10 replies to this topic

[yorkshire]

Dear All,

We are all used to our metal detectors, sieves, magnets, x rays, etc. being considered for selection as a CCP. What about humans as CCPs? We can accept someone carrying out a goods in inspection may be considered for a CCP but what about if that person is on an inspection belt? Can they ever be used as a CCP?

[Simon]

Yorky,

Interesting…humans are definitley 'critical controls' throughout the process but I'm not sure whether you could categorise them as a CCP. For example how would you propose to:

- establish critical limits for the human
- establish a monitoring system for the human (training evaluation, another human double-checking maybe?)

What are they inspecting for physical contaminants? By the way are you joking?

Regards,
Simon

[yorkshire]

No Simon I'm not joking

Let me give you an example from a previous job, i.e. back to peanuts.

Peanuts are harvested from the ground and are therefore prone to foreign body contamination e.g. stones, glass, wood, bone, metal, rubber, etc.

In the process of cleaning them up we had the following equipment:

An air classifier

A destoner ( fluidised bed which removed items more dense than peanuts)

An X ray machine

A colour sorter

Human inspection

Metal detection

The only stage which would remove wood (most of the time) was the human inspection stage, we could not find any alternative technology at the time (are there any now?) therefore it was classed as a CCP in our HACCP.

Your comments on how you:
- establish critical limits for the human
- establish a monitoring system for the human (training evaluation, another human double-checking maybe?)

are the issues.

Can you ever define a human role to ensure a CCP like this is under control?

Some problems could be:

Can they see?
Are they colour blind?
Have they been out on the beer the previous night?
Do they always look at the belt?
Are they thinking about something else?
etc..................................


Anyone else comne across this?

[Charles Chew]

Hi Yorky,

First of all, I am back from out of town and as promised, the hazard analysis formats will be posted very soon. Embarassingly, I seem to have problems attaching the information

With regards to the issue of humans as potential contributors to hazards, I can accept that as a common identity. But to recognise them as CCPs require a BIG justification

I guess this is where "daily personnel hygiene checklist" come in as a monitoring activity or mechanism rather than being classified as a CCP. I really hate to know what the corrective action would be in case of a non-conformance................do you give the person the "sack" or review the process (as in review the job functions)

Interesting but difficult to justify.

Cheers
Charles Chew

[rheath]

Just a few points on your example –

HACCP is predominantly intended to prevent the introduction of a contaminant in its ‘primary’ production. I would take the route that stones / glass etc should be controlled by your supplier in their HACCP system.

If this cannot be achieved, I don’t believe that humans are the CCP – it is the goods receipt or filtering step that is the CCP – the human sorters are the control measure.

Also remember that within a HACCP programme the ideal is to eliminate but any sorting/inspection programme is unlikely be 100% successful whether human or automated – the key is reduce to an acceptable level.

At the end of the day how many of us drunken, beer swilling individuals are going to notice the difference between a peanut & a piece of wood

[Simon]

At the end of the day how many of us drunken, beer swilling individuals are going to notice the difference between a peanut & a piece of wood

Yes, one can often find me munching on the bar.

Simon

[yorkshire]

Richard,

What I forgot to mention is that peanuts are traded as a commodity. Each batch can come from a different grower, coop or supplier so you cannot reply on any previous HACCP.

[rheath]

Yorky,

In which case I would maintain that the filtering process is the CCP as filtering is the step that has been specifically introduced to reduce or eliminate the likely occurrence of a hazard.

As previously stated, the human sorting is the 'how controlled' element.

To expand on this a little further - it is not the metal detection machine that is the CCP - it is the process of metal detection (If you haven’t plugged it in - it wont be much good!!).

Regards

Richard

Edited by rheath, 16 April 2004 - 10:28 AM.

[yorkshire]

Richard

To expand on this a little further - it is not the metal detection machine that is the CCP - it is the process of metal detection (If you haven't plugged it in - it wont be much good!!).

Too true. How many of us have "fail to safe mode" on our metal detectors?

In which case I would maintain that the filtering process is the CCP as filtering is the step that has been specifically introduced to reduce or eliminate the likely occurrence of a hazard.

What filtering process?
The only stage which would consistently reduce the risk of wood contamination was visual inspection.

I'm glad I don't work with nuts any more ( although I do worry about some of my colleagues))

[rheath]

The only stage which would remove wood (most of the time) was the human inspection stage, we could not find any alternative technology at the time (are there any now?) therefore it was classed as a CCP in our HACCP. 

The checking for wood & subsequent removal is the bit that I am calling filtering, you could call it wood detection process, inspection etc

It still remains that it is this point in the 'process' that is the CCP and NOT the human (who is the control measure for the CCP).

I know its semantics but the differentiation is there..

Regards

Richard

[Charles Chew]

Yorky,

Removing hazards say pieces of stones, depends on the efficiency of the intervention step that has been put in place as a control mechanism.

The function of that intervention step is really to prevent, eliminate and if not possible, to reduce the potential hazards to an acceptable level which can be deemed safe.

All control mechanisms are a form of process controls deliberately put in place by virtue of equipment designs with functions determined by HUMANS.

A CCP Control Mechanism - if inadequately effective to control by reason of poor design or incorrect functions therefore resulting in loss of critical control over a CCP (as in a breach of the critical limit) should be highlighted in the non-conformance report for review.

The assessment and decision should predominantly be on the review of the equipment or even to determine if the process justifies alterations rather than focusing on the incapacity of the human being.

Comment - The CCP control mechanism to perform that pre-determined function (in this case being the equipment) is the CCP whilst Humans are merely trained follow operating procedures to ensure that the CL (Critical Limit) is not compromised or breached. Its hard to consider Humans as CCPs!

Yorky, don't go nuts over this issue!

Charles Chew