21 replies to this topic

[Sousa]

Hello, I've recently visited one of our suppliers to audit them and I've noticed they don't have a CCP for their pasta cooking step. They produce RTE salads and use the pasta for the salads. We cook our pasta for NRTE meals and we do have a CCP for the pasta cooking. I was looking around and checking the "Hazard Analysis and Risk-Based Preventive Controls for Human Food: Draft Guidance for Industry" I could see that there's 3 microorganism that could be present and that a lethal control is needed for these pathogens. Then I went to check our supplier's HACCP for dried pasta and I couldn't find any killing step on their side, meaning that WE need to control these hazards (which we do). They do have a COA for these pathogens, but that wouldn't be enough to discard the need of a CCP at our place right? So, my question is, do they need a CCP on their cooking step regardless of their dried pasta supplier? Thank you!

[Charles.C]

Hello,

 

I've recently visited one of our suppliers to audit them and I've noticed they don't have a CCP for their pasta cooking step. 

 

They produce RTE salads and use the pasta for the salads.

 

We cook our pasta for NRTE meals and we do have a CCP for the pasta cooking.

 

I was looking around and checking the "Hazard Analysis and Risk-Based Preventive Controls for Human Food: Draft Guidance for Industry" I could see that there's 3 microorganism that could be present and that a lethal control is needed for these pathogens.

 

Then I went to check our supplier's HACCP for dried pasta and I couldn't find any killing step on their side, meaning that WE need to control these hazards (which we do). They do have a COA for these pathogens, but that wouldn't be enough to discard the need of a CCP at our place right?

 

So, my question is, do they need a CCP on their cooking step regardless of their dried pasta supplier?

 

Thank you!

 

Hi Sousa,

 

Yr query is a little confusing.

 

Why do you cook yr pasta for NRTE meals ? (I anticipate it is labelled as RTC ?)

[Sousa]

Hello Charles,

 

Yes you're right, I ended up mixing up things a little bit.

 

We cook and have a CCP for our pasta because we store it under refrigeration for as long as 4 days before using it in meals. Also, the pasta is used as a side, like spaghetti with meat balls. It's like those quick meals you see on Walmart. So it needs to be cooked first otherwise it would be hard dry pasta.

 

My question is, do they need a CCP for their pasta?

 

Their salads are RTE.

 

PS: Yes, they're ready to cook!

Edited by Sousa, 09 April 2021 - 02:21 AM.

[Charles.C]

Hello Charles,

 

Yes you're right, I ended up mixing up things a little bit.

 

We cook and have a CCP for our pasta because we store it under refrigeration for as long as 4 days before using it in meals. Also, the pasta is used as a side, like spaghetti with meat balls. It's like those quick meals you see on Walmart. So it needs to be cooked first otherwise it would be hard dry pasta.

 

My question is, do they need a CCP for their pasta?

 

Their salads are RTE.

 

PS: Yes, they're ready to cook!

 

Hi Sousa,

 

Thks the info.

 

I am not a pasta expert but I would have predicted a CCP.  For an example -

 

 pasta salad.pdf   42.59KB   52 downloads

 

RTC - So it gets cooked twice. No effect on quality ?

[Sousa]

Thank you very much Charles!

 

The pasta is brought up to an internal temperature of 165/175 F for a short period of time. It's still very much 'al dente' when it's put into the trays. But overall, yes, it looses quality I would say. The company serves a particularly susceptible population, so our main focus is safety, not quality unfortunately.

 

Thank you very much again, I really appreciate it!!!

[danya]

I think, there is no any CCP in pasta cooking. What dangerous you intend to control by cooking? If spore-forming bacteria - temperature and duration are not enough. I think in this case PP will be enough.

Edited by danya, 09 April 2021 - 10:25 AM.

[Charles.C]

I think, there is no any CCP in pasta cooking. What dangerous you intend to control by cooking? If spore-forming bacteria - temperature and duration are not enough. I think in this case PP will be enough.

 

Hi danya,

 

See Post 1.

 

Although I suppose the Ukrainian variety might be "special" ?

[kfromNE]

Hello,

 

I've recently visited one of our suppliers to audit them and I've noticed they don't have a CCP for their pasta cooking step. 

 

They produce RTE salads and use the pasta for the salads.

 

We cook our pasta for NRTE meals and we do have a CCP for the pasta cooking.

 

I was looking around and checking the "Hazard Analysis and Risk-Based Preventive Controls for Human Food: Draft Guidance for Industry" I could see that there's 3 microorganism that could be present and that a lethal control is needed for these pathogens.

 

Then I went to check our supplier's HACCP for dried pasta and I couldn't find any killing step on their side, meaning that WE need to control these hazards (which we do). They do have a COA for these pathogens, but that wouldn't be enough to discard the need of a CCP at our place right?

 

So, my question is, do they need a CCP on their cooking step regardless of their dried pasta supplier?

 

Thank you!

Do they boil the pasta. If so - then you know the temperature is reaching 212 and killing the relevant microorganisms. A reason they might not have it as a CCP though they should.

[Sousa]

I think, there is no any CCP in pasta cooking. What dangerous you intend to control by cooking? If spore-forming bacteria - temperature and duration are not enough. I think in this case PP will be enough.

 

The microorganism/pathogens likely to occur in dry pasta are:

 

Salmonella spp.

B. cereus

S. aureus

 

Some vendors have COAs for these microorganisms, but not all of them.

 

Thank you all for your opinions and precious help!

[Charles.C]

The microorganism/pathogens likely to occur in dry pasta are:

 

Salmonella spp.

B. cereus

S. aureus

 

Some vendors have COAs for these microorganisms, but not all of them.

 

Thank you all for your opinions and precious help!

 

Actually the COA for the 1st item would presumaby be "Not detected" (by an appropriate sampling/analytical methodology).

The snag is that low levels of a pathogen in a lot have a low probability of detection with typical sampling levels.

[Sousa]

Actually the COA for the 1st item would presumaby be "Not detected" (by an appropriate sampling/analytical methodology).

The snag is that low levels of a pathogen in a lot have a low probability of detection with typical sampling levels.

 

Yes, correct! Absolutely agree, I've talked to my co-worker, in the case they present us with their supplier's COA we will say that it's not enough to ensure no pathogens are present. They still need the CCP on their end. 

[danya]

Hi danya,

 

See Post 1.

 

Although I suppose the Ukrainian variety might be "special" ?

Yes, there are some differences in microbiological criteria of cereals, pasta and other like it. Also, I am sorry, I can't understand real and significant way for Salmonella in pasta (if it contain potable water, flour and salt off course :) )

Edited by danya, 12 April 2021 - 02:30 PM.

[Charles.C]

Yes, there are some differences in microbiological criteria of cereals, pasta and other like it. Also, I am sorry, I can't understand real and significant way for Salmonella in pasta (if it contain potable water, flour and salt off course :) )

 

Hi danya,

 

Analogous problem to people getting ill from licking cake dough perhaps ?

[FSQA MKE]

Hello, I've recently visited one of our suppliers to audit them and I've noticed they don't have a CCP for their pasta cooking step. They produce RTE salads and use the pasta for the salads. We cook our pasta for NRTE meals and we do have a CCP for the pasta cooking. I was looking around and checking the "Hazard Analysis and Risk-Based Preventive Controls for Human Food: Draft Guidance for Industry" I could see that there's 3 microorganism that could be present and that a lethal control is needed for these pathogens. Then I went to check our supplier's HACCP for dried pasta and I couldn't find any killing step on their side, meaning that WE need to control these hazards (which we do). They do have a COA for these pathogens, but that wouldn't be enough to discard the need of a CCP at our place right? So, my question is, do they need a CCP on their cooking step regardless of their dried pasta supplier? Thank you!

 

Please do not rely so heavily on this guidance document. This is not a regulation and not applicable to every operation. It is possible to have an operation that has no CCPs. A lack of CCPs does not consider products unsafe. A CCP is not a requirement necessarily.

[Charles.C]

Please do not rely so heavily on this guidance document. This is not a regulation and not applicable to every operation. It is possible to have an operation that has no CCPs. A lack of CCPs does not consider products unsafe. A CCP is not a requirement necessarily.

 

Hi FSQA,

 

Sometimes the customer has to be right.

[FSQA MKE]

Charles,
Perhaps. & sometimes you've got to let the customer go.

[Sousa]

Please do not rely so heavily on this guidance document. This is not a regulation and not applicable to every operation. It is possible to have an operation that has no CCPs. A lack of CCPs does not consider products unsafe. A CCP is not a requirement necessarily.

 

[Code of Federal Regulations]



[Title 21, Volume 2]



[Revised as of April 1, 2020]



[CITE: 21CFR120]

 

 

 

 

 

The HACCP plan shall, at a minimum:

(1) List all food hazards that are reasonably likely to occur as identified in accordance with § 120.7, and that thus must be controlled for each type of product;

(2) List the critical control points for each of the identified food hazards that is reasonably likely to occur, including as appropriate:

(i) Critical control points designed to control food hazards that are reasonably likely to occur and could be introduced inside the processing plant environment; and

(ii) Critical control points designed to control food hazards introduced outside the processing plant environment, including food hazards that occur before, during, and after harvest;

 

 

If a hazard is likely to occur, isn't a CCP mandatory? Likely to occur is open to interpretation, but in some cases it's pretty obvios. Aren't CCPs mandatory in this cases?

 

Thank you

[FSQA MKE]

Sousa,
The regulation listed above ,21 CFR 120, is the juice HACCP. I'm not sure how this is relevant to pasta.
Please help me understand and correct me if I'm wrong on my reasoning below.
So you get the dry pasta from this supplier and cook it at your operation?
If so, this is my reasoning: They do not have a CCP at their site because they are relying on their supplier of the pasta to control the hazard in the pasta manufacturing process, where it gets heated up to a high temperature and gets tested for aflatoxins prior to processing, etc. I worked at a pasta manufacturing facility for a brief stint and remember the cooking step, among others being a CCP.

Thanks.

[Sousa]

The cfr above mentioned was just to show what the law says, for I prob should have copied the 117.

CCPs are not mandatory, if there's no risks at any step.

I think my initial post was a bit confusing. This has nothing to do with our company.

Let me simplify it. We receive RTE salads from another company (X).

This company cooks the pasta and adds it to other ingredients. They have 0 risks identified therefore they have 0 CCPs. We receive similar products from another company where they have a much more robust HACCP plan with at least one CCP to control the growth of likely to occur microorganisms.

Thank you

[FSQA MKE]

Sousa,

Thank you for the clarification.

More concerning than a lack of a CCP is the fact 0 risks have been identified by this supplier. 

I'm not familiar with wet salad operations, but I can think of plenty of risks of the top of my head, especially in a RTE setting.

All in all, it could be the supplier is purposely not considering any risks in their operation so they can avoid identifying & monitoring a CCP.

 

To answer your question whether the supplier needs a CCP on their cooking step, a CCP is not necessarily a requirement if a hazard can be controlled by other means, such as a pre-requisite program. However, some sort of reasoning or risk assessement has to be provided. They can't just ignore a risk and act like it doesn't exist.

 

Thanks!

[Ieatcookies]

CCP is the last step in process, where you eliminate or reduce the step to acceptable level. 

I am not pasta expert, but I can only guess. If they have a quality step at the end of the baking process, where (for example) they cut boiled pasta half and see if it is fully cooked, then cooking will not be a CCP. of course, only if they have a validation, that they can prove that the pasta when fully cooked will not have any pathogens. 

 

for example, I worked in bakeries where baking was and was not a CCP, in both instances it was fine. You can see with your eyes if the bread was baked or not. 

[Charles.C]

CCP is the last step in process, where you eliminate or reduce the step to acceptable level. 

I am not pasta expert, but I can only guess. If they have a quality step at the end of the baking process, where (for example) they cut boiled pasta half and see if it is fully cooked, then cooking will not be a CCP. of course, only if they have a validation, that they can prove that the pasta when fully cooked will not have any pathogens. 

 

for example, I worked in bakeries where baking was and was not a CCP, in both instances it was fine. You can see with your eyes if the bread was baked or not. 

 

Actually a typical definition (Codex)  of CCP is - A critical control point is defined as a step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level.

 

The "essential" can be built into the hazard analysis.

This could be one argument for having no CCP at a baking step (for "visible" reasons as you implied) however FSMA nonetheless, apparently, chooses to make baking a PC. HACCP in some other texts likely differ.  Spin a Coin.