7 replies to this topic

[Patricia326]

So I'm writing a HACCP Plan for herbs and spices. We purchase spices, blend and package them  This isn't my forte since we are a coffee roaster. For CCPs I'm thinking to select foreign material (although the control would only be visual inspection; we don't have a metal detector) and supplier CoAs (all of our suppliers do micro testing).  In your opinion is this acceptable?  No allergens at our site.

[olenazh]

I don't think visual inspection for foreign materials is CCP, just a QC check. You have to assess your processes to determine your CCPs, if any, OPRPs, etc.

[FSQA MKE]

If you're just repacking, it may be possible you have no CCPs.

As olenazh stated above, this is more of a pre-requisite program. In order to deem a step a CCP, it must be measurable like temperature, pH, etc.

You are still responsible for documenting these checks.

A visual inspection is suitable for this operation, yes.

[Charles.C]

So I'm writing a HACCP Plan for herbs and spices.  We purchase spices, blend and package them  This isn't my forte since we are a coffee roaster.  For CCPs I'm thinking to select foreign material (although the control would only be visual inspection; we don't have a metal detector) and supplier CoAs (all of our suppliers do micro testing).  In your opinion is this acceptable?  No allergens at our site.

 

Hi Patricia,

 

^^^(red) - acceptable to whom ?, eg is there an audit Standard involved ?

[emcdonald]

You might not have any CCPs, or you may, depending on your specific process, but there is no need to implement them just to have them.  You have to conduct a process hazard analysis and raw material hazard analysis to determine which are needed.

 

Supplier COAs will not be a CCP, as this is not a process step.  Also, if you can't control metal hazards through other means, you may need a metal detector. Not having one already is not a reason for it not to be a CCP.  I'm also not sure how you'd visually inspect for foreign materials in a spice blend... this would not work as a CCP since you can't visually inspect 100% of the product... you'd only be able to see large/obvious foreign materials that don't blend in color-wise with the spices and if they're visible on the surface of the product (i.e. not buried within a pile of spices).

 

We have a dry blending operation and our only CCP is a screen on top of the blender that we check before and after blending, to control for foreign materials. The screen size (#4 mesh) is based on FDA foreign material limits.  We have foreign material controls built throughout our process/pre-requisite programs, including inspecting our equipment before and after blending to ensure metal fragments aren't introduced from the equipment during blending.  Therefore, we determined through our risk assessment that metal detection wasn't necessary. 

 

Hope this is helpful. It's hard to say what would be necessary as a CCP without having knowledge of your specific processes, products, and raw materials.

[Charles.C]

You might not have any CCPs, or you may, depending on your specific process, but there is no need to implement them just to have them.  You have to conduct a process hazard analysis and raw material hazard analysis to determine which are needed.

 

Supplier COAs will not be a CCP, as this is not a process step.  Also, if you can't control metal hazards through other means, you may need a metal detector. Not having one already is not a reason for it not to be a CCP.  I'm also not sure how you'd visually inspect for foreign materials in a spice blend... this would not work as a CCP since you can't visually inspect 100% of the product... you'd only be able to see large/obvious foreign materials that don't blend in color-wise with the spices and if they're visible on the surface of the product (i.e. not buried within a pile of spices).

 

We have a dry blending operation and our only CCP is a screen on top of the blender that we check before and after blending, to control for foreign materials. The screen size (#4 mesh) is based on FDA foreign material limits.  We have foreign material controls built throughout our process/pre-requisite programs, including inspecting our equipment before and after blending to ensure metal fragments aren't introduced from the equipment during blending.  Therefore, we determined through our risk assessment that metal detection wasn't necessary. 

 

Hope this is helpful. It's hard to say what would be necessary as a CCP without having knowledge of your specific processes, products, and raw materials.

 

Hi emcdonald,

 

Thks for input.

 

Sieving has always been a haccp contest between CCP/PRP. Sometimes the context favours one over the other.

 

^^^(red) - Really ? Perhaps a phantom CCP.

 

Some texts suggest that if a sieve is considered to be a CCP, the critical limit is that the sieve must be visually undamaged, ie working correctly. It's subjective of course.

[emcdonald]

Hi emcdonald,

 

Thks for input.

 

Sieving has always been a haccp contest between CCP/PRP. Sometimes the context favours one over the other.

 

^^^(red) - Really ? Perhaps a phantom CCP.

 

Some texts suggest that if a sieve is considered to be a CCP, the critical limit is that the sieve must be visually undamaged, ie working correctly. It's subjective of course.

Charles, What I meant, where you highlighted red, is the original poster can't determine that metal detection will not be a CCP simply because they don't own a metal detector already.  If metal fragments is identified as a hazard that could only be adequately controlled via metal detection, then the company would have to install a metal detector.

 

Regarding the screen, the critical limit has to be measurable, so for ours it's the mesh size of the screen.  Checking that the screen is visually undamaged and working correctly is the monitoring portion. At least that's how ours is set up.

[Charles.C]

Charles, What I meant, where you highlighted red, is the original poster can't determine that metal detection will not be a CCP simply because they don't own a metal detector already.  If metal fragments is identified as a hazard that could only be adequately controlled via metal detection, then the company would have to install a metal detector.

 

Regarding the screen, the critical limit has to be measurable, so for ours it's the mesh size of the screen.  Checking that the screen is visually undamaged and working correctly is the monitoring portion. At least that's how ours is set up.

 

Hi emcdonald,

 

^^^ (blue/red) Various spice options seem to be available  -

 

 Spice Cleaning Equipment.pdf   66.57KB   64 downloads

 

JFI here is a more generic decision tree for requiring/avoiding a metal detector

 

 metal detection tree.pdf   216.15KB   60 downloads

 

Some Kraft viewpoints regarding the haccp handling of extraneous materials are attached below. The interpretations of some aspects may be subjective.

 

 Handling of Extraneous Materials as PRP- CCP.pdf   173.35KB   63 downloads

 Handling of Extraneous Material by Metal Detector-X-Ray as CCP.pdf   426.98KB   48 downloads

 Handling of Extraneous Material by Filter-Sieve as CCP.pdf   350.66KB   63 downloads