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Bakery, Identification of Low Risk and High Care

HACCP Low Risk High Care Desserts

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#26 Charles.C


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Posted 05 December 2019 - 10:16 AM

Hi Charles,


FSMA is my area. Therefore I don't understand this statement: 




"Is there any evidence for FDA supporting baking not being a CCP  within the traditional haccp scheme?"



It is contradictory in view of HARPC, especially the part about "traditional HACCP scheme" and FSMA. Can you perhaps elaborate?




Hi kettlecorn,


I will attempt to elaborate.


As I understand FSMA typically requires the baking step to be a Preventive Control (eg Ch6/FSMA Draft Hazard Analysis Guidelines).

I deduce this implies that FSMA do not agree with suggestions like "output quality failure" can justify that inadequate baking does not present a potential micro.hazard to the consumer.


Prior to FSMA, FDA implemented (traditional) haccp based on Codex/NACMCF. If my above  interpretation  is accurate and FDA's (then) opinion was unchanged from current, I anticipate that FDA would  favour a CCP at the baking step .


But I have not seen any published examples of FDA-authorised baking haccp plans going back to this period. Hence my query in Post 21.

(A random Literature scan of around 10-15 studies indicated the majority showed Baking CCPs. A few [2-4] did show absence, but with no explanation.)

Kind Regards,



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