223 replies to this topic

[Charles Chew]

Looking at the objectives for implementing a Haccp System, is it possible to have zero CCPs in a Haccp Plan.

My answer is yes....but many would disagree with me. My logic is based on deliberately instituting intervention steps at all steps or a particular step of the process.

Feel free to comment.

Charles Chew

[Simon]

I'm sure HACCP studies of some processes, especially for example in food packaging manufacturing do not identify any CCP's and they happily assure food safety by implementing just the prerequisite systems. IMO it doesn't matter though if they have done the hazard analysis professionally.

As many packaging professionals visit SDF it will be interesting to run a poll to see how many CCP's, and what type of CCP's we have identified in our HACCP systems. Charles I will leave it till Sunday evening GMT so that the thread doesn't disappear over the weekend.

On that note have a good weekend.

Regards,
Simon

[Charles Chew]

Identification of significantly risky hazards in the packaging industry may be some what trying but there is always a likelihood particularly for those who are in the manufacturing of direct food contact materials.

Interestingly, for your information, a manufacturing facility (ISO 9K and HACCP Certified) that I know of who has been producing fish fingers for years have only ONE CCP in their entire process flow. Amazing but true.

Well, I would not be surprised at all where and when appropriate intervention steps are put in place, most packaging companies would only have to ensure strength in their verification activities......with a bit of validations of course.

Regards
Charles Chew

[Simon]

Charles asked:

Is it possible to have zero CCP's in a Haccp Plan?

An interesting question so I've added a poll, please vote and also let us know:

- the process analysed
- what the CCP's (if any) are
- why they were determined CCP's

Or if you really can't be bothered please just do the poll.

Regards,
Simon

[Charles Chew]

Too many CCPs in a process environment can only mean a couple of things,
1. Hazards are of significant risks that are severe and a likehood of occurrence or
2. Wrongful analysis of hazards or
3. Insufficient interventions steps put in place or
4. There may be other reasons

Having a number of CCPs do not mean that the system is ineffective. What it really means is that you will need to do a lot of day-to-day operations to verify that the CCPs are in control (which can be a big hassle) let alone having to deal with the food auditor when the next audit comes around.

Issue: Products with too many CCPs in a process environment tend to imply that it is a "potentially unsafe" product.

Charles Chew

[Charles Chew]

I hope we can have a higher rate of response to this Poll. Different types of hazards may exist in facilities of the same industry but the gravity of it may differ from industry to industry.

A Haccp team of a matured food safety system would have gained sufficient knowledge to deal with fine tuning of the overall system. Having 6- 7 CCPs in an initial haccp plan is not uncommon at all. Often, this will be reviewed over the years and as intervention steps are gradually put in place and supported by validations, these CCPs are not longer "valid" and can be removed.

It is not easy to remove a CCP and for those who are considering to doing so may need to proof that safety to the products is never a compromise when that CCP is removed. In your initial analysis, it would be a wise idea to reconsider whether a CCP can in fact be just a CP.

Regards
Charles Chew

[Charles Chew]

For your information, my colleagues think I am mad to even suggest that it is possible to have 0 CCP in a Haccp Program.

That was the question I confronted a very senior and world renowned food consultant. The answer was YES and we both knew the reason why. Before, any viable foodsafety management system came into our daily working life, no one ever heard about Haccp.

All that everyone knew was 'end product testing" for all finished products prior to shipment of goods delivered or worse, incubate the finsihed products in the warehouse for a period of time and observe for signs of microbial actitivies.

Haccp principles allow us a lot of freedom to do what we want to do so long as we can proof that we are IN CONTROL . No CCPs means requiring a very strong in-process-quality-control programs which would require you to perform VALIDATION ACTIVITIES at all major critical steps of the process.

It appears not to be practical but achievable to ZERO CCPs. In summary, using this approach would mean that you could be operating a beverage manufacturing facility (like OJF case) in an ALMOST similar environment as that of a "pharmaceutical GMP" status.

So, is it not better to control a couple of CCPs than having to deal with None?

Comments on the above is welcome. On the number of CCPs we should consider appropriate, the poll shows a vast range which means this topic is still wide open

Charles Chew

Edited by charleschew, 14 May 2004 - 02:05 AM.

[Charles Chew]

Interestingly, I read an article on the internet recently about a company who pursued their Haccp Program and decided they did not have any CCPs at all in their process flow.

And, amazingly too, the auditor argued that the Haccp Sytem is flawed and they are unable to audit.

Wonder if the auditor is technically correct with his point of argument if the client is able to proof that they have all the control steps in place?

Charles Chew

[Simon]

Interestingly, I read an article on the internet recently about a company who pursued their Haccp Program and decided they did not have any CCPs at all in their process flow.

Charles,

It would be good if you could put a link to the article if you can remember where you read it.

Thanks,
Simon

[Charles Chew]

Hi Guys,

Honest truth...........I really had forgotten where the hexx in the internet I read the article from. Will try to do some "IT traceability" here and see what results I can come out with.

Sorry

Charles Chew

[Franco]

No CCP's seems possible according to these guys

HACCP audit

see page 4. Rgds. Franco

[Charles.C]

Dear All/Simon,
Its a bit late (only just saw it) but I thought the topic was interesting so -

I suspect the question of number of CCPs has a long history. I am in food area and have seen many interpretations of the basic definition of CCP depending for example on yr country / particular authority / particular food type / particular consumer type / concept-politics. The last parameter is maybe the most subjective - you can choose from qualitative risk matrices, quantitative risk analyses, Codex 'trees" etc and the answers may well be different. Nonetheless I would be surprised if any processor maufacturing ready-to-eat food for babies has a zero CCP HACCP plan. In contrast I think from memory you will readily find some model plans on the IT for raw foods which conclude no CCPs.

If you look at references 10yrs+ back you will tend to see a lot of CCPs in food plans which I think were ultimately regarded as sort of embarassing in the sense of the individual processor's (and sometimes the industry ‘s) capability. Additionally complaints started coming in over the costs of monitoring items which seemed, 'most of the time', to not make very much difference to the end product (for example small scale raw meat processors were expected to have a metal detector.) As a result pressure mounted to reduce the numbers (some would call this development). A related cost comment is that one wonders how HACCP systems could have prevented disasters such as the 'mad cow' episode where, presumably, technology was inadequate (amongst other things) or the dioxin contaminations (human error ??).

One 'zigzag' (I think maybe also existing in the pdf download of previous post) which has now become popular (IMO to partly fulfill above referred demand for less CCPs) is that some of the traditional CCPs have been relocated to a so-called 'prerequisite' category so that they can escape the CCP tag (less work for auditor too!). For example the 'reception of raw materials inspection step' is now often placed in this chunk rather than the classic approach of making it a CCP, similarly all the Hygiene related parameters.
Apologise if post has slightly cynical flavour (actually I am a strong proponent of HACCP), but hopefully of interest anyway.

Best Regards
Charles.C

[Simon]

Apologise if post has slightly cynical flavour (actually I am a strong proponent of HACCP), but hopefully of interest anyway.

Yes very interesting, thanks Charles. Does it matter though, shouldn't it really be a case of quality over quantity. For example if two businesses made pork pies, using an identical manufacturing process, and I told you one had 12 CCP's and the other had 2 CCP's would it help us to determine who's pies were the safest?

Regards,
Simon

[Charles.C]

Dear Simon,

This looks suspiciously like bait for another one of your ‘missing blades' episodics.

I fully agree with (what I think was) the intent of your comment that the prioritising of the hazards/CCPs is in itself a considerable self-learning benefit of HACCP. This was my own personal objection to the de-listing of CCPs into the pre-requisites category for certain items and thereby lessening their significance.

I am no expert on pork pies so I looked up this item in 'Food Poisoning & Food Hygiene, 4th ed by Hobbs and Gilbert ( I know it's quite old) - makes 2CCPs look pretty optimistic to me, on the other hand 12 looks like overkill unless the writer knows something we don't and is unusually honest about it.

I will respectfully suggest that a perusal of the development/validation of the HACCP plans/systems is mandated. Many QCs would I think answer that yr question can only be effectively answered by a 'visit.'
By the way, how is the epidemiological record of pork pies in UK these days?

Best Regards
Charles.C

[Simon]

This looks suspiciously like bait for another one of your ‘missing blades' episodics.

It's not Charles, Mr Shittlegroover is ensconced in his condo in Florid - honest! Although I do believe he has a penchant for pork pies.

I fully agree with (what I think was) the intent of your comment that the prioritising of the hazards/CCPs is in itself a considerable self-learning benefit of HACCP. I am no expert on pork pies so I looked up this item in 'Food Poisoning & Food Hygiene, 4th ed by Hobbs and Gilbert ( I know it's quite old) - makes 2CCPs look pretty optimistic to me, on the other hand 12 looks like overkill unless the writer knows something we don't and is unusually honest about it.

Yes that was the point I was trying to make. I know nothing about pork pies either, except that when consumed in large quantities they can be bad for you which, is usually an indicator that they are quite tasty too. The figures I presented were arbitrary ones to demonstrate the point that it's the thoroughness of the HACCP development process that matters which, as you quite rightly say can only be determined by perusal, validation, visit, audit etc. Although to be honest I would eat any pork pie you care to throw at me.

By the way, how is the epidemiological record of pork pies in UK these days?

I have absolutely no idea.

Best Wishes,
Simon

[Charles Chew]

(example if two businesses made pork pies, using an identical manufacturing process, and I told you one had 12 CCP’s and the other had 2 CCP’s would it help us to determine who’s pies were the safest?)

Yes, it does. However, consumers are not supposed to know how many CCPs there are in a facility but assuming that the number of CCPs is known as per above assumption, I would certainly go for the facility that has 2 CCPs.

Why - personally, my opinion is the more CCPs there are, the more dangerous the product is.

Note - Converted XP to Win. 98 hence unable to "quote"

Regards
Charles Chew

Edited by charleschew, 11 June 2004 - 01:50 PM.

[Edwina Chicken Currie]

....my opinion is the more CCPs there are, the more dangerous the product is.

More CCP's indicate a higher risk in the process. If CCP's are managed, the product is safe.

I agree with the idea of perception of risk - people without a thorough understanding of HACCP would not realise the principles relate to risk management.
Certainly a process with only 2 CCP's would seem (upon the surface) to be an easier process to effectively manage.

[Charles Chew]

Having to manage anything more than 6 CCPs is not easy for a relatively new and inexperienced haccp team. I hope I am not being too presumtious, but unless the process has significant process risk exposures, often wrong CCP analysis occurs when the difference between quality and food safety issues are not clearly understood. But having said that if the correct intervention step is taken, a CCP can be "removed" by controlling it. Give it a thought on this one.

I know of an American Facility that has a matured Haccp Team/System with no more than 3 CCPs in a "frozen beef patties" and beef hot -dog process". And, they are certified to world class certification bodies.

Regards
Charles Chew

[Charles Chew]

Does a pork pie that is certified to HACCP considered a tasty product? Not necessary so but it does give you a sense of comfort that the facility that makes the pork pie conforms to a food safety program.

I share the same view that I would go for a pork pie that is tasty and "seems" safe to eat. I would not bother about the issue of whether it is certified to Haccp or not.

Realistically, for purpose of trade, conformity to industrial standards is just but a way of life.

By the way, HACCP is not about the number of CCPs one has in the system. Its about controlling them effectively (which is a heavy responsibility). Naturally, we always try to "beat" the system and the auditor.............


Charles Chew

[Franco]

Looking at the objectives for implementing a Haccp System, is it possible to have zero CCPs in a Haccp Plan.

Yes, according to EU Reg. 852/2004. Look at point n. 15: it seems it may occur.

[Charles Chew]

Yes - I am glad there is support of such possibility under EC Reg 852-2004. Glad to know. Thanks Franco.

Regards
Charles Chew

[dugaucher]

Yes, according to EU Reg. 852/2004. Look at point n. 15: it seems it may occur.

<{POST_SNAPBACK}>

Hi everybody,

No CCP in a HACCP plan is perfectly possible only if you prove you made an efficient hazard analysis and control all your potential hazards by the prerequisites programs. IMO, this can be done only in food retail. I have implemented a HACCP program that have been certified. We have no CCPs and the auditors were confortable with it as long as my prerequisites programs were solids. We are a fresh cut fruits & vegetables distributor. We receive, store, repack & ship.

Hope this help.

[Simon]

No CCP in a HACCP plan is perfectly possible only if you prove you made an efficient hazard analysis and control all your potential hazards by the prerequisites programs. IMO, this can be done only in food retail.

<{POST_SNAPBACK}>

There can be zero CCP's in other lower risk processes such as food packaging manufacture.

Thanks for sharing.

Regards,
Simon

[joyfranks]

Interesting point and my view from a certification body auditors point- A recent pilot audit for ISO22000 in a packaging company deemed no CCP's in the HACCP plan acceptable (providing the evidence that all risks were assessed and documented and stated as OPRP's. ) ISO22000 does require a operational pre requisite hazard plan, which needs control measure. limits and actions. Operational PRP's are a monitoring point during the process as opposed to general pre requisite systems. Is this confusing ? I think ISO22000 has the right approach and is based on planning and verification of both HACCP systems and Pre requisites

[Charles Chew]

I think ISO22000 has the right approach

Hi Joy,
Welcome to the forum. I concur with you as I find the new standard extremely prescriptive and does make a whole lot of sense. My only dissapoinment is IMO the lack of depth in the area of "traceability". Perhaps, ISO is waiting for the release of ISO/CD 22519 before integrating the details into ISO22K.

Nevetheless, I know of many companies where there are no "CCPs" however a strong Operational PRP set of programs must be in place together with internal/external validations on sanitation/cleaning including personnel hygiene is a must.

Lets hope that ISO 22k will truly become a harmonised global food safety standard.

Regards
Charles Chew