10 replies to this topic

[bmmowers]

Good Morning -  We just recently completed another SQF 8.1 Storage and Distribution Audit and all went well with the exception of some questions related to our HACCP Plan. The auditor this time around was very surprised to see that we had CCP's in our plan and I was hoping to get some opinions from the fine folks of this forum. We are primarily a distributor of dry grocery products that are received, stored, and shipped in master cases. One of the items that we do carry is a brined/creamed pickled herring (low 4's for ph). We currently list CCP's for this product for receiving, storage, and distribution. Our auditor agreed that these steps are critical to us safety handling the product, but argued that we aren't introducing or controlling any of the hazards at these steps as they are taken care of by our pre-requisite programs. He also argued that if we list them as CCP's we have to be able to scientifically prove how we manage those CCP's with testing/validation/etc. We have a receiving procedure that states that inbound herring loads must have a temperature recorder for the duration of the trip and this is checked upon receiving (along with the trailer temp setting, box temp, and we probe the cases).  If there are any temperature deviations above 40 F for more than 2 hours, we will reject the load.  This is based on the FDA Fish/Fishery Guide for controlling this type of product. When in storage, product temp is constantly kept via electronic monitoring and glycol temp monitoring. When shipping, it is only shipped to one customer and only loaded once box temp is below 40 F and a temperature recorder has been placed in the trailer.  It is loaded directly from our cooler onto the pre-chilled trailer that belongs to our customer.This has been a source of debate and confusion for some time as various auditors and state inspectors seem to have a different opinion on whether or not this product needs a HACCP plan and to what extent.  We have always erred on the safe side and kept it very detailed and kept these steps as CCP's. What do you all think?  I'm happy to take this offline through email if someone feels particularly strongly or is familiar with handling this type of product.  

[SQFconsultant]

it's a ccp for temperature.

 

your auditor is supposed to be reporter, researcher basically - and not express their own opinion or offer suggestions - it is either acceptable or not and if not then it becomes a gig that you must correct.

 

it appears however this has never occured, so i'd stick to that track.

[TimG]

I did run a FSP in a grocery distributor for about a year, and the cold chain was king. I didn't have them listed as CCP's, and did handle covering them in PRP's.

But here's the thing, It sounds to me like you did your homework/research and came to an informed conclusion based on your interpretation of HACCP guidelines. Could you remove the CCP and list that your receiving, storage, cold chain proof, PRP's, etc. negate the need for a CCP? Sure, probably. At this point why would you? You have a working system in place with an identified control point that you felt was critical and you monitor and treat it as critical if there are deviations, right?

 

So let's address "if we list them as CCP's we have to be able to scientifically prove how we manage those CCP's with testing/validation/etc":

• FDA did the science
  • ​This is based on the FDA Fish/Fishery Guide for controlling this type of product. 
• You manage it by verification the cold chain is maintained per above scientifically backed FDA/Fishery recommendations
• Testing- You have scientifically backed evidence from a trusted source that if you follow these guidelines you keep the food safe, I can't think of an auditor pushing this point too hard because it's a bit rediculous
• Validation would be a combination of your lack of customer complaints and your proven track record that your CCP is keeping the product safe

[Charles.C]

Hi bmmowers,

 

Yr query may relate to whether a Regulatory requirement (eg FDA) supercedes SQF's expectations if different. Which the former presumably does.

 

Do FDA require this specific product to be controlled as a CCP at receiving ? (I vaguely recall such minutiae as being associated with tuna/histamine ?)

 

If not, most receiving options are these days usually handled by PRPs. For (obvious) logistical reasons.

[BrianMatthews]

Have you run them though a CCP decision tree? examples can be found at the link attached.

 

https://www.fda.gov/...tion-guidelines

[Evans X.]

Greetings,

 

Why don't you consider it an OPRP ? You are actively taking control measures and monitor it, with set limits for rejection, but you don't have the control of its production conditions.

Your major concern is maintaining the agreed cold chain while the product is in your care and be able to prove it with records. If you consider it a CCP you kind of engage yourself in veryfing the product's safety by having it tested, which is not your "job" unless you have the expressed permission of the provider/customer/client. And then again if you do test it and find a problem due to bad production conditions, how do you avoid the blaming game and prove it wasn't your fault?

To my experience some things need to be kept simple and clearly defined.

I would give you a bit different answer if you were e.g. an importer who is responsible for the things he sells and would have more immediate concerns about the safety of the products he distributes.

[Charles.C]

Greetings,

 

Why don't you consider it an OPRP ? You are actively taking control measures and monitor it, with set limits for rejection, but you don't have the control of its production conditions.

Your major concern is maintaining the agreed cold chain while the product is in your care and be able to prove it with records. If you consider it a CCP you kind of engage yourself in veryfing the product's safety by having it tested, which is not your "job" unless you have the expressed permission of the provider/customer/client. And then again if you do test it and find a problem due to bad production conditions, how do you avoid the blaming game and prove it wasn't your fault?

To my experience some things need to be kept simple and clearly defined.

I would give you a bit different answer if you were e.g. an importer who is responsible for the things he sells and would have more immediate concerns about the safety of the products he distributes.

 

SQF afaik follow Codex. The latter does not use OPRPs which are an ISO malevolence.

 

(However an analogous comment could be made regarding CPs which SQF does seem determined to require despite  no mention in the SQF Code. So maybe an OPRP would be equally welcomed just as seems to have occurred for FSMA. Nonetheless "simple" might still rule it out. )

Edited by Charles.C, 30 March 2021 - 12:55 AM.
added

[Charles.C]

Have you run them though a CCP decision tree? examples can be found at the link attached.

 

https://www.fda.gov/...tion-guidelines

 

Hi Brian,

 

Yr link has "Receiving" as a PRP although the Codex-type decision tree is certainly effective at generating CCPs.

[Charles.C]

Good Morning - 

 

We just recently completed another SQF 8.1 Storage and Distribution Audit and all went well with the exception of some questions related to our HACCP Plan.  

 

The auditor this time around was very surprised to see that we had CCP's in our plan and I was hoping to get some opinions from the fine folks of this forum.  

 

We are primarily a distributor of dry grocery products that are received, stored, and shipped in master cases.   One of the items that we do carry is a brined/creamed pickled herring (low 4's for ph).   We currently list CCP's for this product for receiving, storage, and distribution.  

 

Our auditor agreed that these steps are critical to us safety handling the product, but argued that we aren't introducing or controlling any of the hazards at these steps as they are taken care of by our pre-requisite programs.   He also argued that if we list them as CCP's we have to be able to scientifically prove how we manage those CCP's with testing/validation/etc.  

 

We have a receiving procedure that states that inbound herring loads must have a temperature recorder for the duration of the trip and this is checked upon receiving (along with the trailer temp setting, box temp, and we probe the cases).  If there are any temperature deviations above 40 F for more than 2 hours, we will reject the load.  This is based on the FDA Fish/Fishery Guide for controlling this type of product. 

 

When in storage, product temp is constantly kept via electronic monitoring and glycol temp monitoring.  

 

When shipping, it is only shipped to one customer and only loaded once box temp is below 40 F and a temperature recorder has been placed in the trailer.  It is loaded directly from our cooler onto the pre-chilled trailer that belongs to our customer.

 

This has been a source of debate and confusion for some time as various auditors and state inspectors seem to have a different opinion on whether or not this product needs a HACCP plan and to what extent.  We have always erred on the safe side and kept it very detailed and kept these steps as CCP's.  

 

What do you all think?  I'm happy to take this offline through email if someone feels particularly strongly or is familiar with handling this type of product.  

 

Hi bmmowers,

 

After a quick look at FDA Fishery manual, I deduce the debate is related to C.botulinum.

The manual (ch 13) specifies "instances" where control of temperature (storage etc), should be associated with a CCP.

 

Does yr product meet the specific situations/criteria given in FDA manual for a CCP ? If so, FDA's text presumably provides the theoretical Validation for selecting a (Regulatory?) CCP/Critical Limit.

 

PS - I presume FDA also have jurisdiction over storage/distribution of this product ?

 

PPS - it is preferred to discuss the topic in the Forum.

Edited by Charles.C, 29 March 2021 - 05:00 PM.
edited

[bmmowers]

Hi Charles - 

 

When we initially developed the HACCP plan we have now, we did rely on guidance from the FDA Guide.  We rely on the time/temperature data found in the tables there related to this product as our validation that the processes and limits we have selected for our CCP's are appropriate.

 

From people's comments (and my own sense), if we call these out as CCP's and treat them as such, it may be overkill, but if we are able to point to scientific data found in the Fish/Fishery Guide (like you mentioned) that we have some of the "heavy lifting" done in terms of research and validation.  

 

FDA does have jurisdiction over this product, so whether or not we use SQF or another standard in the future, I'd rather err on the safe side and commit to doing this the right way.

 

Thank you for the reply and research, and as to the discussion -  I'm glad to have this forum as a resource and keeping it here so that others may benefit!

 

 

 

 

Hi bmmowers,

 

After a quick look at FDA Fishery manual, I deduce the debate is related to C.botulinum.

The manual (ch 13) specifies "instances" where control of temperature (storage etc), should be associated with a CCP.

 

Does yr product meet the specific situations/criteria given in FDA manual for a CCP ? If so, FDA's text presumably provides the theoretical Validation for selecting a (Regulatory?) CCP/Critical Limit.

 

PS - I presume FDA also have jurisdiction over storage/distribution of this product ?

 

PPS - it is preferred to discuss the topic in the Forum.

[Hoosiersmoker]

It looks like you can leave it as is (CCP) and reference FDA requirements and tables as the scientific evidence. If the FDA gives times and temperatures they are based on science, maybe pull the references directly from the manual also. I assume your equipment is calibrated as you didn't state a non-conformance for calibration?