19 replies to this topic

[Shahbaz]

Hi Food Safety Experts,

 

Could someone plz advice is the freezing step CCP or not

Edited by shahbazfoodtech, 19 December 2019 - 09:00 AM.

[Andy_Yellows]

Hi Shahbaz,

 

If you can tell us a bit about your product and processes then we may be able to advise.

 

Regards,

 

Andy

[Setanta]

Definitely need more details...what is the product, the process, what are you 'controlling' by freezing?

[The Food Scientist]

Well it depends on your hazard analysis? Does it minimize, reduce or eliminate a significant food safety hazard? Can you share your process with us?

[Juribe]

Depends on your product and your process. For instance, we purchase an ingredient that is flash-frozen to rapidly decrease the products temperature. This is considered a CCP because the flash-freezing process is used as a means to prevent the product from spoiling. This particular product would otherwise be compromised if not flash-frozen as simply placing the product in a freezer to cool over a long period of time would cause the product to spoil. By flash-freezing, the product is able to significantly reduce, or eliminate the possibility of spoilage.

 

Ask yourself: Without the process step, would the product be compromised? or is the step required to keep the food safe, and is it the last step to keep the food safe from X?

[kettlecorn]

What Juribe said. 

[Charles.C]

Depends on your product and your process. For instance, we purchase an ingredient that is flash-frozen to rapidly decrease the products temperature. This is considered a CCP because the flash-freezing process is used as a means to prevent the product from spoiling. This particular product would otherwise be compromised if not flash-frozen as simply placing the product in a freezer to cool over a long period of time would cause the product to spoil. By flash-freezing, the product is able to significantly reduce, or eliminate the possibility of spoilage.

 

Ask yourself: Without the process step, would the product be compromised? or is the step required to keep the food safe, and is it the last step to keep the food safe from X?

 

Sorry but I disagree. "Spoiling" is simply not typically regarded as a safety hazard.

 

It's all about when pathogenic micro. growth is halted, usually somewhere around 0degC although the rates are generally already very low at the, I think, US refrigerator chilled  "favorite" of 4.4degC (40degF). This is typically a long time before the product core reaches, say, -18degC.

 

In practice, haccp publications/textsofficials do differ on the CCP aspect, often without justification. Both yes and no can be found. (for example, IIRC, NZ normally say yes while FDA (perhaps[?] pre-FSMA) normally say No).

 

Maximum Cooling times to get to  ca 4degC do exist based on bacterial growth rate formulae (see the parallel thread to this).

 

Personally for conventional plate and air-blast freezers with 1kg-7kg blocks of wet seafood I have never used a CCP and never had it queried in audits.

 

PS - one can have similar discussions over whether frozen cold storage is a CCP also.

 

PPS - An alternative  haccp decision criterion other than the ones mentioned in Post 5 is to ask - What is the consequence of an "error" in the relevant step/control measure and what is it's likelihood for occurrence ? (= >>> Risk).

(FSMA IMO went logic overboard over such philosophies afai understand their position)

Edited by Charles.C, 20 December 2019 - 04:18 AM.
added

[MOURADTALBI]

Sorry but I disagree. "Spoiling" is simply not typically regarded as a safety hazard.

 

It's all about when pathogenic micro. growth is halted, usually somewhere around 0degC although the rates are generally already very low at the, I think, US refrigerator chilled  "favorite" of 4.4degC (40degF). This is typically a long time before the product core reaches, say, -18degC.

 

In practice, haccp publications/textsofficials do differ on the CCP aspect, often without justification. Both yes and no can be found. (for example, IIRC, NZ normally say yes while FDA (perhaps[?] pre-FSMA) normally say No).

 

Maximum Cooling times to get to  ca 4degC do exist based on bacterial growth rate formulae (see the parallel thread to this).

 

Personally for conventional plate and air-blast freezers with 1kg-7kg blocks of wet seafood I have never used a CCP and never had it queried in audits.

 

PS - one can have similar discussions over whether frozen cold storage is a CCP also.

 

PPS - An alternative  haccp decision criterion other than the ones mentioned in Post 5 is to ask - What is the consequence of an "error" in the relevant step/control measure and what is it's likelihood for occurrence ? (= >>> Risk).

(FSMA IMO went logic overboard over such philosophies afai understand their position)

Depends on your product and your process.

[The Food Scientist]

Sorry but I disagree. "Spoiling" is simply not typically regarded as a safety hazard.

 

It's all about when pathogenic micro. growth is halted, usually somewhere around 0degC although the rates are generally already very low at the, I think, US refrigerator chilled  "favorite" of 4.4degC (40degF). This is typically a long time before the product core reaches, say, -18degC.

 

In practice, haccp publications/textsofficials do differ on the CCP aspect, often without justification. Both yes and no can be found. (for example, IIRC, NZ normally say yes while FDA (perhaps[?] pre-FSMA) normally say No).

 

Maximum Cooling times to get to  ca 4degC do exist based on bacterial growth rate formulae (see the parallel thread to this).

 

Personally for conventional plate and air-blast freezers with 1kg-7kg blocks of wet seafood I have never used a CCP and never had it queried in audits.

 

PS - one can have similar discussions over whether frozen cold storage is a CCP also.

 

PPS - An alternative  haccp decision criterion other than the ones mentioned in Post 5 is to ask - What is the consequence of an "error" in the relevant step/control measure and what is it's likelihood for occurrence ? (= >>> Risk).

(FSMA IMO went logic overboard over such philosophies afai understand their position)

 

But you can not sell spoiled product...

 I know some food born pathogens that may cause spoilage to food like Bacillus cereus and Clostridium perfringens. 

[zanorias]

But you can not sell spoiled product...

 I know some food born pathogens that may cause spoilage to food like Bacillus cereus and Clostridium perfringens. 

 

Agreed you shouldn't sell spoiled product in general. But purely from a CCP standpoint, if the spoilage is quality related then it will not be relevant for HACCP which is safety based. If the spoilage in this case is pathogenic/safety related too and if the act of freezing is critical to control the hazard then yes I'd agree it should be considered. I think in this case it would depend on the specific product/process and whether the consequence relates only to quality or not.

[The Food Scientist]

Agreed you shouldn't sell spoiled product in general. But purely from a CCP standpoint, if the spoilage is quality related then it will not be relevant for HACCP which is safety based. If the spoilage in this case is pathogenic/safety related too and if the act of freezing is critical to control the hazard then yes I'd agree it should be considered. I think in this case it would depend on the specific product/process and whether the consequence relates only to quality or not.

 

Correct. It depends on the food and your process... The OP never told us what their processes are.

You can not always regard Spoilage as a non-food safety hazard I agree. But, You can't sell spoiled product to a consumer and tell them oh eat it is okay, you won't get sick! Because it's not a safety hazard. Will they eat it? No. They can just simply look at it or smell it and get sick. 

Edited by The Food Scientist, 20 December 2019 - 05:31 PM.

[Charles.C]

Hi Food Safety Experts,

 

Could someone plz advice is the freezing step CCP or not

 

There is a useful discussion over this topic here (2013) -

 

https://www.ifsqn.co...-control-point/

 

Also see the excel compilation in Post 13 (seems my NZ recollection in Post 7 was incorrect)

 

@ Food Scientist, this is a 1994 quote which illustrates the historical  treatment of spoilage within haccp  -

 

 A. Identification of Potential Hazards

Hazards have been defined (ICMSF 1988) as the unacceptable contamination, growth or survival of bacteria in food that may affect food safety or quality (spoilage) or the unacceptable production or persistence in foods of substances such as toxins, enzymes or products of microbial metabolism.

 

The U.S. National Advisory Committee on Microbiological Criteria for Foods (NACMCF 1992) have defined a hazard as: a biological, chemical or physical property that may cause a food to be unsafe for consumption (NACMCF 1992). For inclusion on the list, hazards must be of a nature such that their elimination or reduction to acceptable levels is essential to the production of safe food. (Some food companies also include regulatory compliance, nutritional value and other important aspects in the definition of hazards). Hazards which are of low risk and not likely to occur would not require further considerations (NACMCF 1992).

 

Thus, while the ICMSF includes both safety aspects and quality in the definition of hazards, the US-NACMCF is only including safety. In the present presentation, the HACCP-system will be used to control both safety and all aspects of spoilage of fish products.

 

http://www.fao.org/3...8E/T1768E05.htm

 

However, afaik, following the haccp presentations by Codex (1997) and NACMCF (1998),  HACCP treatments have typically excluded spoilage aspects from hazard analyses.

[Ryan M.]

CCP means food safety.  Product spoilage is not necessarily food safety.  A product can be food safety compromised without spoilage.  Spoilage can happen in a product and it still is perfectly safe to consume.  Milk / Dairy based products are great examples of products that can fall under both types of issues.

 

These definitions are important.

 

Food Safety =/ Quality

Edited by Ryan M., 22 December 2019 - 12:16 AM.

[The Food Scientist]

Yes I am 100% aware Spoilage is not regarded as a hazard. But again you still cannot sell and consume some spoiled foods, as some are caused by pathogenic bacteria like B.cereus and C. perfringens. (meat & dairy). Really you have these pathogens as the hazards that will in turn, also cause spoilage. (affecting quality of the food). So the goal is not to really "prevent" spoilage, it is to minimize, reduce and eliminate these pathogens ( to prevent illness) that do cause spoilage. 

[The Food Scientist]

Depends on your product and your process. For instance, we purchase an ingredient that is flash-frozen to rapidly decrease the products temperature. This is considered a CCP because the flash-freezing process is used as a means to prevent the product from spoiling. This particular product would otherwise be compromised if not flash-frozen as simply placing the product in a freezer to cool over a long period of time would cause the product to spoil. By flash-freezing, the product is able to significantly reduce, or eliminate the possibility of spoilage.

 

Ask yourself: Without the process step, would the product be compromised? or is the step required to keep the food safe, and is it the last step to keep the food safe from X?

 

 

Can you share what your products are?

[Ryan M.]

Yes I am 100% aware Spoilage is not regarded as a hazard. But again you still cannot sell and consume some spoiled foods, as some are caused by pathogenic bacteria like B.cereus and C. perfringens. (meat & dairy). Really you have these pathogens as the hazards that will in turn, also cause spoilage. (affecting quality of the food). So the goal is not to really "prevent" spoilage, it is to minimize, reduce and eliminate these pathogens ( to prevent illness) that do cause spoilage. 

 

"Spoilage" is a common term relating to quality.  Quality should not be intermingled when assessing food safety hazards.  Spoilage bacteria does not necessarily mean there will be pathogens, and vice versa.  Additionally, "pathogens" are considered adulterants, not really spoilage in regulatory terminology.

 

If freezing is to be deemed a CCP then it needs to have a targeted microorganism that causes illness, or produces toxins.  If freezing is used for spoilage then it is not a CCP, but can be a critical quality point in a quality plan.

[CMHeywood]

If you consider a CCP as a control to remove or reduce contamination then freezing is not a CCP.  Freezing does not remove or reduce contamination.

 

However, freezing is necessary for your product to prevent the growth of microbio contamination.  So it is a very important, necessary control for your process.

 

If you define "very important, necessary control point" = "critical control point", then you are just redefining "very important, necessary" as being "critical".  

 

So in my opinion, it doesn't matter if you call it a CCP, or call it a PRP with a very high risk level.  Either way, the freezing must be done.  Your procedure describing the freezing should note that this is a critical, important, necessary (whatever words you choose) procedure and must be done at all times.

 

I think we sometimes get caught up in the different definitions and interpretations.  Bottomline, is that your control program must be adequate - (1) it works, (2) it is done correctly, and (3) you can prove that it is being done (records).

[Charles.C]

If you consider a CCP as a control to remove or reduce contamination then freezing is not a CCP.  Freezing does not remove or reduce contamination.

 

However, freezing is necessary for your product to prevent the growth of microbio contamination.  So it is a very important, necessary control for your process.

 

If you define "very important, necessary control point" = "critical control point", then you are just redefining "very important, necessary" as being "critical".  

 

So in my opinion, it doesn't matter if you call it a CCP, or call it a PRP with a very high risk level.  Either way, the freezing must be done.  Your procedure describing the freezing should note that this is a critical, important, necessary (whatever words you choose) procedure and must be done at all times.

 

I think we sometimes get caught up in the different definitions and interpretations.  Bottomline, is that your control program must be adequate - (1) it works, (2) it is done correctly, and (3) you can prove that it is being done (records).

 

Sorry but IMO there are several debatable assumptions in the above comments.

 

Probably "safer"  to reference a typical haccp system/definitions such as that associated with GFSI-recognised Standards. The OP unfortunately suffered from a similar lack of precision.

 

Including a discussion of terms like like risk, prevention, validation, verification would have helped.

 

Might add that from a workload POV, it can matter whether one classifies freezing as a CCP. or not. This was one reason for the boom in use of Prerequisite Programs.

[MSifat]

Still, even if the possibility of spoilage is not by any pathogenic bacteria, where there is potentiality of spoilage, to prevent it, CCP must be set for that point. Because, the bacteria that cause the spoilage, can cause stomach upset when they are higher than limit of acceptable level. And in the spoiled products, they are always higher. So it should be a CCP.

"Spoilage" is a common term relating to quality.  Quality should not be intermingled when assessing food safety hazards.  Spoilage bacteria does not necessarily mean there will be pathogens, and vice versa.  Additionally, "pathogens" are considered adulterants, not really spoilage in regulatory terminology.

 

If freezing is to be deemed a CCP then it needs to have a targeted microorganism that causes illness, or produces toxins.  If freezing is used for spoilage then it is not a CCP, but can be a critical quality point in a quality plan.

[Ryan M.]

Still, even if the possibility of spoilage is not by any pathogenic bacteria, where there is potentiality of spoilage, to prevent it, CCP must be set for that point. Because, the bacteria that cause the spoilage, can cause stomach upset when they are higher than limit of acceptable level. And in the spoiled products, they are always higher. So it should be a CCP.

 

No.  In food safety a CCP is meant for safety, such as if you lose control of your CCP people will become very ill and/or die.  An upset stomach is not "very ill" or "death".  What you are referring to may be a PRP or ORP, whatever you want to call it.  And, again you need targeted organism(s) for your CCP if it is a biological hazard.