19 replies to this topic

[Fara Dieba]

Hi. I hope someone can assist me with this topic. May I know is it possible for freezer storage not to be CCP? My company make freezer storage as one of CCP for many years but last year an auditor said our freezer storage doesn't need to be a CCP. He said mostly company doesn't make it as CCP. So, my Managing Director ask me to take out freezer storage as CCP because he doesn't want to encounter same issue in future. Can we take out the CCP just like that? Thank you in advance.

[Charles.C]

Hi . I hope someone can assist me with this topic.

 

May i know is it possible for freezer storage not to be CCP? My company make freezer storage as one of CCP for many years but last year an auditor said our freezer storage doesn't need to be a CCP. He said mostly company doesn't make it as CCP.

 

So, my Managing Director ask me to take out freezer storage as CCP because he doesn't want to encounter same issue in future. Can we take out the CCP just like that? 

 

Thank you in advance.

 

Hi Fara,

 

Yes you can remove as CCP unless perhaps yr temperatures are very poor, eg a failing installation.

 

In textbooks you can find examples to support either option but IMEX, nowadays, it not usually a CCP. And similarly for the freezing stage although this tends to be more contentious.

 

I have never set "cold room" as a CCP and never had it queried.

[Fara Dieba]

Hi Fara,

 

Yes you can remove as CCP unless perhaps yr temperatures are very poor, eg a failing installation.

 

In textbooks you can find examples to support either option but IMEX, nowadays, it not usually a CCP. And similarly for the freezing stage although this tends to be more contentious.

 

I have never set "cold room" as a CCP and never had it queried.

 

Do i need to make any document to state the reason why we want to remove it? 

[The Food Scientist]

Perform a Hazard Analysis and determine if it should be a CCP or not. It depends if it is minimizing/reducing/eliminating any potential hazards or not. YOUR process, YOUR call.

[Charles.C]

Do i need to make any document to state the reason why we want to remove it? 

 

Hi Fara,

 

As per previous post. The answer should be in yr (revised) hazard analysis.

 

Just for example, you might consider potential hazards such as (a) Physical contamination, (b) Micro.Growth. Hopefully the likelihood of such events in yr case will be Low so that the respective risk assessments (eg Likelihood x severity) >>> No significant hazard >>>> No CCP.

[tahoeskier]

You didn't mention the product?  That would help determine the need for CCP.

[Fara Dieba]

You didn't mention the product?  That would help determine the need for CCP.

 

it's frozen food (surimi based)

[Fara Dieba]

Hi Fara,

 

As per previous post. The answer should be in yr (revised) hazard analysis.

 

Just for example, you might consider potential hazards such as (a) Physical contamination, (b) Micro.Growth. Hopefully the likelihood of such events in yr case will be Low so that the respective risk assessments (eg Likelihood x severity) >>> No significant hazard >>>> No CCP.

 

I saw a few example for freezer storage for finished product (not CCP) they put no for potential hazard, the reason is not likely to occur because frozen. But for my case our company put yes because we think there might be temperature abuse(freezer breakdown/blackout in long period) so we end up make this processing step as one of the CCP.

[Koko LMQ]

If your products are already packed in the bag and also pass the cooking step which shall be CCP, from that step your product cannot be contaminated from outside pathogen, the cold room is not categorized as CCP. Consider your processes, please.

[Charles.C]

I saw a few example for freezer storage for finished product (not CCP) they put no for potential hazard, the reason is not likely to occur because frozen. But for my case our company put yes because we think there might be temperature abuse(freezer breakdown/blackout in long period) so we end up make this processing step as one of the CCP.

 

Hi Fara,

 

The answer returns to Risk assessment.

 

So is there an existing history of frequent compressor breakdowns/extended blackouts sufficient for product  core temperature to increase to, say, -15degC ?

 

PS - What type/presentation of frozen product are you processing ? eg vegetables-seafood-beef, B/F-IQF, RTE-NRTE ??

[Fara Dieba]

Hi Fara,

 

The answer returns to Risk assessment.

 

So is there an existing history of frequent compressor breakdowns/extended blackouts sufficient for product  core temperature to increase to, say, -15degC ?

 

PS - What type/presentation of frozen product are you processing ? eg vegetables-seafood-beef, B/F-IQF, RTE-NRTE ??

 

So far there is no existing history about the frequent breakdown/extended blackout. But we do not have any step to eliminate or reduced the bio hazard before the storage stage.

 

Our company make NRTE frozen food.

[Scampi]

You should absolutely write in controls and monitoring for the freezer temperatures as well as preventative maintenance of the freezer system (annual shut down and thaw, cleaning of condensate pipes etc), but your call whether or not that warrants a CCP

 

What do you think the greatest risk is and how would you minimize/eliminate it?

[Charles.C]

So far there is no existing history about the frequent breakdown/extended blackout. But we do not have any step to eliminate or reduced the bio hazard before the storage stage.

 

Our company make NRTE frozen food.

 

Hi Fara,

 

The above supports Post 5(b).

Hopefully yr GMP, Packaging, etc supports Post 5(a).

 

Maybe have a look at this model HACCP plan which is oriented to FSSC22000 -

 

https://www.ifsqn.co...ge-4#entry50651

[Fara Dieba]

If your products are already packed in the bag and also pass the cooking step which shall be CCP, from that step your product cannot be contaminated from outside pathogen, the cold room is not categorized as CCP. Consider your processes, please.

 

Hi,

My product do not have cooking step or any process that can eliminate/minimize bio hazard before storage(finished product) step.

[Charles.C]

Hi,

My product do not have cooking step or any process that can eliminate/minimize bio hazard before storage(finished product) step.

 

Hi Fara,

 

Note that the haccp risk assessment includes action of final consumer.

 

Since yr product is NRTE it presumably requires heat treatment, eg cooking ? >>>> (micro) Low Risk unless toxins involved.

 

So what raw materials are used for yr product ?

[Fara Dieba]

Hi Fara,

 

Note that the haccp risk assessment includes action of final consumer.

 

Since yr product is NRTE it presumably requires heat treatment, eg cooking ? >>>> (micro) Low Risk unless toxins involved.

 

So what raw materials are used for yr product ?

 

Hi Charles,

 

My product do not require heat treatment and it is surimi based.

[Charles.C]

Hi Charles,

 

My product do not require heat treatment and it is surimi based.

 

So Product is RTE ?.

 

Can you summarize the actual process steps, eg to explain the biohazard you refer to in Post 14 ?

 

(I still anticipate that frozen storage step no reason to be a CCP if correctly implemented).

 

One possible "test/Risk assessment" to apply at each stage of the process is to self-ask - What can additionally go wrong here? (with respect to FS) (when referenced to the consequence at the finished (typically consumed) item).

 

(For a more general example maybe try the Campden tree [= Codex Tree + 1])

[Fara Dieba]

So Product is RTE ?.

 

Can you summarize the actual process steps, eg to explain the biohazard you refer to in Post 14 ?

 

(I still anticipate that frozen storage step no reason to be a CCP if correctly implemented).

 

One possible "test/Risk assessment" to apply at each stage of the process is to self-ask - What can additionally go wrong here? (with respect to FS) (when referenced to the consequence at the finished (typically consumed) item).

 

(For a more general example maybe try the Campden tree [= Codex Tree + 1])

 

Hi Charles,

 

I'm sorry but do you mean does not require heat treatment such as cooking during our process or when it arrives customer?

 

So this is my hazard analysis for Storage .

 

Potential Hazard : Biological Hazard - Growth of undesirable microbes.

Justification : Microorganism growth and multiplying due to temperature abuse e.g undesirable conditions such as freezer breakdown or blackout in long period.

severity : 2 (can cause serious illness)

likelihood : C (could occur)

potential hazard : yes

preventive measure : - Maintenance supervisor shall carry out daily in house checking on temp. of storage freezer (≤ -18°C) to prevent serious breakdown.

-hourly checking of freezer temp. during working hours shall be done by QC

-if freezer breakdown, transfer finished product to other freezer which is afford  to support the load & to prevent the multiplying of microorganism growth.

CCP Decision Tree Questions

Q 1 : Yes . (based on preventive measure)

Q 2 : No . (Storage only can prevent microbe from multiplying not eliminating)

Q 3 :  Yes . (Lower temperatures slow down reactions and the propagation of microorganisms. Malaysia Food Act (Food Hygiene Reg. 09 – Chapter 2-Protection of Food) recommended a minimum temperature of  -18°C for frozen food.)

Q 4 : No . (because our next process step is Loading.)

CCP? : Yes

[qabrarflour@gmail.com]

Frozen foods are kept frozen to limit the growth of pathogenic organisms. They may also be kept frozen for certain physical attributes. Most pasteurization processes do not sterilize food, so the risk of the bacteria reproducing is still there. I would continue with the freezer CCP.

[Charles.C]

Frozen foods are kept frozen to limit the growth of pathogenic organisms. They may also be kept frozen for certain physical attributes. Most pasteurization processes do not sterilize food, so the risk of the bacteria reproducing is still there. I would continue with the freezer CCP.

 

^^^(red) - At approx. -18degC ?!