223 replies to this topic

[Charles.C]

Dear Moochie,

Well, IMO both the generic items you mention could potentially be the cause of a CCP, depending on the specific BCPA condition of yr input.

Maybe you should hv tried the suggestion in preceding post, perhaps followed by the "best of 3" ??

Rgds / Charles.C

[Ives]

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

I agree. It doesn't mean that HACCP plan has to have CCPs. If based on your risk analysis, hazards are managed at a very low risk to the finished products (e.i. minimized by pre-requisite/supporting programmes, then no need for a CCP.

Hope this helps.

[Carlos Leoncini]

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

[Carlos Leoncini]

Hi. Zero CCP's is not rare or imposible to me. What really calls my attention in the poll, are systems with more than 4 or also 10!!!. If I were in that haccp team, I'd rather be doing a revision. Regards.

[cosmo]

Hi. Zero CCP's is not rare or imposible to me. What really calls my attention in the poll, are systems with more than 4 or also 10!!!. If I were in that haccp team, I'd rather be doing a revision. Regards.

I have to agree that zero CCPs is not only possible, but a target. it shows either a low risk product of a very robust process.

[Charles Chew]

I have to agree that zero CCPs is not only possible, but a target. it shows either a low risk product of a very robust process.

Dear Cosmo, You have raised a totally separate issue here albeit an important one which i suggest Simon to consider separating this thread.

I agree with you that zero CCPs is a target that we should be aiming for. Given that target, how and what do we need to do before we can consider seriously reducing the existing number of CCPs in our HACCP Plan to a minimum and where possible, zero where the established FSO can remain consistently achievable. As a system becomes matured and with continous improvements effectively in place together with the introduction of new process technologies, why not?

[Simon]

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

If an important branch of discussion has been identified I encourage the creation of a new discussion topic. Now either I can do it for you or please someone go ahead and take the lead. If you would like me to do it please give me a title and an a brief introductory text I can use.

Thanks,
Simon

[GMO]

Can anyone 'fess up to >10? What process(es) are involved?

[Strait Consulting]

Of course you can have zero CCP's and you should be happy about your life being so easy. Only if the hazard is significantly controlled at a single "intervention" step must it be a CCP, otherwise have solid PRP's in place and clearly identify each step of the process where they come into play. A lot of this also goes by standard industry practice which is a point of reference for the auditors; Packaging, Distribution, and Packing Houses are some of the industries in which zero CCP's are the norm. To me, the opposite is the problem - excessive numbers of CCP's screams "Amateur".

[Charles.C]

Dear Strait Consulting,

Only if the hazard is significantly controlled at a single "intervention" step must it be a CCP, otherwise have solid PRP's in place and clearly identify each step of the process where they come into play

I assume you interpret "significantly" as per Codex.
To my understanding, a combination of process steps is equally acceptable where the result is validatable (although probably less preferred where other, equivalently effective, single step, options exist.)

Rgds / Charles.C

[Bawdy]

How can you have a HACCP program without CCPs? Its built into the very name of the system. With no CCPS, does it not then become a Quality Management System as opposed to a traditional HACCP? Semantics i know, but if i were the auditor coming to audit a HACCP program then i would expect to see CCPS.

That said, i do understand and agree with what you mean, if during your Hazard Analysis phase you have determined that there are no CCPS, which could be possible dependant upon the nature of your product, the processing methods and the intended customer usage, then it could be possible not to have any. Particularly if you have really good pre-requsite programs in place.

Just my 2 cents worth.

Paul.

[RMAV]

Indeed, it is not a HACCP program without CCPs in the most strict sense of the acronym. However, a Hazard Analysis is required, not only by most regulation, but also to prove the product is safe with the controls in place, be they CCPs or not. This is an important distinction between HACCP and a Quality Management System.

How can you have a HACCP program without CCPs? Its built into the very name of the system. With no CCPS, does it not then become a Quality Management System as opposed to a traditional HACCP? Semantics i know, but if i were the auditor coming to audit a HACCP program then i would expect to see CCPS.

That said, i do understand and agree with what you mean, if during your Hazard Analysis phase you have determined that there are no CCPS, which could be possible dependant upon the nature of your product, the processing methods and the intended customer usage, then it could be possible not to have any. Particularly if you have really good pre-requsite programs in place.

Just my 2 cents worth.

Paul.

[GMO]

Indeed, it is not a HACCP program without CCPs in the most strict sense of the acronym. However, a Hazard Analysis is required, not only by most regulation, but also to prove the product is safe with the controls in place, be they CCPs or not. This is an important distinction between HACCP and a Quality Management System.

It can be a HACCP program without CCPs, however, I disagree that this should be a target. It's one of those situations that as a rule of thumb, fewer CCPs often indicate a more controlled system and probably a 'better' hazard analysis; BUT, that does not necessarily follow that 0 is the best of all. What is 'best' is what's right for your company and for your process (which is fundamentally why I disagree with off the shelf HACCP plans.)

[Tony-C]

Can anyone 'fess up to >10? What process(es) are involved?

I have seen consultants claim there to be 200 odd CCP's in a UHT plant !

[GMO]

I have seen consultants claim there to be 200 odd CCP's in a UHT plant !

Lol! Did they get paid by the CCP?

[jose22000]

I audit some companies with 3 HACCP plans, one for the advisors (consultants) with 2 CCPs, another one for the veterinary control (5 CCPs) and finally "The HACCP plan" for auditors (without CPPs)

By the way, it's a packaging house for apples and pears....

[mellonz]

Of course there can be no CCPs in a HACCP system however it truly depends the product manufactured. My honest opinion is that no CCPs in a food manufacturing facility is quite impossible

[Mendeljev]

Lol! Did they get paid by the CCP?

I don't want to be the one who has to validate these !

[Dalways]

Zero CCP thats mean very strong pre requisite programme in place . But yes zero CCP is possible .

[Indy]

Zero CCP thats mean very strong pre requisite programme in place . But yes zero CCP is possible .

I agree with you.. its possible with zero CCP but must very strong OPRP

[HACCP Mentor]

If you have assessed your identified food safety hazards correctly and then applied the Codex CCP decision tree correctly - it is possible. Regardless if you have CCPs or not, you need to be able to justify your position. Having all of your workings and decisions documented is required for review during your 3rd party certification audit.

[Dr Susil Fernando]

Hi,

Absence of a CCP in an HACCP Plan can be seen as not utilising the Codex decision tree properly. It does not necessarily imply that the organisation is doing great with respect to managing its food safety meaning having excellent Support programs, WIs, SOPs and GMP well under control.

On the other hand, NASA wanted a "Zero Defects" program to guarantee the safety of foods. Response from the Pillsbury was to come up with a system with defined CCPs.

CPs become CCPs, specifically when the subsequent step or support program is NOT eliminating or reducing the likely occurrence of the hazards to acceptable levels.

The other concern is whether the organisation correctly identified the potential FS hazards and carried out a risk assessment.

To understand the significance of a CCP it is worthwhile looking at the original HACCP Table of Pillsbury for NASA.

Initially, HACCP reported to have consisted of three principles;
1 Identification of hazards
2 Determination of critical control points to control any hazard
3 Establishment of monitoring systems.

Can someone post the very first HACCP Table to the group? Thanks


Cheers,
Susil

[George @ Safefood 360°]

I have to agree that zero CCPs is not only possible, but a target. it shows either a low risk product of a very robust process.

Not entirely sure zero CCP's should be a target. There are either critical points in your process or not. The target is to correctly identify them if they exist. I would agree that it is desirable to have Zero CCP's but this is not the same as a target. It may just be a choice of words but important when it comes to food safety.

George

[George @ Safefood 360°]

This question for me brings up the aging weaknesses in the principles of HACCP which are now IMO overdue for revision. The issue is not HACCP so much but rather the fact that the principles are in bad need of review and development based on a decade of practitioners applying them.

IMO there is a need to underpin those areas that work well and revise those that need to be improved. Of these the most important is the development of the principles to properly incorporate risk assessment into the control plan development. For me this is the reason it can often be difficult to answer the CCP question. The HA/RA aspects of HACCP are obscurely housed in a Principle and are independent of the remaining process when it should be an intrinsic part.

But that is another days work which I really want to start a discussion on (or even a mass movement) in the new year. I will share my ideas on this after I complete an article I'm writing on the subject. But it is this community that I most value in terms of experience and open and sometimes painfully honest opinion.

When we reach a point where we debate whether a HACCP plan should or should not have CCP's we have reached a strange position.



George

[Cobus]

Hi all.

I have seen many companies operate very successful food safety management systems without CCP's.

Many people seem to forget that HACCP can only work effectively if implemented on a foundation of fully operational PRP's which should control most hazards very effectively. Doing a bit of research about the cause of most food related outbreaks will clearly show that people die because of poor practices and not because of CCP failures.

I believe that we are overcomplicating food safety and are more concerned about paperwork and passing audits than we are about making sure our PRP's are understandable (to those who actually do the work and not auditors - far too many FSMS are written for auditors and not for the actual users), practical and properly managed.

Well managed PRP's will dramatically reduce the significance of most hazards to such an extent that they will never come close to ending up in the HACCP plan.