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ISO22000:2018 please explain clause 8.5.4.3

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avn165cwf

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Posted 22 January 2019 - 06:53 AM

Good morning ladies and gentleman

 

new version of ISO22000, section 8.5.4.3---At each CCP, the monitoring method and frequency shall be capable of timely detection of any failure to remain within critical limits.

 

we are a catering service company, and measure the core temperature of product(rice or meat or soup....) with a thermometer is identified as CCP.

if I monitored CCP once a hour even once 30 mins, is it compliant with this section requirement?

or I need to modified CCP as checking pot or oven temperature by visual which are display on panel.

 

I am confused about the word "timely". I think it means the core temperature cannot be as CCP, unless I can always monitor it.

 



Ivan Ivanov

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Posted 22 January 2019 - 09:32 AM

Hi,

 

The thinking of the new version of ISO 22000 abou the monitoring of CCP is the same. "Timely" is mean on time, not in exact moment. You should implemet that system for monitoring which can identify lose of control at the CCP to be possible to take corsponded corrective actions to turned back the control. 

I think that you are identified correct CCP (of course my opinion is based only on the information which you are share). 

How often you will measure and recorded and how is depend of you. The standard is not set exact period or system, everything is based on your hazard analysis and risk assessment but you should ensure that the CCP is under control and in case of out of control your system is capable to identify this and take the next actions.

About the temperature of the oven or pots - ask yourself at first "what is show this temperature and what is mean? Where is measure this temperature? The temperature which is show its have any corelation with the temperature in the core of the food which is coocked? .....

This temperature can be your CP or the temperature of the pots of course can be and CCP but you can find the correct answer after using the decision tree. I can told you this is or not CCP.

When you set your frequency of monitoring of CCP take into account and the size of batches with which you work and the shelf life of the products. 

I hope that i am were helpful for you :)

 

Best regards,

Ivam 



Drumstick

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Posted 22 January 2019 - 04:51 PM

Hi everyone,

 

First time posting in this forum, so apologies in advance if what I say doesn't make much sense (or grammar mistakes, as I'm not an English native speaker).

 

I have a Spanish version of the ISO 22.000:2005; the clause 7.4.4. b) says (literally translated from Spanish), "...the evaluation of the control measures must be done taking into account: b)Its feasibility to be monitored (for example, the feasibility to monitor in a timely manner to allow inmediate corrections". I always understood this clause as: "do it as you want, but in a way that prevents that any hazardous product arrives to the consumer's fridge". Indirectly, this means that, as long as it doesn't become a health issue, it doesn't matter if you have to destroy (or reprocess) tons of product.

 

However, in the ISO 22.000:2018 version, I see a difference in the clausule you mentioned: it explicitly says that you have to monitor in a way that ensures that you work within the critical limits. If you take into account that the ISO 22.000:2018 (at least as I have heard, I couldn't read it yet) also covers "business risks", it sounds reasonable to think that the standard requires to ensure that the monitoring allows you to stay within the "safe zone". 

 

In your specific case, I imagine that the process should be "validated" somehow to ensure that, within the time frame you conduct the temperature control, it won't surpass any critical limit.

 

Does this make sense?



Charles.C

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Posted 22 January 2019 - 08:24 PM

Good morning ladies and gentleman

 

new version of ISO22000, section 8.5.4.3---At each CCP, the monitoring method and frequency shall be capable of timely detection of any failure to remain within critical limits.

 

we are a catering service company, and measure the core temperature of product(rice or meat or soup....) with a thermometer is identified as CCP.

if I monitored CCP once a hour even once 30 mins, is it compliant with this section requirement?

or I need to modified CCP as checking pot or oven temperature by visual which are display on panel.

 

I am confused about the word "timely". I think it means the core temperature cannot be as CCP, unless I can always monitor it.

 

Hi avn,

 

In various previous CCP/OPRP plans, this aspect has been used as a direct/ semi-direct criterion to separate CCPs and OPRPs

 

iso22000:2005 had -

 

b)its feasibility for monitoring (e.g. ability to be monitored in a timely manner to enable immediate. corrections)

 

This resulted in the availability of  continuous monitoring to be one convenient criterion to determine CCPs.in some plans.

 

iso22000:2018 has now somewhat "diluted" the 2005 text.

 

iso22004 :2014 has this as one criterion for CMs associated with CCPs -

 

control  measures  applied  at  CCPs:  these  control  measures  are  managed  by  a  HACCP  plan.  Such
control measures have defined critical limits that can separate acceptable product from potentially
unacceptable (unsafe) product. In addition, their implementation can be monitored in a manner that
enables detection of any loss of control within a timeframe sufficient to effectively control affected
product.
Failure to meet critical limits will result in a potentially unsafe product.

 

 

The significance of yr monitoring frequency will therefore relate to the stability of the measured temperature and its typical closeness to yr chosen critical limits.

 

Offhand, IMO, the monitoring frequencies you mention seem low however yr  process characteristics are unknown.

 

One "solution"  to this aspect is to define "operating limits" outside the critical limits so that there is then a reduced, hopefully very low,  likelihood of failure of the critical limits. Nonetheless, to implement this manouevre will still require an "adequately" stable temperature situation.


Kind Regards,

 

Charles.C


Mathieu Colmant

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Posted 28 January 2019 - 10:46 AM

Hi,

 

I will copy/paste something I just wrote a few minutes ago (here is the original post): 

 

The main issue between CCP and oPRP becomes clearer in ISO22000:2018.

But I know it is more like a boy-scout game...

So, CCP(3.11) has a critical limit (3.12). And the note 1 says that when you are on the wrong side of the limit, the product must be considered as potentially unsafe (sorry, I don't have EN version, so I retranslate from French. exact words in EN version can differ).

Let's find those potentially unsafe products... this is managed in 8.9.4. And there is a small tip in 8.9.4.2, release of products: If the critical limit was not met, you can't release the product, they must be managed following 8.9.4.3. So, let's go there :

Products that can't be released (so this includes all products not meeting critical limits) must be

a) reprocessed, so the hazard is taken below the limit

b) used in another way, if this has no impact on food safety

c) destroyed

 

So, a critical limit is black or white. For example, when a product is rejected by the metal detector (CCP), you can't sell it. You can destroy it (try to find the metal source before  ;) ) or you can "reprocess" it, for example, remove the contaminated slice from the package then push it through the metal detector again.

But, for temperature, this is less clear. If your limit is 4°C, do you throw every product reaching 4.1°C ? No, you will try to find what happened, check the curve and the duration of the problem, then decide if the product is good or not. So, this isn't critical, this is an action criterion and you have an oPRP.

 

For me, the temperature is never a CCP. Combination of time and temperature, like pasteurisation value, can be.


Mathieu Colmant

Consultant in Food Safety - Brussels & London

Director

FollowFoodLaw.eu ltd


Charles.C

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Posted 28 January 2019 - 11:53 AM

Hi,

 

I will copy/paste something I just wrote a few minutes ago (here is the original post): 

 

For me, the temperature is never a CCP. Combination of time and temperature, like pasteurisation value, can be.

 

In the general case i agree with you.

 

However, in the Literature, you can find various examples of instantaneous achievements of sufficiently high product core temperatures being set as cooking CCPs. The terminology tends to be a practical  rationalization of reaching a precalculated minimum Lethality (for the desired log reduction) when the associated time (arbitrarily) reaches a "few" seconds.


Kind Regards,

 

Charles.C


Mathieu Colmant

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Posted 28 January 2019 - 12:10 PM

Hi Charles,

 

As you said, "when the associated time (arbitrarily) reaches a "few" seconds". We then have time & temp :) 


Mathieu Colmant

Consultant in Food Safety - Brussels & London

Director

FollowFoodLaw.eu ltd


Charles.C

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Posted 28 January 2019 - 12:41 PM

Hi Charles,

 

As you said, "when the associated time (arbitrarily) reaches a "few" seconds". We then have time & temp :) 

 

Actually, textually, not since the CCP typically only refers to an "instantaneous" value. (Presumably for fear of confusing the wary)

 

The rest is my deduction from studying various lethality publications.


Kind Regards,

 

Charles.C




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