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Can we consider Aseptic tank or Aseptic bulk filler as CCP?


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#1 Tonying0287

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Posted 23 June 2020 - 01:23 AM

Dear Expert,

 

 

Can we consider Aseptic tank or Aseptic bulk filler as CCP?  Currently our CCP is UHT.

 

Process: Pasteurization --> Blending----> UHT --> Aseptic Tank --> Aseptic Bulk Filler

 

Thanks,

 

Tony



#2 Mathieu Colmant

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Posted 23 June 2020 - 07:28 AM

Hi Tony,

 

I don't know your process in your detail, so I will suggest you to keep with your decision tree... The main question you should answer there is "Is there any chance that my product is contaminated in such a way that the hasard will rise above the critical limit ?"


Mathieu Colmant

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#3 Tonying0287

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Posted 23 June 2020 - 07:35 AM

Hi Mathieu,

 

Our UHT is 141deg for 7 secs (CCP) and after that it will be stored in Aseptic tank with temp barriers, same for bulk filler.  If that barriers will deviate the asepticity of the product will compromise even if its already passed through the UHT.

 

Thanks,

 

Tony



#4 pHruit

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Posted 23 June 2020 - 07:50 AM

Obviously there is a degree of variation in how this type of process is interpreted, depending on the site / experience / choice of decision tree / standard / potentially also customer expectation...

Having looked at quite a few aseptic processes, I only recall seeing one example (out of several hundred) where the tank stage was a CCP. Doesn't mean it shouldn't be one if that's what your analysis and decision process are indicating, but you should be aware that it may get more questions because it's perhaps more commonly not expected to be one.

The most common ones for micro IMEX tend to be the final thermal process (time/temp) and the filler (head/chamber temp or equivalent, depending on the specifics of the machine).



#5 Tonying0287

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Posted 24 June 2020 - 12:32 AM

Actually we were thinking to identify the UHT and the bulk filling (temp barriers) as CCP. Is it possible that there is 2 CCPs in one process with the same hazard control?

 

 

Thanks,

 

Tony



#6 Charles.C

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Posted 24 June 2020 - 04:16 AM

Hi tonying,
 

Not my area (no idea what a "temperature barrier"  is ) and product is unknown but maybe this short thread is of some interest -

 

https://www.ifsqn.co...ptic-tanks-ccp/


Kind Regards,

 

Charles.C


#7 Mathieu Colmant

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Posted 24 June 2020 - 05:20 AM

Actually we were thinking to identify the UHT and the bulk filling (temp barriers) as CCP. Is it possible that there is 2 CCPs in one process with the same hazard control?

 

 

Thanks,

 

Tony

Hi Tony,

 

I won't say yes or no to your process as I don't know it. I need more information if you want me to give you an answer.

 

But you can have many CCP, if some are intended to remove the hazard (in your case : UHT - immediate CCP following codex tree) and the last one (and only one for that case) is intended to prevent the hazard coming back (Codex tree : Will avoid hasard reaching critical limit and no more step to control it)

 

However, UHT (temp and time) can have a critical limit (so it's a CCP), but what will be the critical limit on the step behind ? Will it be CCP or oPRP ?

Reminder : with ISO22000:2018 (and FSSC, then), when the critical limit is broken, you have to destroy or reprocess your product (or change the destination so the hazard is controlled). No other choice, no tolerance...


Edited by Mathieu Colmant, 24 June 2020 - 05:22 AM.

Mathieu Colmant

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#8 Tonying0287

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Posted 24 June 2020 - 05:41 AM

Hi Matheu,

 

We have 2 barriers in the Bulk filler (Steam barrier/Filling valve barrier) which requires minimum 121 deg Celcius to maintain the asepticity of the product. 

 

Yes you are correct, our machine is set to automatically discharge the product once temperature requirement is not met.

 

Thanks,



#9 pHruit

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Posted 24 June 2020 - 07:34 AM

 

Actually we were thinking to identify the UHT and the bulk filling (temp barriers) as CCP. Is it possible that there is 2 CCPs in one process with the same hazard control?

 

 

Thanks,

 

Tony

 

There are perhaps two ways to look at this?
If you characterise the hazard as just the specific organism(s) (i.e. the hazard is bacteria x/y/z) then they would both be addressing the same thing. However I believe you could entirely reasonably phrase the hazards as being slightly different, in that one is effectively "survival of bacteria x/y/z due to inadequate thermal process" and the other is "failure of aseptic status and contamination with bacteria x/y/z due to inadequate filler head temperature" (or similar).

Equally one could perhaps argue that the latter step is a prerequisite (the exact name of which may depend on your particularly certification requirements), so it really is going to come down to how you assess and interpret the hazards and how this is interpreted via your chosen decision process. Admittedly it's often possible to skew that decision process in the direction one prefers, so in an applied sense the key element is how to structure it so that you know that your process really is controlling the hazards, IMO.



#10 Ryan M.

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Posted 24 June 2020 - 11:50 PM

I would say no.  But, it depends on your process, the process controls in place, and the actual risk.  So...what is the actual risk with food safety if aseptic is compromised?  Keep in mind...food safety.  You have sterile product that is compromised.  What is the actual risk of pathogen outgrowth if compromised and if somehow it is packaged?

 

I'm also thinking you do a hold and release once the product passes all micro testing. Do you do finished product ATP testing to verify?



#11 Tonying0287

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Posted 26 June 2020 - 12:58 AM

Yes we do 14 days incubation prior release and we also do micro analysis on that duration.



#12 Ryan M.

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Posted 26 June 2020 - 04:38 PM

Yes we do 14 days incubation prior release and we also do micro analysis on that duration.

 

Seems to me you have enough controls in place you don't need to make it a CCP.  As someone else mentioned, run it through the decision tree to assess real risk.



#13 Macanraup

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Posted 27 June 2020 - 05:57 AM

Dear Expert,

 

 

Can we consider Aseptic tank or Aseptic bulk filler as CCP?  Currently our CCP is UHT.

 

Process: Pasteurization --> Blending----> UHT --> Aseptic Tank --> Aseptic Bulk Filler

 

Thanks,

 

Tony

 

Hi Tonying,

 

I would say the Aseptic Tank and Aseptic Bulk Filler are not a CCP, since the UHT has been defined as CCP and those following stages have same food safety hazards. But as someone else recommend, please run the decision tree to identify the (microbiological) risk at those stages. 






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