Is a sterile terminal filter at the point of compressed air entry a CCP?
Today there was a strong debate with one of my colleagues, about a point of CCP. Discussion is whether the point can be termed as CCP or not.
At a stage, we analyzed that compressed air and gas can contain pathogenic microorganism, and it may affect the in process product. In my sense, if the contamination happens, there is no established procedure of eliminating the contamination, except just throwing the product. So, we are using a sterile terminal filter at the point of compressed air entry. I decided that point should be a CCP.
Now, someone claimed that, if contamination happens, we will detect it and throw the product. So, no chance of delivering unsafe product to the consumer. So, that point will not be a CCP, rather this can be relevant to process control. However, I know that if the product is contaminated due to failure of CCP, then we have to handle it as a potentially unsafe product, and we have to take other measures.
Could anyone explain me what would be the right in this case?
A) what is the likelyhood that pathogenic bacteria would be present in the compressed air (have you tested your ambient air?)
B) what is your history of this occurring (actual pathogenic bacteria)
C) assuming there is not a kill step after this processing step
D) how did you determine that the presence of pathogenic bacteria could occur
A CCP is to be used when there are not any other control measures in place to control/reduce or eliminate a known hazard
Generally speaking these are the compressed air hazards
Particles # particles per m3 , and mass concentration in mg/m3 Intake air, compressor wear, storage system, delivery system
Water Pressure dew point ºC, and concentration of liquid water in g/m3 Intake air, compressor
Oil Concentration of total oil in mg/m3 Aerosol -compressor, vapors - intake air
A) what is the likelyhood that pathogenic bacteria would be present in the compressed air (have you tested your ambient air?)
B) what is your history of this occurring (actual pathogenic bacteria)
C) assuming there is not a kill step after this processing step
D) how did you determine that the presence of pathogenic bacteria could occur
A CCP is to be used when there are not any other control measures in place to control/reduce or eliminate a known hazard
Generally speaking these are the compressed air hazards
Particles # particles per m3 , and mass concentration in mg/m3 Intake air, compressor wear, storage system, delivery system
Water Pressure dew point ºC, and concentration of liquid water in g/m3 Intake air, compressor
Oil Concentration of total oil in mg/m3 Aerosol -compressor, vapors - intake air
Actually, we have not tested for the compressed air quality, but we are using a terminal filter. And no other steps later to eliminate the contamination like cooking, heating or pasteurization etc. I found scientific articles that compressed air may contain pathogen.
I would disagree---if you do not have IN HOUSE evidence that pathogenic bacteria in your compressed air are a real hazard, then I would side with your co worker
You've put a CCP in place based solely on articles?? What did your hazard analysis determine? You need to perform this step before even talking about a CCP
Determining if there are Critical Control Points (CCPs) in your process and establishing critical limits for these CCPs are essential steps in the development of a Preventive Control Plan (PCP) that will effectively control hazards significant for your food. They are also the second and third principles of a Hazard Analysis Critical Control Point (HACCP) system.
A CCP is a step in your process where a control measure with clear critical limit(s) is essential to control a significant hazard. Critical limits are the measurable or observable pre-set values or criteria that separate what is acceptable from what is not acceptable to achieve food safety.
I agree with you, it is to discuss whether this point does qualify as a CCP or not, based on the presence of pathogenic microbial contamination. I suggested that if we can establish air quality monitoring procedure then it will not be a CCP, rather a PRP would be enough. But actual debate is that, if there is contamination, we will detect it and just throw the product. So, this cannot be a CCP.
I would disagree---if you do not have IN HOUSE evidence that pathogenic bacteria in your compressed air are a real hazard, then I would side with your co worker
You've put a CCP in place based solely on articles?? What did your hazard analysis determine? You need to perform this step before even talking about a CCP
Determining if there are Critical Control Points (CCPs) in your process and establishing critical limits for these CCPs are essential steps in the development of a Preventive Control Plan (PCP) that will effectively control hazards significant for your food. They are also the second and third principles of a Hazard Analysis Critical Control Point (HACCP) system.
A CCP is a step in your process where a control measure with clear critical limit(s) is essential to control a significant hazard. Critical limits are the measurable or observable pre-set values or criteria that separate what is acceptable from what is not acceptable to achieve food safety.
Today there was a strong debate with one of my colleagues, about a point of CCP. Discussion is whether the point can be termed as CCP or not.
At a stage, we analyzed that compressed air and gas can contain pathogenic microorganism, and it may affect the in process product. In my sense, if the contamination happens, there is no established procedure of eliminating the contamination, except just throwing the product. So, we are using a sterile terminal filter at the point of compressed air entry. I decided that point should be a CCP.
Now, someone claimed that, if contamination happens, we will detect it and throw the product. So, no chance of delivering unsafe product to the consumer. So, that point will not be a CCP, rather this can be relevant to process control. However, I know that if the product is contaminated due to failure of CCP, then we have to handle it as a potentially unsafe product, and we have to take other measures.
Could anyone explain me what would be the right in this case?
Hi Mazid,
Re ^^(red)
The option simply reflects a lack of understanding of HACCP IMO. However a "possible" support for such a conclusion, ie CCP or nothing, in a similar (but different) situation such as in Baking has become "contentious".
Typically for HACCP -
1st requirement is to justify the existence of a significant hazard at a Process Step, ie risk assessment.
If yes, 2nd requirement is to determine if a control measure (including a "potential" CL) exists.
If yes, 3rd requirement depends on yr subsequent choice of Standard/Procedure for Categorization of a CCP.
For example -
(a) the original Codex tree will probably give you a CCP (cf Metal Detector) albeit with perhaps a contentious CL (cf Sieve?).
(b) the Campden Tree may give you a PRP or CCP depending on your "set-up".
(c) ISO-haccp may give you a PRP/CCP/OPRP.
Industrial suppliers of sterile filters IIRC used to nominate the unit/step as associated with a CCP but nowadays seem to prefer PRP. An example of one's logic is in file sh5 of this Post -
to further muddy the waters, if you are going to automatically dispose of product if you DETECT pathogens, then that is the step (the actual detection) that WOULD be the CCP
to further muddy the waters, if you are going to automatically dispose of product if you DETECT pathogens, then that is the step (the actual detection) that WOULD be the CCP
Prerequisite.
Hopefully, sometime, someone, will devise a continuous flow "pathogen" detector like a MD (also IIRC a Prerequisite in some interpretations).
Isn't HACCP wonderful ? So precise. :smile:
Hello,
You might find the information in this article useful. A few of the relevant points to your question:
-
“For compressed air, CCP’s are points in the manufacturing process wherever compressed air comes into contact with the product or could be contaminated, including point of use, valves, in-line filters, etc.”
-
“A critical limit is a maximum and/or minimum value to which a biological, chemical or physical parameter must be controlled at a CCP to prevent, eliminate or reduce to an acceptable level the occurrence of a food safety hazard. In compressed air systems, preventative measures include filter and purification equipment. The intake filter is the system’s first defense for contamination and should be replaced according to the compressor manufacturer’s guidelines.”
Hello,
You might find the information in this article useful. A few of the relevant points to your question:
“For compressed air, CCP’s are points in the manufacturing process wherever compressed air comes into contact with the product or could be contaminated, including point of use, valves, in-line filters, etc.”
“A critical limit is a maximum and/or minimum value to which a biological, chemical or physical parameter must be controlled at a CCP to prevent, eliminate or reduce to an acceptable level the occurrence of a food safety hazard. In compressed air systems, preventative measures include filter and purification equipment. The intake filter is the system’s first defense for contamination and should be replaced according to the compressor manufacturer’s guidelines.”
Hi Trace Analytics,
An, I think, different opinion is detailed in file sh5 in this post -