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No CCPs in a Haccp Plan - Can This Be Possible?


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Poll: How many CCP's in your HACCP System? (766 member(s) have cast votes)

How many CCP's in your HACCP System?

  1. Voted 0 (Zero) (223 votes [29.07%])

    Percentage of vote: 29.07%

  2. 1-2 (309 votes [40.29%])

    Percentage of vote: 40.29%

  3. 3-4 (142 votes [18.51%])

    Percentage of vote: 18.51%

  4. 5-6 (61 votes [7.95%])

    Percentage of vote: 7.95%

  5. 7-8 (11 votes [1.43%])

    Percentage of vote: 1.43%

  6. 9-10 (7 votes [0.91%])

    Percentage of vote: 0.91%

  7. More than 10 (14 votes [1.83%])

    Percentage of vote: 1.83%

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#201 JillClark

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Posted 14 February 2020 - 08:33 PM

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



#202 TimG

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Posted 19 February 2020 - 03:33 PM

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.



#203 Brendan Triplett

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Posted 24 February 2020 - 09:45 AM

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.

Director of Operations/Vice President and SQF Practitioner in Pennsylvania
Brendan Triplett


#204 TimG

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Posted 24 February 2020 - 04:45 PM

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.



#205 Hussein1965

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Posted 11 March 2020 - 12:38 PM

yes



#206 Timwoodbag

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Posted 15 May 2020 - 06:29 PM

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?



#207 nehank

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Posted 15 May 2020 - 06:39 PM

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. 



#208 Charles.C

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Posted 16 May 2020 - 11:26 PM

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.


Kind Regards,

 

Charles.C


#209 FoodSafetyPlanet

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Posted 18 May 2020 - 09:38 AM

Y'all.

 

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






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