7 replies to this topic

[robertmcc67]

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

[pHruit]

How have you determined that this is a CCP?
Are you using some sort of severity/likelihood matrix?
It sounds like you have the data to justify a position that the likelihood of occurrence is low, in which case could you not move it to a prerequisite program? (Specific terminology applicable may depend on which certification scheme etc you use)

If you are the company using the pesticides and that is controlled by a suitable system then this would also be a key prerequisite, but will also help justify the low likelihood status given that you're effectively in direct control of the activity that could lead to elevated pesticide levels.
I'm not in aquaculture so here may be key elements of which I'm not aware, but that's how I'd see it based on the information provided so far.

[Charles.C]

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

 

Just to expand  the previous post -

 

Typically CCPs are a result of a hazard analysis involving risk assessment.

 

The typical CCP definition is similar to that offered by Codex -

 

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 hazard analysis attempts, by methods such as in previous post, to determine if the hazard is "significant" in which case the process step having the hazard's involvement  may require designation as a CCP.

 

Offhand, I rather doubt that you are regulated by specific USFDA requirements ? (unless export is involved ?)

 

As noted in Post 2, potential hazards in the inputs to a Process are nowadays often handled via a Prerequisite Program(s) (PRP) however this may depend on whether you have specific (aquaculture) haccp format requirements to comply with ( does aquaculture have a defined regulatory haccp program ?).

Edited by Charles.C, 16 September 2019 - 09:26 AM.
added

[GMO]

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.

 

 

That cannot be a CCP.

 

For a start, is it a critical hazard?  Will it cause an illness in a consumer if it's not controlled?  Possibly but possibly only over time and if sufficient OOS fish is eaten.  Secondly, is the likelihood high enough to make it critical?  The 5+ years of good results would suggest not.

 

As you're indicating as well, CCPs must be monitored in real time and you must be able to react to adverse results while the product is in your control.  I think you've proven this is not the case here.  This doesn't mean pesticides go uncontrolled of course. Your suppliers must be able to prove they are following the right protocols and your testing programme is verification of that but critically it's not monitoring.

 

I've worked in the dairy industry and there is a similar concern on antibiotics.  What you can get there is rapid test methods for acceptance but even they are not foolproof and I know of no dairy saying it's a CCP.  To me it's like saying a microbiological test is a CCP.  It's not sufficiently fast and your actual control is the cooking process not the testing. 

 

For me I love the phrase "you can't test things safe".  HACCP is about designing in food safety to prevent the failure of processes, not about finding out if they're safe later by excessive testing.

[robertmcc67]

All,

 

Thanks for the replies, much appreciated. Will look further into this issue.

[PowderQM]

I believe this is not a CCP, but a classical oPRP.

Control is necessary, but no emediat action in case of a deviation is possible.

[Fishlady]

Are you the grower or the primary processor? If you are the primary processor, then you need to have a CCP at receiving to ensure that your grower/supplier has controlled the use of antibiotics and that the potential hazard of environmental chemicals is being controlled. If you are the grower/supplier, you are not subject to the FDA Seafood HACCP rule. You do, however, need to control the use of antibiotics and to ensure that your fish do not contain environmental chemicals at levels that are greater than those allowed by USFDA. This would likely entail ensuring that the farm is not located in areas of known contamination, that you take appropriate action to quarantine fish should there be some kind of release of chemicals into the water, and that you do not intentionally add chemicals to the growing water. These would be operational steps rather than CCPs.
There may be additional regulations that you need to comply with in the UK, but this is the view from the US.

[Charles.C]

Are you the grower or the primary processor? If you are the primary processor, then you need to have a CCP at receiving to ensure that your grower/supplier has controlled the use of antibiotics and that the potential hazard of environmental chemicals is being controlled. If you are the grower/supplier, you are not subject to the FDA Seafood HACCP rule. You do, however, need to control the use of antibiotics and to ensure that your fish do not contain environmental chemicals at levels that are greater than those allowed by USFDA. This would likely entail ensuring that the farm is not located in areas of known contamination, that you take appropriate action to quarantine fish should there be some kind of release of chemicals into the water, and that you do not intentionally add chemicals to the growing water. These would be operational steps rather than CCPs.
There may be additional regulations that you need to comply with in the UK, but this is the view from the US.

 

Hi Fishlady,

 

Thks above.

 

Unfortunately the OP's specific location seems unknown. Probably EU (from "samples") but, if so, unclear why FDA logic is being implemented.

 

Assuming the Fishery/FP hazards etc manual is still the current FDA Guide, I got the impression that either internal/external  CCPs were potential options (although latter seems rather non-Codexian).

 

In contrast to FDA, EU Aquaculture Standards appear "diverse".