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Unsure about CCP in turmeric powder manufacturing industry


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#1 Rajkumaar

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Posted 21 February 2020 - 11:05 AM

Dear Food Safety Specialists, 

             

I am working in a turmeric powder manufacturing industry. In the processing line we have 4 controls here

                 

                 1. 4000 gauss magnet in pulverizer feeder

                 2. 12000 gauss magnet at the end of cyclone separator

                 3. Powder Siever  & 

                 4. Metal detector

 

  In this four controls which we have to take as CCP.

 

    If Metal detector was the CCP means, then what the others will be, are they OPRP's. 

     Can anyone please help me out with this doubt?



#2 pHruit

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Posted 21 February 2020 - 11:47 AM

Views on what to call non-CCP controls (OPRPs etc) and expectations around these can vary between certification schemes, so that may have a bearing on the semantics of the situation.

Assuming you've listed these in the chronological order in which they occur, metal detection would probably be the "expected" physical CCP and thus the magnets would likely be called something else.
The sieve is perhaps a more interesting question as there is an argument that it addresses a far greater range of potential physical hazards than the metal detectors or magnets, since it can remove non-metallic physical contaminants. The consideration around this step therefore potentially comes down to consideration of the particular nature and corresponding likelihood of non-metal hazards in your product and process.

 



#3 Charles.C

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Posted 21 February 2020 - 01:32 PM

 

Dear Food Safety Specialists, 

             

I am working in a turmeric powder manufacturing industry. In the processing line we have 4 controls here

                 

                 1. 4000 gauss magnet in pulverizer feeder

                 2. 12000 gauss magnet at the end of cyclone separator

                 3. Powder Siever  & 

                 4. Metal detector

 

  In this four controls which we have to take as CCP.

 

    If Metal detector was the CCP means, then what the others will be, are they OPRP's. 

     Can anyone please help me out with this doubt?

 

 

Hi Rajkumaar,

 

I assume you are implementing iso22000 or fssc22000.

 

Accordingly you are required to do a risk assessment (eg LxS) of the potential hazards along the stages of the flowchart while including the infuence of the (hopefully) already designated PRPs.

 

Flowchart not provided but I assume MD is at the end of the line.

 

(1) Conceptually the risk assessment logic is <<< What will be the consequence if any "hazardous" metal contamination is not removed in first 3 units ?>>>>.

If such a defect does occur and passes 3rd unit but is then reliably remedied by the final MD, then the likelihood of defect reaching the "consumer" is LOW. Consequently the risk at first 3 units will not generate a significant hazard, ie neither CCP or OPRP. In contrast,  the likelihood at final MD for same defect will, analogously, be HIGH thereby generating a CCP or OPRP.

 

(2) One can also find Literature support (for Codex haccp) for (a) creating a "combined" CCP (or OPRP) using >1 of the 4 units (eg if any/all of units 1-3 are regarded as "equally" critical as the MD), (b) making at least one of the first 3 units + MD as separate CCPs (or OPRPs).

 

It seems to me that the "simple" analysis in (1)  is the least argumentative route (an analogous situation for 2 MDs in series is also noted in Literature for Codex haccp).

 

PS - even further options are feasible whereby earlier units are classified as PRPs but seems easier to ignore this if possible.

PPS - depending on yr interpretation of OPRPs, such could be involved in (1) however I try to avoid using them if possible. Normally it is relatively easy for decision trees to show that a MD qualifies as a CCP in iso-haccp..


Edited by Simon, 21 February 2020 - 01:59 PM.
added

Kind Regards,

 

Charles.C





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