223 replies to this topic

[JillClark]

Good afternoon all, 

 

I have looked to this forum for a lot of information and am never disappointed.  After a google search for "zero ccps in a haccp" topic was the top link.  I am wrapping up the final updates on our HACCP and we haven't identified any CCPs in our process, so am relieved to see others agree it it is possible.  The test will be in the next few months when we have our third party audit for certification.

 

Have a great weekend, 

 

Jill

[TimG]

Hey Jill, one thing to keep in mind is that the auditor will most likely take a look at your customer complaint history. Make sure that helps validate the no CCP decision. For example, if you have customer complaints for foreign material, the auditor will have a harder time buying that you don't need some type of foreign material critical control point.

[Brendan Triplett]

Hey all,

 

I have been running our HACCP in a food storage/distribution facility with 0 CCPs for quite sometime now and when the FDA came through I gave them the same argument that I usually do, which has always been acceptable.  I told them that we have a robust set of PRPs and GDPs and that we had policies in place to maintain time and temperature.  His argument was Form-438 reporting that our HACCP plan is not considered a HACCP plan unless there are CCPs in place.  The company was put on notice and we had to create CCPs in the process.  It is great that you have a good program to keep them out I am confident that without a CCP you will continue to get notice.  I process finished/packaged product and have 14.  I would reassess your plan and keep in mind that the hazards are for issues that are "reasonably likely to occur."  What you consider reasonable and what the FDA and USDA consider reasonable might not be agreeing at this point.

 

Cheers.

Edited by Brendan Triplett, 24 February 2020 - 09:54 AM.

[TimG]

Hey Brendan, did you mean the argument was on his Form-483? What did he use to back up the claim that your "HACCP plan is not considered a HACCP plan unless there are CCPs in place"? There are several risk assessment matrices out there and I'm not sure how the FDA inspector could trump those and say you need to have a CCP to be a HACCP plan.

[Hussein1965]

yes

[Timwoodbag]

Hey all,

 

I have been running our HACCP in a food storage/distribution facility with 0 CCPs for quite sometime now and when the FDA came through I gave them the same argument that I usually do, which has always been acceptable.  I told them that we have a robust set of PRPs and GDPs and that we had policies in place to maintain time and temperature.  His argument was Form-438 reporting that our HACCP plan is not considered a HACCP plan unless there are CCPs in place.  The company was put on notice and we had to create CCPs in the process.  It is great that you have a good program to keep them out I am confident that without a CCP you will continue to get notice.  I process finished/packaged product and have 14.  I would reassess your plan and keep in mind that the hazards are for issues that are "reasonably likely to occur."  What you consider reasonable and what the FDA and USDA consider reasonable might not be agreeing at this point.

 

Cheers.

 

Oh my, you went from 0 to 14 CCP's because of one audit?

[nehank]

Hey all,

 

I have been running our HACCP in a food storage/distribution facility with 0 CCPs for quite sometime now and when the FDA came through I gave them the same argument that I usually do, which has always been acceptable.  I told them that we have a robust set of PRPs and GDPs and that we had policies in place to maintain time and temperature.  His argument was Form-438 reporting that our HACCP plan is not considered a HACCP plan unless there are CCPs in place.  The company was put on notice and we had to create CCPs in the process.  It is great that you have a good program to keep them out I am confident that without a CCP you will continue to get notice.  I process finished/packaged product and have 14.  I would reassess your plan and keep in mind that the hazards are for issues that are "reasonably likely to occur."  What you consider reasonable and what the FDA and USDA consider reasonable might not be agreeing at this point.

 

Cheers.

 

Oh wow, I have recently joined an importer as QC. We do storage and distribution of some products and repackaging and distribution of some. We are fairly small company. We have all the correct measures and steps in place to reduce hazards as much as possible. I have developed a HACCP plan with 0 CCPs. As we monitor temperature twice a day and make sure it is in range. We are yet to get HACCP certified. 

 

Do you think I should get a third party auditor on board before we schedule a federal audit?

 

Thanks,

Neha. 

[Charles.C]

Is there a specific statement in the relevant FDA Regulations  to support the interpretation that a haccp plan must have > 0 CCPs ? I seem to remember that this "trap" has long been a FSIS mantra.

[FoodSafetyPlanet]

Y'all.

 

This thread is 16 years old; I think it's a good time to restart it. 

[El Molino]

We have a process for tortilla chips and yes there are no CCP's in the HACCP plan - all hazards are controlled thru an effective PRP . oPRP and GMP's

Some may think the metal detection should be a CCP however, with oPRP for foreign materials control and a metal detector  - no CCP

 

Thoughts?

[Charles.C]

We have a process for tortilla chips and yes there are no CCP's in the HACCP plan - all hazards are controlled thru an effective PRP . oPRP and GMP's

Some may think the metal detection should be a CCP however, with oPRP for foreign materials control and a metal detector  - no CCP

 

Thoughts?

 

(Sort of) Off-topic

If one prefers a non-simple FS life, think oprp. IMHO it should have never have been invented.

[Mathieu Colmant]

We have a process for tortilla chips and yes there are no CCP's in the HACCP plan - all hazards are controlled thru an effective PRP . oPRP and GMP's

Some may think the metal detection should be a CCP however, with oPRP for foreign materials control and a metal detector  - no CCP

 

Thoughts?

 

If metal detection is a step in your diagram, it should be... Or at least it will depend on the sensitivity.

From Codex Tree : Is the step designed to remove the hasard or keep it within the limit ? -> Yes, metal detection is designed to removed metal contaminated products above "2mm" -> CCP

But why would you use a MD when the detection limit is 25 mm, for example ?

 

With ISO22000 and CCP/oPRP distinction, it is still a CCP for me. MD will separate immediatelly (no delay) all (systematic control) products on "PASS" and "FAIL" categories (no "amber" category)

[zoelawton]

We are an egg packing facility and we have no CCP's :)

[Olive]

Hello,

 

Based on the new version of ISO 22000:2018 most of the control measures considered before as CCP are now categorized as oPRP.

 

Regards,

Olive

[Charles.C]

Hello,

 

Based on the new version of ISO 22000:2018 most of the control measures considered before as CCP are now categorized as oPRP.

 

Regards,

Olive

Sort of OT wrt to OP

 

Hi Olive,

 

Interesting. Had not noticed this.

 

Can you give some examples/cross-references ?

[Olive]

Hi Charles,

 

Sorry for a very late reply. Here is my example of the CCP that is now categorized as an oPRP:

Before we consider baking as CCP, but then we realize that baking temp and time is not specifically designed to kill microorganisms from the RM.

Time and temp combination is primarily designed for product conversion and to achieve the desired sensory property of the product. Fluctuations or off std. value does not mean it is potentially unsafe and the product produced is not fit for human consumption.

 

ISO 22000:2018 8.9.2.2 8.9.2.2 When critical limits at CCPs are not met, affected products shall be identified and handled as potentially unsafe products

 

Referring to this statement, plus the D-value of pathogen of concerns and the Control Measure that we are currently using, we can confidently declare that it is not a CCP.

 

Hope I was able to explain this right to you. 

 

Best regards,

Olive

[Charles.C]

Hi Charles,

 

Sorry for a very late reply. Here is my example of the CCP that is now categorized as an oPRP:

Before we consider baking as CCP, but then we realize that baking temp and time is not specifically designed to kill microorganisms from the RM.

Time and temp combination is primarily designed for product conversion and to achieve the desired sensory property of the product. Fluctuations or off std. value does not mean it is potentially unsafe and the product produced is not fit for human consumption.

 

ISO 22000:2018 8.9.2.2 8.9.2.2 When critical limits at CCPs are not met, affected products shall be identified and handled as potentially unsafe products

 

Referring to this statement, plus the D-value of pathogen of concerns and the Control Measure that we are currently using, we can confidently declare that it is not a CCP.

 

Hope I was able to explain this right to you. 

 

Best regards,

Olive

 

Hi Olive,

 

Thks comments.

 

Frankly, based on yr interpretation, I would have thought that you would have concluded that no significant FS hazard existed. So neither CCP nor oprp.

 

Based on many previous discussions here the conclusion as to CCP/oprp (or even PRP) seems ultimately to be a "matter of opinion". Some haccp users will agree with you, many will probably not. Likely also true for auditors.

 

As long as it (audit/control-wise) works for you, it's OK.

 

ISO22004 (paraphrasing) remarks that the number of CCPs relative to oprps is less important than ensuring that all significant safety hazards are acceptably controlled.

 

PS - JFI, this thread originated prior to the existence of ISO22000

[Clemkonan]

To say that a HACCP program with no CCPs is not auditable is scary. Don't look for CCPs look for control Measures that eliminate or mitigate valid hazards and that are effectively implemented. So that if you choose to call your CCPs "soft love" would the auditor refuse to do the audit?

[Brendan Triplett]

I always get a bunch of notifications from this thread.  Years later, and many audits later, we have landed on 1 CCP for time and temperature.  It is one that has been agreed upon by FDA and is only in place because of the seafood that makes its way through the facility.  Time and Temp.  Everything els continues to be controlled by PRPs and GDPs. 

 

That's the thing about food safety.  Always evolving.

 

Cheers!

[Paigepackaging]

No CCPs, absolutely! I am a practitioner in a corrugated packaging facility and our HACCP plan is reviewed like everyone else, and we do not declare a CCP. We do have robust programs in place, and I am sure that eases my pain. 

[MOHAMMED ZAMEERUDDIN]

Hi Charles,

Answer to your question is Yes. If a HACCP plan controls the risk of hazard through PRP's 100% then no need of either OPRP or CCP.

[Kelpack]

Hi Food Safety Team 

 

I have been recently audited and had findings on the HACCP Risk Assessment.  IE:

 

Temperature monitoring during storage for Refridgerated product - OPRP however when taken through the decision tree did not come up as an OPRP and rather a CCP, As the hazard identified was micro  - Indicator organism (not life threatening) and not pathogens (life threatening) 

 

Then the Risk assessment matrix and decision tree was questioned. See below for  Risk assessment matrix I am currently using.  Please advise if this is aligned with the 5.1 requirement.

 

Your assistance will be highly appreciated.

 

2nd Finding - just before the audit, during the HACCP  risk assessment review , the team decided to make cleaning and sanitising as a step in the process flow, and without consulting with the decision tree we made it an OPRP as well.  Auditor advised cleaning and sanitation step should not be included in the process flow. 

 

Please advise if this decision treee is aligned with 5.1

 

Question 1 – Is a combination of control measures able to effectively without fail eliminate or reduce the food safety hazard to an acceptable level in the factory process? NO: OPRP, Stop, proceed to next step in the process. YES: Go to question 

 

Question 2 - Is monitoring in place to enable immediate corrective action?( continuous monitoring of product)NO:OPRP.Stop ,proceed to next step in the process. Yes:Go to question 3.

 

Question 3 - Is the process capable measuring (critical limit) and controlling the significant hazard at this point? NO:OPRP.Stop ,proceed to next step in the process. Yes:Go to question 4.

 

 

Question 4 - Are the control measures specifically designed to eliminate or reduce the hazard to an acceptable level?NO:OPRP.Stop ,proceed to next step in the process. Yes:Go to question 5. 

 

Question 5 - Will the consumer be exposed to a critical food safety incident should the control measure for the significate hazard fail?NO:OPRP.Yes:CCP.

 

Await your response 

[Kelpack]

Please advise if this decision treee is aligned with 5.1

 

Question 1 – Is a combination of control measures able to effectively without fail eliminate or reduce the food safety hazard to an acceptable level in the factory process? NO: OPRP, Stop, proceed to next step in the process. YES: Go to question 

 

Question 2 - Is monitoring in place to enable immediate corrective action?( continuous monitoring of product)NO:OPRP.Stop ,proceed to next step in the process. Yes:Go to question 3.

 

Question 3 - Is the process capable measuring (critical limit) and controlling the significant hazard at this point? NO:OPRP.Stop ,proceed to next step in the process. Yes:Go to question 4.

 

 

Question 4 - Are the control measures specifically designed to eliminate or reduce the hazard to an acceptable level?NO:OPRP.Stop ,proceed to next step in the process. Yes:Go to question 5. 

 

Question 5 - Will the consumer be exposed to a critical food safety incident should the control measure for the significate hazard fail?NO:OPRP.Yes:CCP.

 

Await your response 

[MFSC]

Yes you can have no CCPs in a HACCP Plan.  If all the hazards are controlled by PRPs thus your hazards are not significant.  If all the potential hazards are reduced or prevented and then your HACCP Plan is actually a preventative control plan. 

 

In the fresh produce agricultural sector, greenhouse, field, packing houses  that provide fresh whole produce are being asked to provide a HACCP Plan.  A hazard analysis is carried out  to verify all risks have been assessed and that they are controlled.  These types of facilities have no CCPs.