Is it possible to have too many CCPs?

Hi mentors. I am very new to the blogging world and as my first query ever on a blog I ask for guidance on the following:

1) Can a HACCP Auditor comment/suggest to a company that they have too many CCPs? I know auditors are there to audit the plan/system as is. Just asking!

2) For those familiar with Fish and Fishery Products Auditing in particular Tuna Purse Seiners (Brine Freezing) and Longliners  (Tunnel Freezing). Can you suggest/guide to what points within the chain (Net or Line Soaking to Discharge) true CCPs are as opposed to CPs? The reason I ask is I have seen plans with no CCPs, other with one (at Cold Store) other with more than 5 (Soaking time, "Harvesting", Brine Freezing, Dry Storage, Discharge).

3) Can the issue of  Scombrotoxin formation in related species like the Brine Frozen Tunas be controlled by CPs and SOPs noting that the product is going for further processing (canneries) since more than likely they will classify reception from the vessel as their first CCP?? Await your kind guidance. Regards and thanks in advance. Endhir

as a former auditor i can attest to the fact there are a number of companies out there that have haccp plans with excessive ccp's.  

normally because the writters of said plans did not know what they were actually doing, or thru an over-the-top caution decided to make everything a ccp.

and as an auditor i remember commenting on a number of these.

the issue of course is that it leads to a lot of extra labor, paperwork and is a training nightmare.

i always did documentation first as, thus the questions for operators, etc could be framed based on what i saw and based on way too many ccp's on a plan the downfalls were always operators that got confused and training that was never effective as it became too top heavy, thus most with excessive ccps would fail their audits - there are a bunch of other reasons but the key thing i would say is that your haccp plan needs a rewrite by someone that has been trained on seafood haccp such as that offered by the florida sea grant, would be a nice vacation as well.

Hi bzefella,

Please avoid double posting since it may cause confusion. Thks.

Have to say that I agree with Glenn on the general principle here - I'm not sure it's an auditors place to tell you how many CCPs you should have, or what they should be, but if I see a HACCP plan with an excessive number of CCPs then it calls into question the HACCP team's (and particularly the team leader's) understanding of HACCP. Or perhaps that they haven't really kept abreast of progress - I do recall there was a fad for large number of CCPs back in the 90, but one hopes that most HACCP plans have had at least one decent review since then ;) 

Yes, an auditor commenting on the number of CCPs may actually be challenging the team to present the hazard analysis / CCP determination document.

As already mentioned above, most companies tend to include everything that could be a hazard, without properly determining their applicability to their operation AND thus have excessive CCPs

Current HACCP documentation limits CCPs to be absolutely critical to food safety - if the CCPs fail, then the product's safety can no longer be assured - and will depend on your actual hazard analyses and determination.

One big reason why older hazard analyses (ca 90s) generated  so many CCPs (sometimes >10 !) was that many System Control features  such as involving  Sanitation, Raw Material Reception, etc, etc, were typically not included within Prerequisite programs (ie not PRPs). Some major developments in this respect were  formalised/presented in NACMCF's HACCP Methodology(1997).

Subsequent increased implementation of wider-scoped PRPs, along with some other conceptual changes, caused  major re-thinks in HACCP System Risk Assessment and associated Documentation. Possibly (PRP-wise) culminating much later in the ISO22002-X Series.

So No.1 in OP may  mean that the auditor was implicitly/explicitly criticizing the hazard analysis Procedure. More specific details required to comment much further.

The appearance of  ISO-HACCP(2005) added new complications to the existing  Codex/NACMCF Methodologies.

Thanks very much to all those mentors that took the time out to respond to my query. As to the double posting, my apologies.

Hopeful for responses on the Fish portion of my query.

Regards and thanks again