10 replies to this topic

[schnitzelman]

From my understanding after I have selected my CCPs, what is to be done with them going forward is regular CCP on-site verification, validations if the CCP process were to change, and issuance of an NCR upon a CCP non-compliance.

 

Am I missing stuff, or is this all?

[FSQA]

 what is to be done with them going forward is regular CCP on-site verification, 

Just make sure that  "limits" of CCP, " Frequency of Verifications" and " Responsible individual/team"  are included and mentioned in your HACCP plan (document).

[schnitzelman]

OK thanks for the input!!

[012117]

Hi, Schnitzel.

 

Here are my inputs.

 

Establish the monitoring plan which is to include the limits, when, who, where and how it will be monitored and the action to be taken in case of deviation and where it should be documented.

Validate not only if there are changes but to validate before the plan is implemented which also include the identified corrections.

Training :)

 

As for the verification, it may not only be on-site, depending on the CCP that you have establish, other means of verification can be implemented but to ensure you can distinguish verification of system and verification of HACCP plan :)

[Scampi]

Your CCP should be validated PRIOR to implementation.  You hazard analysis has determined you need them..........now you have to VALIDATE the limits

 

Sometimes that is really straight forward, say metal detection.....some countries have legislated  maximum limits for the different materials..........you then just have to run a series of tests in situ to make sure your process can capture those limits and then set frequency for monitoring

 

However, if you determine you have a CCP for something like e coli.........you would have to back up your CCP with scientific papers that show under conditions X the e coli is removed/reduced to an acceptable limits (think carcass/veggie washing here)

 

Remember, nothing in a HACCP plan is written in stone.........so you try to validate a CCP as you think it should work, and your validation study doesn't hold up.....then change the parameters of the CCP

 

 

Scheintzelman ...........if you share the product type we can assist a lot more............I also suggest you have a look at this link

http://www.inspectio...7674768_eng.pdf

 

IMHO the FSEP manual is one of the very best HACCP models going and is full of very useful information (plus CFIA inspectors are used to it so moving forward into SFCR it will be easier for you and them)

 

Feel free to ask me directly----have been working in a CFIA inspected facility for 10+ years and there are not a lot of Canadians on this site

[schnitzelman]

Hi everyone thanks again for the replies. Fellow Canuck Scampi, how are ya!

 

I am in a restaurant hotel-type facility, with a large kitchen and robust menu. We are going for ISO 22000. So many different products, I've broken down the HACCP plans to hot food, cold food, bakery, etc.

 

I do have another question regarding CCPs. If something is controlled in the PRPs I am under the impression that it doesn't have to be controlled by a CCP. For instance, foreign material contamination is controlled by PRP G.2.... however in every processing facility I've worked in metal detectors have been a CCP.

 

Why in this case are foreign material detectors CCPs if this is already covered in the PRP (technically OPRP)?

[schnitzelman]

Just to specify, the control in my operation for foreign material control at the last point is an undocumented visual inspection of equipment.

[Charles.C]

Just to specify, the control in my operation for foreign material control at the last point is an undocumented visual inspection of equipment.

 

If it's undocumented, from a haccp POV, it doesn't exist.

 

You can find  a metal detection step implemented/justified  in haccp plans as, variously, PRP, OPRP, CCP.

 

Welcome to the World of HACCP Subjectivity.

 

You are correct in yr impression regarding PRPs.

 

Two common reasons why people might select the metal detection step as a CCP are (a) the process has no other CCPs, (b) if not selected a long auditorial discussion/justification  may be anticipated. Auditors are often "motivated" by their cumulative audit experiences.

 

@Scampi, just for consistency, might add that the E.coli you refer in Post5 is the pathogenic one(s), not the generic indicator.

[schnitzelman]

Thanks Charles.

 

On that note, one of my HACCP Plans is for cold food; sandwiches, salads etc. Each step in the process are covered in the PRPs. I had originally listed the self-serve cooler temperature as a CCP (last step in the process).

 

However I had a thought - this control is in the PRP, for Storage. So it's already controlled.

 

Can I have a HACCP Plan without a CCP?

[Charles.C]

Thanks Charles.

 

On that note, one of my HACCP Plans is for cold food; sandwiches, salads etc. Each step in the process are covered in the PRPs. I had originally listed the self-serve cooler temperature as a CCP (last step in the process).

 

However I had a thought - this control is in the PRP, for Storage. So it's already controlled.

 

Can I have a HACCP Plan without a CCP?

 

Hi scnitzelman,

 

It may always depend on yr specific Process And Standard. Both unknown. Offhand I would be rather surprised if such a high risk/Care product had no CCPs in its Production Process. Then again.........?

 

Re-red, this may depend on yr operative interpretation of "haccp Plan".

 

There is an interminably long, IIRC identically titled thread, still running on this forum. The majority viewpoint is probably Yes but I think not 100% agreement. You should have a look.

 

Just as an example, I seem to remember that a USA Regulatory meat Authority "expect" their submitted haccp plans to contain a minimum of one CCP (possibly a Regulatory one) (if justfiably otherwise = no haccp plan >  no inspection).

[Scampi]

Charles, I really don't think so...........in poultry in Canada, the test on the carcass is generic ecoli, not 0157...........so I will leave it at generic ecoli. See link below

 

http://www.inspectio...6/1371152627120

 

 

 

scnitzelman, follow the FSEP manual to a T.........if your plan says no CCP, then no CCP

 

The CDN auditors I have had, all have had a background in the FSEP regulated commodities and will be completely comfortable with the FSEP format...................also moving into the SFCR, more inspectors at more facilities looking at more plans..........so some continuity will go a long way