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Temperature as a CCP in a non cooking facility

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nontando

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Posted 09 June 2020 - 06:13 AM

Good Morning Everyone

 

Please may i have some clarification or better understanding in terms of temperature being a CCP in a non cooking facility.

 

We currently supply retail with ready to eat salads and prepared vegetable packs that require further cooking. 

 

On our last audit, the auditor recommended that we list temperature of our high risk area and dispatch as a CCP, currently we have them as OPRP's.

 

Should we do so? 

 

Thank you



Charles.C

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Posted 09 June 2020 - 08:56 AM

Good Morning Everyone

 

Please may i have some clarification or better understanding in terms of temperature being a CCP in a non cooking facility.

 

We currently supply retail with (a) ready to eat salads and (b) prepared vegetable packs that require further cooking. 

 

On our last audit, the auditor recommended that we list temperature of our high risk area and dispatch as a CCP, currently we have them as OPRP's.

 

Should we do so? 

 

Thank you

 

Hi nontando,

 

Some more info might assist.

 

I assume only (b) requires further cooking.

 

Frozen products ?
Which Product process commented on ?

Which high risk area  commented on ?

Why did the auditor make the suggestions ? eg Environment at high temperature ?

How do you dispatch ?


Kind Regards,

 

Charles.C


El Molino

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Posted 09 June 2020 - 03:13 PM

Auditors are not allowed to make recommendations - oPRP's are required in ISO 22000 - I am assuming this is the standard to which you are audited. Did you auditor give you a NC or was this just a suggestion?If you determined this by a decision tree and prove it is an oPRP - the auditor cannot question your decision. If by your analysis there is no reduction / elimination of a hazard you are correct 



GMO

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Posted 10 June 2020 - 07:58 AM

Good Morning Everyone

 

Please may i have some clarification or better understanding in terms of temperature being a CCP in a non cooking facility.

 

We currently supply retail with ready to eat salads and prepared vegetable packs that require further cooking. 

 

On our last audit, the auditor recommended that we list temperature of our high risk area and dispatch as a CCP, currently we have them as OPRP's.

 

Should we do so? 

 

Thank you

 

An interesting situation.  Firstly it is your HACCP plan, not the auditors.  That said, I have suggested changes to HACCP plans before on an audit, not because I presume to know better but because, having seen multiple plans, there are sometimes things which stick out as unusual.

 

As for whether their suggestion has merit, you need to go back to your risk assessment.  What is the cooking process at the customer?  Will it be effective at killing pathogens?  What kind of log reduction will they get?  If pathogens grow to high levels, is there a chance their cooking process will be ineffective in reducing the contamination to a safe level?  Are you clear in your labelling and specifications that the ingredients must be cooked?

 

I think you could end up looking at it in either way.  From a quality point of view (obviously not HACCP) you will need chilling to extend life.  From a safety point of view you might need chilling to prevent the consumer becoming ill based on the intended use of your product. 

 

I suppose you also need to consider customer and consumer misuse.  That is where, perhaps, chilling may become a CCP for you. 

 

But ultimately it's your plan, your decision and if I'm honest, whether it's an oPRP or CCP you're pretty likely to manage it the same way I'm guessing?





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