Knife Tips - PRP, CP or CCP

According to our IFS auditor the check for missing / broken knife tips is a CCP, though we do not use a metal detector. Instead we use a manual knife register, a CP based on our PRP's according to our interpretation.

I may be overly generalizing, but since a CCP must be "measured" and not "observed", how can it be a CCP? And second, what on earth would be my critical limit?

How is your register set-up? Is there a section for 100% accountability on old / worn out / or damaged blade? 

It is just a daily list of all knifes and their condition. Problem being, of course, if a blade-tip snaps off inside the product then detecting this at the end of the day is very late for it being a CCP.

Understood. Recently I have shifted from replacing blades to buying 100% metal folding knives like a pocket knife. I have yet to have a blade break or come up missing, usually the blade will dull out prior to anything else happening. If you are having blades break easily maybe look into another type of knife, or increase your inspections of knives more throughout the day? 

The knifes simply never break, at least this has never happened before the knife was due replacement anyway. The issue is our IFS auditor considers this a CCP but I am struggling with what my critical limits are.

The knifes simply never break, at least this has never happened before the knife was due replacement anyway. The issue is our IFS auditor considers this a CCP but I am struggling with what my critical limits are.

Yr auditor may be confused over haccp.

Product/Process is unknown.

afaik IFS is based on Codex haccp.

A possible CCP is metal inclusion.

Codex haccp (2020) allows a critical limit to be measurable or observable. However I note that ifs (following iso22000 ?)  has "Control measures, other than CCPs, shall be monitored, recorded and controlled by measurable or observable criteria". If a measurable criterion is necessary, can set the (visual) critical limit > 0.0 mm :smile:

Details of the handling of above CCP (if it exists) are usefully detailed in Pgs 385-393 of enclosed document.

SeafoodHazardsGuide-Fish-and-Fishery-Products-Hazards-and-Controls-Guidance-Fourth-Edition-August2019.pdf   4.12MB   19 downloads

(esp pgs 386, 391 et seq)

PS - Also note that various modern CCP decision trees typically start with the question - Can a  PRP handle this hazard ? Assuming Yes,  then define routine control/inspection of the condition of knives as a PRP.