54 replies to this topic

[MsMars]

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

 

 

https://www.fda.gov/...A/UCM517402.pdf

[bmart]

If you are looking for more resources for feed ingredient hazards, I highly recommend that you look into the AFIA's documents. They have a regulatory section that has heaps of information on how to set up a food safety plan and a massive list of hazards broken down by a variety of categories.

 

I too work in the feed industry and we have no preventive controls. We are also SF/SF certified which claims compliance with FSMA standards. 

 

Here is the FDA guidance document specifically for animal feed:

 

 https://www.fda.gov/...y/UCM592870.pdf

Edited by bmart, 20 December 2018 - 09:29 PM.

[MsMars]

If you are looking for more resources for feed ingredient hazards, I highly recommend that you look into the AFIA's documents. They have a regulatory section that has heaps of information on how to set up a food safety plan and a massive list of hazards broken down by a variety of categories.

 

I too work in the feed industry and we have no preventive controls. We are also SF/SF certified which claims compliance with FSMA standards. 

 

Here is the FDA guidance document specifically for animal feed:

 

 https://www.fda.gov/...y/UCM592870.pdf

 Bmart, 

Have you been on their website today? I went to go look for these documents as I'm working on our FSMS and poof... gone.  Looks like they want membership $ now before you're given access to any documents... Luckily I had downloaded a lot of them before the website update. 

 

EDIT: Found them! You just have to click directly on "Resources", then do a search. 

Edited by MsMars, 20 December 2018 - 09:50 PM.

[Parkz58]

If you are looking for more resources for feed ingredient hazards, I highly recommend that you look into the AFIA's documents. They have a regulatory section that has heaps of information on how to set up a food safety plan and a massive list of hazards broken down by a variety of categories.

 

I too work in the feed industry and we have no preventive controls. We are also SF/SF certified which claims compliance with FSMA standards. 

 

Here is the FDA guidance document specifically for animal feed:

 

 https://www.fda.gov/...y/UCM592870.pdf

 

Hi bmart,

 

Thanks!  I appreciate the feed-specific link.  We are not AFIA members, so I can't access that info, unfortunately.

 

Brian

[MsMars]

Hi bmart,

 

Thanks!  I appreciate the feed-specific link.  We are not AFIA members, so I can't access that info, unfortunately.

 

Brian

 Brian: 

 

Try doing a search here: 

 

https://www.afia.org/resources/search/

 

A lot of the documents are still available for free.

[Charles.C]

Regarding feed, not my area at all but i  noticed this presentation (146pgs including some template models) which looked quite interesting -

 

 animal feed,FSMA, guidance-tutorial,2016.pdf   3.97MB   56 downloads

 

@Marshall (mgourley),

 

Appreciate yr efforts to clarify what is IMO an Operational collision of traditional/FSMA terminologies/concepts. Particularly where PCs -  PRPs are involved.

 

The above attachment has a not inconsiderable portion about this confusion although I wouldn't say it comfortably solves the mystery(s).

 

I guess FSMA does not exactly reject Codex- GFSI Principles but it certainly reinterprets/rearranges them. Or tries to. "When it ain't broken ......."

 

PS -  the attachment is 2 years old so apologies in advance if FSMA has substantially changed any of the rules in the meantime !.

[MsMars]

Regarding feed, not my area at all but i  noticed this presentation (146pgs including some template models) which looked quite interesting -

 

animal feed,FSMA, guidance-tutorial,2016.pdf

 

 

VERY helpful, I needed a reference like this  - thanks Charles!

[jfox1]

And this is why this website rocks! Such a wealth of knowledge! 

[bmart]

Bit off topic but... is there anyway to get a subsection or tag for feed facilities? We now have similar food safety requirements but they are unique because we deal with different species and processes. Also, are risks/hazards are somewhat different. So far I haven't found  any forums where feed facilities are specifically discussed but I think there are a lot of people interested right now because the FDA is beginning to audit the hazard analyses of feed facility. Up to this point they have only been looking at our GMPs. I can help get the ball rolling on this if any help is needed.

[jfox1]

@bmart - Totally Agree! Also, unless I am missing it - a "Sanitary Transportation" or maybe just "Transportation" section would be great! 

[MsMars]

Agree with both of the previous - I thought I would be out of place on this forum when I entered the feed industry, but now I see that there are plenty of us out there with a lot of similar issues!  @Simon? 

[Charles.C]

Agree with both of the previous - I thought I would be out of place on this forum when I entered the feed industry, but now I see that there are plenty of us out there with a lot of similar issues!  @Simon? 

 

The nudge has been passed on. 

 

Sadly, the vast majority of documents within yr link Post 30 are now inaccessible.

[CMHeywood]

This is my opinion:

 

PC (Preventative Control), PRP (Prerequisite Program) = procedures to prevent contamination from entering into or occurring during your process.  Examples are pest control, control of cleaning chemicals, etc.  These are usually done prior to the processing.

 

CCP (critical control point) = "kill" step that removes or reduces contamination to an acceptable level.  You are "fixing" the contamination that is likely to be present.  Example is pasteurization of milk since milk has a high probability of containing bacteria.  This is done during the processing.  You are not asking your milk suppliers to ship bacteria free milk as a preventative control since they can't adequately prevent bacteria from being present.

 

You can have a food safety program without CCP's.  I work for a packaging company and we don't have CCP's.  We don't expect our raw materials to be contaminated but we do other things to prevent contamination occurring in our processes - pest control, employee cleanliness, material inspection - raw and finished goods, etc.

 

So PC vs CCP depends on what food safety standard you are referencing, and the intent of the procedure:  prevent contamination from happening or controlling the process because you know there usually will be contamination present.

[MsMars]

This is my opinion:

 

PC (Preventative Control), PRP (Prerequisite Program) = procedures to prevent contamination from entering into or occurring during your process.  Examples are pest control, control of cleaning chemicals, etc.  These are usually done prior to the processing.

 

CCP (critical control point) = "kill" step that removes or reduces contamination to an acceptable level.  You are "fixing" the contamination that is likely to be present.  Example is pasteurization of milk since milk has a high probability of containing bacteria.  This is done during the processing.  You are not asking your milk suppliers to ship bacteria free milk as a preventative control since they can't adequately prevent bacteria from being present.

 

You can have a food safety program without CCP's.  I work for a packaging company and we don't have CCP's.  We don't expect our raw materials to be contaminated but we do other things to prevent contamination occurring in our processes - pest control, employee cleanliness, material inspection - raw and finished goods, etc.

 

So PC vs CCP depends on what food safety standard you are referencing, and the intent of the procedure:  prevent contamination from happening or controlling the process because you know there usually will be contamination present.

 

I would agree with you on this, except I would differ in that I would consider Process Preventive Controls a bit differently depending on risk; I would not necessarily lump them in with prerequisites. I would consider temperature control both a PC and a CCP.

[CMHeywood]

Depends on what the temperature control accomplishes.  In a food plant, it is likely used as a kill step.  For the packaging industry I am in, it is a physical control:  we melt plastic to laminate films together, so temperature control is not used for a kill step.  If the temperature is not correct, then the plastic doesn't flow properly.

 

I agree with you that a prerequisite is most likely applicable to a low risk situation and a CCP is most likely used in a high risk situation.  They both are preventative controls:  possibly the difference being non-critical (general application, low risk-might happen) and critical (application at a particular process step, high risk-usually happens).  I realize I am not including severity in the low vs. high risk.  For my geographical area, earthquakes are a low probability but could be a high severity, so low risk - we do not have earthquake resistant builidings.

 

it all comes down to how the referenced food safety standard defines preventative control.  You have to speak the same language that your auditor is using.

 

So what I am implying is that perhaps you can call everything a preventative control but some of them need to be identified as critical (CCP's).  A CCP is a preventative control, but not all preventative controls are CCP's.

[MsMars]

So what I am implying is that perhaps you can call everything a preventative control but some of them need to be identified as critical (CCP's).  A CCP is a preventative control, but not all preventative controls are CCP's.

 

I use this very phrase when training HACCP-familiar employees on FSMA/PC's.  I often also use the pyramid diagram from this article.  Not hard and fast rule of course, but it helps. 

 

Edit: Looks like I've already referenced that article in this thread.   I suppose it's valuable information!

Edited by MsMars, 26 December 2018 - 05:42 PM.

[Charles.C]

I use this very phrase when training HACCP-familiar employees on FSMA/PC's.  I often also use the pyramid diagram from this article.  Not hard and fast rule of course, but it helps. 

 

Edit: Looks like I've already referenced that article in this thread.   I suppose it's valuable information!

 

Hi MsMars,

 

I have previously liked and utilized several articles from the source you have linked but I found this particular one disappointing.

 

IMO, (1)  it contains some inaccurate information regarding Codex-type haccp and (2)  I found the FSMA/HARPC/CCP discussion ultimately incomprehensible.

 

Hopefully the inadequacy is only for me.

 

Quantitatively, terms like FSMA's  "significantly minimize" and Codex's "acceptable level" are obviously intrinsically subjective however it might also be noted that FSMA have basically gone back in time for their "new" terminology which afaik was abandoned in haccp history several decades ago due to the confusion it then generated.

[QA_123]

So, can a preventative control also be considered a critical control point?  Or can it only be on or the other?  Can you call them preventative control/critical control point?

[jfox1]

@QA_123 - That is the point of the discussion. I would say they are semantics but others make a distinction. To be CCP's are HACCP and PC's are FSMA. We had them listed as you mentioned with a slash at my previous job.  

[kaneeileen02]

I am curious if CCP's are okay for FSVP? 

[Charles.C]

I am curious if CCP's are okay for FSVP? 

 

Some context is necessary.

[kaneeileen02]

Hi Charles,

 

We import Fish Meal and Fish Oil for Animal Feed (pet food and aquaculture) into the US.  When we are evaluating our suppliers for FSVP their HACCP plans have CCP's.  So their HACCP plans are not reading verbatim "Preventive Controls".  I am curious if this is acceptable?  The FDA TANS system takes a while on responses.  I hope this helps?

 

Thanks!

[CMHeywood]

A CCP is a preventive control.  Not all preventive controls have to be CCP's.  Pest Control is an example of a Prerequisite program that is a preventive control but not a CCP.  Pest Control is a plant wide activity.  It is not a risk that is controlled at one critical point.

 

It is important to understand that a CCP (in HACCP definition) is a critical control point at a certain part of your manufacturing process.  Do not confuse "important", "crucial", "necessary" controls as a HACCP CCP.

 

The "Critical" in CCP means:

1. There must be a contamination control procedure.
2. It must be monitored (recorded), verified that it is being done (audited) and validated that it is working (tested).
3. The final control happens at one point (critical control point) in the process.  There should be no "let's do the control again at a different point in case we missed it the first time".

[kaneeileen02]

Thank you for the explanation.

[Charles.C]

 

A CCP is a preventive control.  Not all preventive controls have to be CCP's.  Pest Control is an example of a Prerequisite program that is a preventive control but not a CCP.  Pest Control is a plant wide activity.  It is not a risk that is controlled at one critical point.

 

It is important to understand that a CCP (in HACCP definition) is a critical control point at a certain part of your manufacturing process.  Do not confuse "important", "crucial", "necessary" controls as a HACCP CCP.

 

The "Critical" in CCP means:

1. There must be a contamination control procedure.
2. It must be monitored (recorded), verified that it is being done (audited) and validated that it is working (tested).
3. The final control happens at one point (critical control point) in the process.  There should be no "let's do the control again at a different point in case we missed it the first time".

 

 

IMO the above explanation is slightly inaccurate.

 

Traditional Codex definition - Critical Control Point (CCP) A step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level.

 

The word "essential" is in fact "important and necessary"