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Why is treated Post Harvest Wash Not a CCP

HACCP Primus CCP Chlorine Dioxide

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#1 amac19

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Posted 29 February 2020 - 01:10 AM

My company previously used a consulting company to create a HACCP Plan. We are a tree fruit (peaches, plums) packing shed. In reviewing our HACCP plan I noticed that no CCPs are listed. We do a Post-Harvest Wash of all our fruit and the water is treated with Chlorine Dioxide (it is not recirculated). I feel like this could be a CCP under the guidelines of "prevent, eliminate or reduce the risk of the hazard to consumers." Is there any guidance on why this would not be a CCP?

 

Thank you



#2 Hank Major

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Posted 06 March 2020 - 09:27 PM

Because you would need to Validate, Verify and continually Monitor the washing step to be sure it was controlling the hazard. Most people would consider it a prerequisite program instead.



#3 Charles.C

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Posted 06 March 2020 - 09:31 PM

In some texts it is a CCP.

 

Experts do not always agree. :smile:


Kind Regards,

 

Charles.C


#4 Tbaker13

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Posted 05 November 2020 - 05:07 PM

A little late to the party, but I manage the food safety program for an apple packing facility (whole apples no slicing etc.) and the reason that we do not have it as a CCP is that the fruit does not actually get sanitized or cleaned when going through the flume. The ORP System and the chlorination is there to sanitize the water to prevent cross contamination via the water and not the fruit. There is extensive research about the santitization levels and log reduction that it actually provides which is not significant enough to qualify as a Kill Step for the different pathogens that exist on the fruit themselves. Another reason/argument that I have used is that (at least for apples) Costco does not qualify them as a ready to eat product, the FDA recommends washing all fruit prior to eating them. 

Finally, I like to think of the Flume as more of a Transportation device to get the fruit to the packing line rather than a wash system since that really is the main function of the flume. If there were a way to put fruit on the line without bruising it and causing other quality issues that would be amazing and we could eliminate water from the process almost entirely!



#5 Charles.C

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Posted 05 November 2020 - 05:48 PM

A little late to the party, but I manage the food safety program for an apple packing facility (whole apples no slicing etc.) and the reason that we do not have it as a CCP is that the fruit does not actually get sanitized or cleaned when going through the flume. The ORP System and the chlorination is there to sanitize the water to prevent cross contamination via the water and not the fruit. There is extensive research about the santitization levels and log reduction that it actually provides which is not significant enough to qualify as a Kill Step for the different pathogens that exist on the fruit themselves. Another reason/argument that I have used is that (at least for apples) Costco does not qualify them as a ready to eat product, the FDA recommends washing all fruit prior to eating them. 

Finally, I like to think of the Flume as more of a Transportation device to get the fruit to the packing line rather than a wash system since that really is the main function of the flume. If there were a way to put fruit on the line without bruising it and causing other quality issues that would be amazing and we could eliminate water from the process almost entirely!

Hi Tbaker,

 

IIRC, an analysis of the situation as you mention was presented several years ago. From memory,  the analysis presented was also used to support a Process CCP. As you say, FDA tends to avoid CCPs in their own published articles preferring to use terms like "minimising" risks of contamination. HACCP is often a subjective topic.

 

A CCP's typical definition includes some flexibility, eg -

 

CCP
step  in  the  process  at  which  control  measure(s)  is  (are)  applied  to  prevent  or  reduce  a significant  food  safety  hazard  to  an  acceptable  level,  and  defined  critical  limit(s)   and measurement  enable the application of corrections (3.9)

Kind Regards,

 

Charles.C


#6 LostMyMind

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Posted 05 November 2020 - 06:37 PM

We handle fresh citrus out of Florida and are audited by Primus annually.  For more than a decade the fact that our drencher (first step after fruit arrival) was not a CCP consideration or talking point with them, but this past year, I lost points because it wasn't and because I refused to make it one.  I'm hoping it was just that auditor and not a new wholesale "we know better than you do" logic by them (He stated that he had been told by Primus that ALL recirculated water systems were to be considered CCPs).  After that, I wrote a separate deep-dive five page HACCP-based justification on why it isn't to try and better protect myself from future auditors.  Using the Codex Alimentarius logic, the crux of the analysis is below (if it helps you out).  And for the record, I have very strong direct science for my industry, location, products and activities, so this is all based on them:

 

Question 1: Do control preventive measure(s) exist?
Yes, the company employs a sanitizer (PAA) to the recirculated water prior to its application to prevent cross-contamination.  Based upon the Yes answer, move to Question 2.
 
 
Question 2: Is the step specifically designed to eliminate or reduce the likely occurrence of a hazard to an acceptable level?
No.  The purpose of this step is apply a fungicide to the fruit.  It is not intended to reduce or eliminate the possibility of biological contaminants on the citrus fruit.  Based upon the No answer, move to Question 3.  
 
 
Question 3: Could contamination with identified hazard(s) occur in excess of acceptable level(s) or could these increase to unacceptable levels?
Yes.  Should the PAA sanitizer application fail, it is possible that cross contamination of the fruit could occur, leading to elevated levels of biological contaminates.  Based upon the Yes answer, move to Question 4.
 
 
Question 4: Will a subsequent step eliminate identified hazard(s) or reduce likely occurrence to an acceptable level? 
Yes.  There are multiple steps (identified below) that occur later in the process steps within the packing house that been scientifically proven to reduce the possibility of biological risk (pathogens) to an acceptable level.  
 
Anyway maybe this will help you  a little somehow....
 
Good luck,
LostMyMind 
 


#7 Charles.C

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Posted 05 November 2020 - 08:06 PM

 

We handle fresh citrus out of Florida and are audited by Primus annually.  For more than a decade the fact that our drencher (first step after fruit arrival) was not a CCP consideration or talking point with them, but this past year, I lost points because it wasn't and because I refused to make it one.  I'm hoping it was just that auditor and not a new wholesale "we know better than you do" logic by them (He stated that he had been told by Primus that ALL recirculated water systems were to be considered CCPs).  After that, I wrote a separate deep-dive five page HACCP-based justification on why it isn't to try and better protect myself from future auditors.  Using the Codex Alimentarius logic, the crux of the analysis is below (if it helps you out).  And for the record, I have very strong direct science for my industry, location, products and activities, so this is all based on them:

 

Question 1: Do control preventive measure(s) exist?
Yes, the company employs a sanitizer (PAA) to the recirculated water prior to its application to prevent cross-contamination.  Based upon the Yes answer, move to Question 2.
 
 
Question 2: Is the step specifically designed to eliminate or reduce the likely occurrence of a hazard to an acceptable level?
No.  The purpose of this step is apply a fungicide to the fruit.  It is not intended to reduce or eliminate the possibility of biological contaminants on the citrus fruit.  Based upon the No answer, move to Question 3.  
 
 
Question 3: Could contamination with identified hazard(s) occur in excess of acceptable level(s) or could these increase to unacceptable levels?
Yes.  Should the PAA sanitizer application fail, it is possible that cross contamination of the fruit could occur, leading to elevated levels of biological contaminates.  Based upon the Yes answer, move to Question 4.
 
 
Question 4: Will a subsequent step eliminate identified hazard(s) or reduce likely occurrence to an acceptable level? 
Yes.  There are multiple steps (identified below) that occur later in the process steps within the packing house that been scientifically proven to reduce the possibility of biological risk (pathogens) to an acceptable level.  
 
Anyway maybe this will help you  a little somehow....
 
Good luck,
LostMyMind 

 

Hi LMM,

 

Thks for input.

 

Not my product area but I'm not quite sure how above relates to the OP, eg fungicide drenching (not sure what that is) vs fluming/washing/chlorinated water.

 

IIRC, for many years, the chlorinated water treatment aspect in fresh produce process texts was typically  haccp-presented as a direct pathogen-reducing step /CCP  but this CCP was later "re-oriented" based on the prevention of cross-contamination logic.

 

The Codex tree can sometimes be ambiguous. IMO the hazard analysis  is the most important step for determining significant hazards albeit subjective opinions are sometimes inevitable.

 

I didn't understand how qu1 links to qu 2. Seems that different hazards are being discussed??

 

qu 4 appears to imply that a combined control measure may be involved.


Kind Regards,

 

Charles.C


#8 LostMyMind

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Posted 05 November 2020 - 08:46 PM

@ Charles...

 

1. It applies because it is at the beginning of the process in both cases.  The logic would be similar regardless of the sanitizer involved (acknowledging differences in how those sanitizers actually work, the differences in risks, etc.).

 

2. A hazard analysis is and was completed which excluded the step from being a CCP, but that was not deemed acceptable my GFSI auditor; ergo a more detailed justification for future auditors.  A justification I consider to be a waste of time, but a necessary one for the scheme.

 

3. The step is to apply a fungicide.  The addition of a sanitizer is to reduce the likelihood of cross-contamination.  The justification is not concerned with the fungicide; that is part of the original HACCP analysis itself.  

 

4. Yes, I was referring to multiple additional steps that were outline later in the document.  Basically, since you asked, once the fruit inside, it is drenched with PAA (85ppm) for 2 minutes, goes through a brush/wash step, and then onto heating/waxing.  Each of those steps leads to different microbiological reductions.  Those reductions are best outlined in Michelle Danyluk's (and others) recent work in Reduction of Escherichia coli, as a surrogate for Salmonella spp., on the surface of grapefruit during various packingline processes.  Or you can go back further to Pao & Brown's Reduction of Microorganisms on Citrus Fruit Surfaces during Packinghouse Processing or perhaps Zhang's Detection of Microbial Populations on Freshly Packed Florida 'Valencia' Oranges or (you get the idea). 

 
The underlying point I was making was that it is perfectly fine IMO to not call a recirculated water system a CCP if you have the underlying justification/logic required by the HACCP process and I try to provide an example of what that thought process might look like.  I'm sorry that I tried to help.  You can just delete my posts....
 
Thanks,
LMM






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