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Is a Preventive Control the same as a CCP?

CCP FSMA HACCP

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#1 jfox1

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Posted 17 December 2018 - 09:20 PM

Ok, 

 

I just got off the phone with a consultant friend of mine and he was telling me that I was mistaken about a Preventive Control being the FSMA equivalent of a CCP in HACCP. In my FSPCA courses they never mention CCP's. But he was telling me that in my food safety plan I was developing that my justification in column 4 of why I do not feel like the food safety hazards require a preventive control are actually my preventive controls. I considered them PRP's or oPRP's. I have things like magnets, screens, approved supplier program, and water testing listed. 

 

We are strictly an animal feed producing facility in the USA. 

 

Looking for help on clarifying if they are the same thing or if I am misunderstanding their use.

 

I attached my rough draft for you to review. 

 

Are they the same and used to talk about the same principles (HACCP = CCP while FSMA = Preventive Controls) or are they completely different? 



#2 Ryan H.

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Posted 17 December 2018 - 09:43 PM

Prevention! Your preventing this occurrence of a scientifically known, hazard from occurring in the first place, instead of "controlling it" later down the road. 

 

I did not see your rough draft. 


All the best, 

 

Ryan Heavner 


#3 jfox1

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Posted 18 December 2018 - 12:32 PM

Sorry about that something must have happened. It should be on there now. 

Attached Files



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#4 Ryan H.

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Posted 18 December 2018 - 01:33 PM

It looks like your food safety plan is on the right track, understanding that it is your rough draft. I believe the template your using is from FSPCA? In your HA i would just make sure you write in what you decide are your CCP's and your PC's-which can include Supplier PC, Sanitation PC's and Allergen PC's. 


All the best, 

 

Ryan Heavner 


#5 jfox1

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Posted 18 December 2018 - 01:38 PM

@Ryan H. That is my question. I have always been of the understanding that CCP's are to HACCP what Preventive Controls are to FSMA/Food Safety Plans....

 

Is that accurate? 



#6 Ryan H.

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Posted 18 December 2018 - 02:07 PM

Yes that is mostly it. The FDA simply wanted to use their OWN terms which writing up the FSMA law because it's still based off HACCP they just added more requirements and wanted more specific items in your plan. This has confused everyone so anyone asking these questions are not alone. In your Food Safety Plan (Which can be a modified version of your HACCP Plan) your still going to have CCP's, but you will also have PC's, so do not give up your metal detectors! At certain steps your controlling hazards, at other steps your preventing them. The FSPCA class details a lot of it for you, however since for some it seems like overload (understandable) we leave forgetting some of the details.

 

Supply-chain for example: You receive an ingredient with a known biological hazard.. This product is shelf-stable and is applied on your finish product. How do you know it's safe? Your supplier is controlling the hazard i would hope? If so, that would be a Supply-chain PC and your going to need to document, monitor, verify/ validate and keep records of all the documentation as needed. 

 

 

Attached Files


All the best, 

 

Ryan Heavner 


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#7 Ryan H.

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Posted 18 December 2018 - 02:13 PM

This attachment may be helpful too. 

Attached Files


All the best, 

 

Ryan Heavner 


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#8 jfox1

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Posted 18 December 2018 - 02:40 PM

@ Ryan H. I appreciate your input. That was my question and it seems there is still confusion although I reached out to a contact at the NGFA and he seemed to clear things up for me. 

 

Again my question was - are PC's and CCP's the same thing? PC's for FSMA Food Safety Plans and CCP's for HACCP? He seemed to agree that I am correct in this thinking. It seems like you will not have both Preventive Controls and CCP's in a Food Safety Plan. CCP's are not discussed in the FSPCA courses and so I think I have clarity now. 

 

If anyone wants to set me straight I would appreciate any additional input as well. 

 

 

Thanks for your help! 



#9 Ryan H.

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Posted 18 December 2018 - 02:46 PM

Your most definitely still going to have CCP's. The question is are you going to have a separate HACCP Plan (CCP) and Food Safety Plan (PC) or are you going to put them together as one overall Food Safety Plan. 

 

Actually, if you check out my template from FSPCA you will see in the HA portion the options for CCP, Sanitation, Supply-chain, and Sanitation PC's.. 


All the best, 

 

Ryan Heavner 


#10 jfox1

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Posted 18 December 2018 - 02:58 PM

I will be putting them together into one FSP. Again I see that in the template but in the course no mention of CCP is made. To my current understanding CCP's are a term used in HACCP while PC's are used in FSMA. I do not mean to be annoying about this but it was something that I thought (and still think) I have under my belt but I was confused by the comment my consultant gave me. I feel like now I have clarity that under FSMA PC's are the equivalent to CCP's. 



#11 kfromNE

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Posted 18 December 2018 - 03:33 PM

They are basically the same thing: A big difference was that in HACCP, our plan only discussed the points we were controlling. In the FSP, we have things mentioned that we considered but aren't controlling. For example we order paprika from a supplier. In the FSP, we mention lead oxide as a potential hazard because it has been a known hazard in the past but we don't have a PC step for it. (Our supplier selection program and COAs we receive from our suppliers eliminate the need for it).

 

 

https://www.foodsafe...c-a-comparison/



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#12 Charles.C

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Posted 19 December 2018 - 04:14 PM

This discussion is analogous to haccp vs harpc.

 

The discussion has been going on for several years already.

 

Just to perhaps increase the confusion can see -

 

https://techni-k.co....entive_controls

 

https://techni-k.co....entive-controls


Kind Regards,

 

Charles.C


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#13 mgourley

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Posted 19 December 2018 - 09:11 PM

Let's see if I can take a stab at it.
The definitions of CCP and Preventive Control are essentially the same. A Preventive Control prevents or significantly minimizes a hazard. A CCP eliminates or reduces a hazard to an acceptable level.

The differences may seem small, but they are the essential difference between a HACCP Plan and a Food Safety Plan. HACCP Plans are predicated on pre-requisite programs that are supposed to reduce hazards, and then any hazard that remains, is essentially a CCP.

 

Food Safety Plans assume no pre-requisite programs when conducting the hazard analysis and risk assessment.

 

Process Preventive Controls are linked with a particular point in the process or a particular piece of equipment. They do not fit into the other groups of Preventive Controls. (Sanitation Preventive Controls, Supply Chain Preventive Controls, and Allergen Preventive Controls)

 

Process Preventive Controls should be managed the same as CCP's.

Sanitation, Supply Chain and Allergen Preventive Controls are not necessarily "CCP's", but that will entirely depend on your facility, products you produce and of course your hazard analysis and risk assessment.

 

Clear as mud, I know. If your hazard analysis and risk assessment clearly identify which of your Preventive Controls are Process Preventive Controls, and you treat them the same as CCP's, you should be good.

 

Just a word of caution to those that think you can use a COA from a supplier as a Supplier Preventive Control for raw materials that contain hazards.... don't.

The FDA inspector we had earlier in the year for a 3.5 day FSMA Readiness Evaluation specifically stated that FDA will not accept that.

 

Hope that helps,

 

Marshall



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#14 jfox1

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Posted 20 December 2018 - 12:22 PM

@mgourley - That is how I understood it basically. 

 

I am confused about the COA. Why would that not be acceptable? Obviously I understand you might need additional verification like random testing or approved supplier programs but why did your Inspector say they wouldn't accept those as a control of the hazard? 



#15 MsMars

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Posted 20 December 2018 - 02:13 PM

I agree - I've always been told COAs alone aren't acceptable if you've identified a risk that needs a Supply Chain Control.  You need validated proof from the supplier that they are controlling the hazard, and if they cannot provide that then you will need to do some kind of validation yourself such as random testing. 



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#16 MsMars

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Posted 20 December 2018 - 02:34 PM

Also - if you're looking for another take on CCPs vs PC, check out this article: 

 

https://www.foodqual...-harpc-plan/2/ 

 

I've always used the pyramid when training a facility on preventive controls when they've previously used HACCP.  I would say that ESSENTIALLY a PROCESS preventive control (i.e. a control that needs validation) and a CCP could be considered one in the same, but I think you could also argue that a preventive control isn't NECESSARILY a CCP. But, as mgourley said, you're going to manage them the same way, so probably don't need to complicate things too much. 

 

Reading through your food safety plan: 

Food Safety Team - include some members from production, maintenance, accounting, etc. Diversify.

Product Description: Make it brief, I wouldn't necessarily include specific mycotoxin requirements, only "Free of Mycotoxin Contamination" or equivalent

 

Also glad to see another feed plan with no preventive controls - I was a bit nervous after developing ours (as I was used to dealing with human food) and coming up with no controls during risk assessment, but it does make life a little easier after it's said and done.  Hope it satisfies the FDA. 



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#17 kfromNE

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Posted 20 December 2018 - 02:36 PM

I agree with needing more than a COA that is why we also have our supplier selection program which is more in depth. One reason the inspector may have not taken the COA as acceptable - a company could falsify their records which I believe the Peanut Corporation did.



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#18 jfox1

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Posted 20 December 2018 - 02:43 PM

@msmars - I appreciate your take. I think we are often pressured into have a preventive control or we didn't do it right. May I ask what you process as feed? We process oats and barley at one facility, alfalfa at another, and feed blends (non-medicated) at others. 

 

Thanks! 



#19 MsMars

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Posted 20 December 2018 - 02:47 PM

We process local corn, then blend with other ingredients that are shipped in (soybean meal, DDGs, etc.) for medicated and non-medicated feeds.



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#20 jfox1

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Posted 20 December 2018 - 02:56 PM

Ok! You have quite a few more regulations with medicated feeds than we do. May I ask what resources you used to analyze the hazards in the ingredients? I only could find the FDA hazards document and one from CFIA. I do not have a degree in Food Sciences to be able to know that I have covered them all. That would be my weak spot especially because I am new to the industry.  



#21 mgourley

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Posted 20 December 2018 - 02:56 PM

@mgourley - That is how I understood it basically. 

 

I am confused about the COA. Why would that not be acceptable? Obviously I understand you might need additional verification like random testing or approved supplier programs but why did your Inspector say they wouldn't accept those as a control of the hazard? 

Because a COA is not a preventive control. It's a piece of paper.

 

Let's say you have established salmonella as a hazard in an ingredient you purchase. (I'm in baking, so flour has historical evidence of salmonella).

 

Remembering that Food Safety Plans, unlike HACCP, assume no pre-requisite programs. A COA is in essence, "evidence" that your supplier is controlling the hazard for that particular lot of material. (A pre-requisite program). But what if they are not?

 

Since we have identified salmonella as a possible hazard in flour, then we require a Process Preventive Control (baking), to ensure the elimination of any possible salmonella.

 

Marshall



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#22 Parkz58

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Posted 20 December 2018 - 02:58 PM

jfox1, we are also in livestock feed (all we process is feed-grade oat products at our facility), and we do not have a PC, either.



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#23 MsMars

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Posted 20 December 2018 - 03:50 PM

Ok! You have quite a few more regulations with medicated feeds than we do. May I ask what resources you used to analyze the hazards in the ingredients? I only could find the FDA hazards document and one from CFIA. I do not have a degree in Food Sciences to be able to know that I have covered them all. That would be my weak spot especially because I am new to the industry.  

 

I loosely used the FDA hazards document, but also considered past recalls and feed safety issues as well as our own customer complaint/corrective action records. There simply aren't a lot of inherent risks in animal feed manufacturing, save for pet food.  We do have a few more regulations under cGMP requirements for medicated feeds and such that are considered in the hazard analysis, but none that I have identified as needing a preventive control (currently). 



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#24 mgourley

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Posted 20 December 2018 - 07:20 PM

The FDA guy that we had used the FDA hazards document when he was checking my hazard analysis of various ingredients.

If you use their document, there really is not a lot they can find fault with, I'd guess.

 

Marshall



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#25 Parkz58

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Posted 20 December 2018 - 07:52 PM

Does anyone have a link to this FDA Hazards Document?  I think I've seen it before, but I'm not sure...







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