Juice HACCP - Frequency of monitoring sanitation controls
Hi all,
We are having a healthy discussion/debate about the interpretation of parts of the Juice HACCP regulation, specifically 21CFR120.6. If you read below, it states what you have to do, and that you have to do it before, during and after processing. What is your interpretation of "before, during and after?"
Our debate is whether it means:
A. We use a checklist of the 8 items and do them 3 times every day (or every day you manufacture juice) - before we start processing, while we are processing, and after processing stops.
or
B. We use our routine monitoring of the 8 key items, for which there are already established procedures and records, but may not be daily.
If we already do all these things, do we need to do them to three times a day/shift? I'm struggling. A combination of A and B seems reasonable, but we're not sure. What are your thoughts?
§120.6 Sanitation standard operating procedures.
(a) Sanitation controls. Each processor shall have and implement a sanitation standard operating procedure (SSOP) that addresses sanitation conditions and practices before, during, and after processing.
(1) Safety of the water that comes into contact with food or food contact surfaces or that is used in the manufacture of ice;
(2) Condition and cleanliness of food contact surfaces, including utensils, gloves, and outer garments;
(3) Prevention of cross contamination from insanitary objects to food, food packaging material, and other food contact surfaces, including utensils, gloves, and outer garments, and from raw product to processed product;
(4) Maintenance of hand washing, hand sanitizing, and toilet facilities;
(5) Protection of food, food packaging material, and food contact surfaces from adulteration with lubricants, fuel, pesticides, cleaning compounds, sanitizing agents, condensate, and other chemical, physical, and biological contaminants;
(6) Proper labeling, storage, and use of toxic compounds;
(7) Control of employee health conditions that could result in the microbiological contamination of food, food packaging materials, and food contact surfaces; and
(8) Exclusion of pests from the food plant.
(b) Monitoring. The processor shall monitor the conditions and practices during processing with sufficient frequency to ensure, at a minimum, conformance with those conditions and practices specified in part 110 of this chapter and in subpart B of part 117 of this chapter that are appropriate both to the plant and to the food being processed. Each processor shall correct, in a timely manner, those conditions and practices that are not met.
Hi all,
We are having a healthy discussion/debate about the interpretation of parts of the Juice HACCP regulation, specifically 21CFR120.6. If you read below, it states what you have to do, and that you have to do it before, during and after processing. What is your interpretation of "before, during and after?"
Our debate is whether it means:
A. We use a checklist of the 8 items and do them 3 times every day (or every day you manufacture juice) - before we start processing, while we are processing, and after processing stops.
or
B. We use our routine monitoring of the 8 key items, for which there are already established procedures and records, but may not be daily.
If we already do all these things, do we need to do them to three times a day/shift? I'm struggling. A combination of A and B seems reasonable, but we're not sure. What are your thoughts?
§120.6 Sanitation standard operating procedures.
(a) Sanitation controls. Each processor shall have and implement a sanitation standard operating procedure (SSOP) that addresses sanitation conditions and practices before, during, and after processing.
(1) Safety of the water that comes into contact with food or food contact surfaces or that is used in the manufacture of ice;
(2) Condition and cleanliness of food contact surfaces, including utensils, gloves, and outer garments;
(3) Prevention of cross contamination from insanitary objects to food, food packaging material, and other food contact surfaces, including utensils, gloves, and outer garments, and from raw product to processed product;
(4) Maintenance of hand washing, hand sanitizing, and toilet facilities;
(5) Protection of food, food packaging material, and food contact surfaces from adulteration with lubricants, fuel, pesticides, cleaning compounds, sanitizing agents, condensate, and other chemical, physical, and biological contaminants;
(6) Proper labeling, storage, and use of toxic compounds;
(7) Control of employee health conditions that could result in the microbiological contamination of food, food packaging materials, and food contact surfaces; and
(8) Exclusion of pests from the food plant.
(b) Monitoring. The processor shall monitor the conditions and practices during processing with sufficient frequency to ensure, at a minimum, conformance with those conditions and practices specified in part 110 of this chapter and in subpart B of part 117 of this chapter that are appropriate both to the plant and to the food being processed. Each processor shall correct, in a timely manner, those conditions and practices that are not met.
I am in Seafood HACCP, and we fall under the same requirements. (from how it looks)
From what I know, BOTH interpretations. Yes a combination.
Now in the 8 key ones, there are items you will do DAILY, (before, during and after). and there are items you will do Monthly and some you will do periodically, because some things are not requiring you to do daily, depending on that certain item. I will attach examples for forms we use to simplify for you what it means when you combine them (daily, monthly and periodically, depending on the area. I hope that helps you :)
Attached Files
Hi miri,
Here is a US haccp/ssop package stated to be appropriate to cold pressed juice -
Juice SSOP Program,2014.pdf 123.66KB 41 downloads
Juice-HACCP-Plan.zip 209.4KB 37 downloads
You can see that, in agreement with the nice layouts in previous post, a degree of interpretation is applied to the 21cfr 120.6 "menu" of requirements.
You may also find this seafood ssop program of some interest in respect to illustrative records/forms. The procedures (colloquially termed the" Big 8" ) intend to match the US seafood regulation (1995) (21cfr 123) which predates but seems to closely parallel 21cfr 120.6 -
SSOP Plan - Sanitation Control Records,haccp alliance.pdf 1.48MB 52 downloads
PS - JFI here are 2 more Juice haccp documents -
FDA-Juice HACCP Hazards and Controls Guidance,2004.pdf 1.23MB 36 downloads
juice haccp, training and regulations,2002.pdf 690.14KB 29 downloads