12 replies to this topic

[thanhtung259]

Hello everyone, i am a new member. Now i'm QA of restaurant, i'm writting HACCP for my restaurant and our team are arguing about Storage is a CCP or not. According to my team, they used CCP decision tree and thought that Storage is a CCP (chill and frozen) because this step are special designed step for prevent growth of pathogen bacteria (low temperature). As far as i know, i don't think this step is CCP because there nothing special design, it's just for storage. This step doesnt dedicate time for storage, just temperature. We don't record temperature of products, just record the temperature of the storage.
Our process is: receiving, storing, preparing, cooking, chilling
Please give me advices
My many thanks :)

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[TimG]

It sounds to me like your team is correct.

FDA defines a CCP as: Critical Control Point: A step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level.

I can't imagine this definition would be any different in Vietnam.

 

No where in that definition does it mention "special design." But even if it did, a chilled temperature controlled environment would indeed be a 'special design' as it's specially designed to keep the enclosed space at a temperature differing from its surrounding environment.

 

Have you had HACCP management courses? If so, have you performed a hazard analysis on the process yourself? I'd be interested to see how a refrigeration storage step isn't essential to prevent or eliminate pathogenic hazards.

[pHruit]

I presume you're looking at the Codex decision tree where question two reads: "Is the step specifically designed to eliminate or reduce the likely occurrence of a hazard to an acceptable level?".

In this case, context is very relevant, although as with many things it also comes down to interpretation.
One could argue that, if the hazard at the storage stage is the growth of a given pathogen (or pathogens), the temperature regime is specifically designed to reduce the likely occurrence of the hazard - freezing the product stops growth, chilling it slows growth etc. Equally one could argue this is part of a prerequisite program...

Indeed the Codex document CAC/RCP1-1969 itself notes that: "Application of a decision tree should be flexible, given whether the operation is for production, slaughter, processing, storage, distribution or other. It should be used for guidance when determining CCPs. This example of a decision tree may not be applicable to all situations. Other approaches may be used. Training in the application of the decision tree is recommended.".

 

As TimG suggests, training on HACCP is extremely useful to be able to implement a system well and to get the best out of it, so that might be something to investigate.

It may be that your local regulatory body for the food industry has guidance on this too, and indeed if it's useful as a reference the UK has two sets of information designed to help caterers/restaurants and similar implement the basics of HACCP and associated food safety management systems:

https://myhaccp.food.gov.uk/

https://www.food.gov...better-business

[Charles.C]

Hello everyone, i am a new member. Now i'm QA of restaurant, i'm writting HACCP for my restaurant and our team are arguing about Storage is a CCP or not. According to my team, they used CCP decision tree and thought that Storage is a CCP (chill and frozen) because this step are special designed step for prevent growth of pathogen bacteria (low temperature). As far as i know, i don't think this step is CCP because there nothing special design, it's just for storage. This step doesnt dedicate time for storage, just temperature. We don't record temperature of products, just record the temperature of the storage.
Our process is: receiving, storing, preparing, cooking, chilling
Please give me advices
My many thanks :)

Sent from my LM-G710 using Tapatalk

 

Hi thanhtung,

 

It might relate to whether you are implementing any particular FS Standard, eg iso22000 etc.

 

Generically, see this older thread -

 

https://www.ifsqn.co...cp/#entry113700

 

You can find cold storage  argued as a CCP, PRP, or OPRP.

 

Nowadays, IMO it is more likely, prior to the hazard analysis, to be designated as a PRP, eg iso22002-1

 

If you would like to see a recent tabular-type USDA hazard analysis -

 

 USDA hazard analysis - Hot Dog.pdf   203.69KB   8 downloads

 

PS - IIRC the later Campden version of Codex tree has as Question No.1 - Is this a PRP ?

 

PPS - I mostly avoid the "pure" Codex tree since it often tends to generate arguments like the present.

 

P3S - the Codex tree is supposed (NACMCF) to only be applied to significant hazards, eg as derived from a risk assessment. Is this significant ?

 

P4S - IIRC, "special design" was originally incorporated so as to focus on items like metal detectors.

[thanhtung259]

Hi thanhtung,

It might relate to whether you are implementing any particular FS Standard, eg iso22000 etc.

Generically, see this older thread -

https://www.ifsqn.co...cp/#entry113700

You can find cold storage argued as a CCP, PRP, or OPRP.

Nowadays, IMO it is more likely, prior to the hazard analysis, to be designated as a PRP, eg iso22002-1

If you would like to see a recent tabular-type USDA hazard analysis -

USDA hazard analysis - Hot Dog.pdf

PS - IIRC the later Campden version of Codex tree has as Question No.1 - Is this a PRP ?

PPS - I mostly avoid the "pure" Codex tree since it often tends to generate arguments like the present.

P3S - the Codex tree is supposed (NACMCF) to only be applied to significant hazards, eg as derived from a risk assessment. Is this significant ?

P4S - IIRC, "special design" was originally incorporated so as to focus on items like metal detectors.

Thanks Charles.C,
I reads a lots of your comments in this forum and i just don't know what does "IMO" mean
I'm graduated Food technology. All of my teachers are now working for export company (seafoods, meats,...) and 5 star-restaurant too, they told me that storage should not be concerned as a CCP because it's PRPs like you said. I see a lot of people think storage is CCP because it's just low temperature, however, i think it's not necessary and make this step CCP just give my team more papers, more procedure.
Should I explain it for my team about this? Or i just follow them?



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[thanhtung259]

It sounds to me like your team is correct.
FDA defines a CCP as: Critical Control Point: A step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level.
I can't imagine this definition would be any different in Vietnam.

No where in that definition does it mention "special design." But even if it did, a chilled temperature controlled environment would indeed be a 'special design' as it's specially designed to keep the enclosed space at a temperature differing from its surrounding environment.

Have you had HACCP management courses? If so, have you performed a hazard analysis on the process yourself? I'd be interested to see how a refrigeration storage step isn't essential to prevent or eliminate pathogenic hazards.

Thanks TimG,
I graduated Food Technology. I used to work as QC in seafoods factory, QC in milk factory,... There are no CCP for storage step. I understand that a lot of people think storage is CCP. However, HACCP is not a standard, it's just a plan, methods for food safety so that it should be suitable and more effective for our company. As far as I know, put CCP in this step makes us more papers work and it's not necessary. We have great standard for storage, audit it everyday, i believe that this step should be PRPs or just a control point

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[thanhtung259]

I presume you're looking at the Codex decision tree where question two reads: "Is the step specifically designed to eliminate or reduce the likely occurrence of a hazard to an acceptable level?".
In this case, context is very relevant, although as with many things it also comes down to interpretation.
One could argue that, if the hazard at the storage stage is the growth of a given pathogen (or pathogens), the temperature regime is specifically designed to reduce the likely occurrence of the hazard - freezing the product stops growth, chilling it slows growth etc. Equally one could argue this is part of a prerequisite program...
Indeed the Codex document CAC/RCP1-1969 itself notes that: "Application of a decision tree should be flexible, given whether the operation is for production, slaughter, processing, storage, distribution or other. It should be used for guidance when determining CCPs. This example of a decision tree may not be applicable to all situations. Other approaches may be used. Training in the application of the decision tree is recommended.".

As TimG suggests, training on HACCP is extremely useful to be able to implement a system well and to get the best out of it, so that might be something to investigate.
It may be that your local regulatory body for the food industry has guidance on this too, and indeed if it's useful as a reference the UK has two sets of information designed to help caterers/restaurants and similar implement the basics of HACCP and associated food safety management systems:
https://myhaccp.food.gov.uk/
https://www.food.gov...better-business

Thanks for your advices pHruit,
I graduated Food Technology and i understand how HACCP works in some factories (seafoods, meats,...) which i worked before. Most of people, include my team, think storage is CCP. I don't know how to say, i think it's a little bit robot and it's not good.

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[zanorias]

As far as I know, put CCP in this step makes us more papers work and it's not necessary.

 

Whichever way you go, make sure that your justification based on neccessity for food safety - not whichever option means less paperwork  

 

IMO = 'In My Opinion'

[thanhtung259]

Whichever way you go, make sure that your justification based on neccessity for food safety - not whichever option means less paperwork

IMO = 'In My Opinion'

Thanks zanorias,
My team, include my manager, they didn't learn Food Technology or Food safety as a main degree. They were trained ISO22000, then copied lots of examples on the Internet, just followed them without any knowlegde about significant hazard or not in our restaurant. I just want to make paperworks more simple, and when i quit my jobs, our team can follow this HACCP plan more easier.
I don't know how to describe my feeling, i feel a little tired. It looks like robots, they just want to deal with third-party audit, not for the quality

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[TimG]

Yeah, there's been a debate on this site for a while on the PrP/CCP for cold storage debate. 

'IMO stands for 'in my opinion.' By the way, that's relevant. Regardless of our interpretations here, it will come down to what your auditor interprets in the code/law. If your auditor decides the cold storage must be a CCP, it will be a hard fight to convince them otherwise, especially if you already had it listed as a CCP. 

I've personally only worked in one 'cold-chain' environment. It was a box in box out grocery distributor. I can't fathom trying to take those cold chain steps and turning them into a PRP. So my interpretation is pretty one sided.

[thanhtung259]

Yeah, there's been a debate on this site for a while on the PrP/CCP for cold storage debate.
'IMO stands for 'in my opinion.' By the way, that's relevant. Regardless of our interpretations here, it will come down to what your auditor interprets in the code/law. If your auditor decides the cold storage must be a CCP, it will be a hard fight to convince them otherwise, especially if you already had it listed as a CCP.
I've personally only worked in one 'cold-chain' environment. It was a box in box out grocery distributor. I can't fathom trying to take those cold chain steps and turning them into a PRP. So my interpretation is pretty one sided.

Thanks for your advices,
I will update my hazard analysis in this post as soon as i can because i need to translate it in English (my english is not too good and it takes time to finish)
I hope guys give me your opions so i can improve my knowledges in FSMS

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[Charles.C]

Thanks Charles.C,
I reads a lots of your comments in this forum and i just don't know what does "IMO" mean
I'm graduated Food technology. All of my teachers are now working for export company (seafoods, meats,...) and 5 star-restaurant too, they told me that storage should not be concerned as a CCP because it's PRPs like you said. I see a lot of people think storage is CCP because it's just low temperature, however, i think it's not necessary and make this step CCP just give my team more papers, more procedure.
Should I explain it for my team about this? Or i just follow them?



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Hi thanhtung,

 

IMO means "In My Opinion". See -

 

https://www.ifsqn.co...ons/#entry24154

 

IMO you need to ensure your team focus on the chronological aspect of  implementing haccp.

 

The first step should be to specify/list PRPs, before you worry about CCPs. This facilitates doing the hazard analysis since control by PRPs can be automatically assumed to ensure that related hazards are not significant, ie not producing CCPs. This aspect is under-discussed in Codex.

 

Originally haccp focus tended to be on only finding CCPs, as many as possible. Later, PRPs were introduced and used more widely so as to reduce the total number of CCPs and enable concentration on the fewer but  "real" critical control points.

 

I recommend you to read Practical HACCP by Mortimore et al which has very clear English and a wealth of haccp experience/examples inside although I don't always agree with its use of Decision trees. One practical snag is that it has a lot of pages.

[thanhtung259]

Hi thanhtung,

IMO means "In My Opinion". See -

https://www.ifsqn.co...ons/#entry24154

IMO you need to ensure your team focus on the chronological aspect of implementing haccp.

The first step should be to specify/list PRPs, before you worry about CCPs. This facilitates doing the hazard analysis since control by PRPs can be automatically assumed to ensure that related hazards are not significant, ie not producing CCPs. This aspect is under-discussed in Codex.

Originally haccp focus tended to be on only finding CCPs, as many as possible. Later, PRPs were introduced and used more widely so as to reduce the total number of CCPs and enable concentration on the fewer but "real" critical control points.

I recommend you to read Practical HACCP by Mortimore et al which has very clear English and a wealth of haccp experience/examples inside although I don't always agree with its use of Decision trees. One practical snag is that it has a lot of pages.

Thanks so much Charles.C,
I will try to dicuss this with my team, i hope they listen to me.
And i will read this book too

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