I am wondering if I could have some advice please. I am working for an Aquaculture business that has designated Pesticide control as a CCP. This is based on FDA guidelines for Fish. We also as part of the Government requirements to have to carry out a monthly testing on Pesticides. As a result of these guideline and requirements the team has decided that the Pesticide should be a CCP where I am saying to them that you cannot control the process, only measure and react approx. 3 weeks (testing times as sending samples to the EU) after the results have published and therefore not a CCP.
We have results going back 5+ years indicating that we have never had an incident of Pesticides in the growing process or factory process.
I have always been under the instructions and teaching that CCP's are points that you as an operation can control (Metal detection, Heat Processing etc) where you measure and have a direct influence on the outcome. Where there is a difficulty to have direct influence then monitor only and address where there is deviation and highlight through controls and control.. In essence a control point and not critical.
When explaining this to the team and therefore asking for daily certificate (CCP) from the farm I was told that they only get on Bi annually after a separate set of tests have been carried on a the full assay of Water / Limnology.
What is the current thinking on these type of CCPS where control and elimination are very difficult.
The below statement is the one that throws me.
Control measures shall be established for each relevant hazard. The control measures shall prevent or eliminate the hazard or reduce it to an acceptable level.
In this case I only measure and not control