSA audit. That are CCP's are not justified. However, we were fine in our ISO Audit. 

 

Our CCPs are temperature during the recieving, storage, dispatch and distribution. 

 

Please can you let me know if temps would be a CCP or not. 

 

Our product arrives frozen and is stored at -26 degrees celcius. 

 

Thank you

Rosanna,

 

-26C should be fine, however, can you please share more about the type of product you are handling? Based on your description above, it seems like no processing is done and its only a storage related query.

Also, please share the finding from FSA, does it mentions to include temps as your CCP or otherwise?

[rosanna@060208]

Thank you for your reply. We store meat products. There is no handling on the product at all. Should Temp be a CCP?

 

Please let me know. 

[FSQA]

Thank you for your reply. We store meat products. There is no handling on the product at all. Should Temp be a CCP?

 

Please let me know. 

I am not sure of the meat storage regulations in South Africa, however, IMHO since you are not processing the products at your facility and the product temps are <-26C, it should not be considered as a CCP.

 

Including this as a CCP can be a subjective opinion, however, how many times in the past have you seen your product/storage conditions deviating from -26C temperatures?

[012117]

Hi, Rosana.

 

The audit is ISO of what, btw? and if ISO 22000, what is the main difference is FSA audit meaning what clauses are excluded or added?

 

From the perspective of CCP, which in basic terms, is to eliminate, reduce hazard to an acceptable level. Which this may mean that "whatever is within" of what you receipt (of there is a single cell or heavily contaminated by a pathogen), the <-26C will not likely help eliminate or reduce it to acceptable level, it will help the process to remain it as inactive.  That is why storage temp most of the time is referred to as PRP.

 

Now, depending on the decision tree you have used, there are some qualifications for CCP such as feasibility to be monitored, with certain criteria (numerical limit) and if it can be monitored it can also demonstrate that action can be taken immediately when this limit is exceeded. I assume that if any case, on any monitoring, you temp became higher than -26C, you will not immediately throw the product (or reprocess or resort depending on the process). Which is why it may not qualify as CCP.

 

On other aspect, validation is also key. Is your spot the warmest spot, or is your monitoring location may also tell you if it correlated to your meat core temp? 

 

Many factors will play if you tag it as CCP. :)

[rosanna@060208]

Thank you for the info. It was very helpful

[Brendan Triplett]

Rosanna,

 

If you are only controlling time and temperature it is possible to control these items without making it a CCP.  Personally we control storage of refrigerated items without a CCP and instead have a robust of PRPs and GDPs to control these factors.  A few people touch on this in the forum topic about whether or not it is possible to have a process without any CCPs.

[Charles.C]

Hi Rosanna,

 

If you look back through the Forum there are a few cases where both freezing stages and Cold Storage are set as CCPs - based on individual risk logics, sometimes as per Local interpretations. However IMO the majority of haccp plans have no CCPs.

 

From a conceptual POV you might refer to the definition of a CCP and go from there,