CCP or Operating Control
Does anyone have input on if a CCP should exist even if the Operating Control exceeds the precaution? For instance, kill step for a system is 165 degrees F for 15 min. If the material must be heated to 200 for 30 minutes to create the product, should a CCP still be documented because it is the only prevention of microbial and pathogenic presence in the manufacturing system?
I am finding more and more large customers want to see that CCP on paper, regardless that the material would not be sellable without the operating parameter. But, I have a production manager that is hesitant to document CCP's because of the attention it draws. Do we let the customers have this one? Any thoughts?
If there is a biological hazard before the kill step, its a ccp or process preventive control (FSMA).
I don't recall any exemption for your situation.
Does anyone have input on if a CCP should exist even if the Operating Control exceeds the precaution? For instance, kill step for a system is 165 degrees F for 15 min. If the material must be heated to 200 for 30 minutes to create the product, should a CCP still be documented because it is the only prevention of microbial and pathogenic presence in the manufacturing system?
I am finding more and more large customers want to see that CCP on paper, regardless that the material would not be sellable without the operating parameter. But, I have a production manager that is hesitant to document CCP's because of the attention it draws. Do we let the customers have this one? Any thoughts?
Product/Process unstated so difficult to respond.
Looks analogous to the well-known debate over whether the baking step for baked products is a CCP or not.
For baking, In the US, the existence of "kill-step" websites indicates the answer is Yes (unless perhaps the user welcomes auditorial arguments).
Thanks for your input. I pulled out my Codex to reread, I think the removal of the decision tree in 2020 has created this problem. The tree stated Q2 "Is the step specifically designed to eliminate or reduce the likely occurrence of the hazard to an acceptable level?" We run a blancher for performance, happens to be the kill step as well. But, without it the product cannot be sold, it is ruined. Therefore the step 1) wasn't created as a hazard control 2) because it is inherent to the product being valid, the hazard doesn't technically exist.
Without that one phrase in the tree, I see a risk assessment assuming a CCP acceptable on paper. Its context. But who wants to have this discussion with the customer!? We have as an OPRP of course, but they are hung up on those magical letters "C-C-P."
I'm always up for some auditorial "discussions", but not with the document administrator.
Thanks for your input. I pulled out my Codex to reread, I think the removal of the decision tree in 2020 has created this problem. The tree stated Q2 "Is the step specifically designed to eliminate or reduce the likely occurrence of the hazard to an acceptable level?" We run a blancher for performance, happens to be the kill step as well. But, without it the product cannot be sold, it is ruined. Therefore the step 1) wasn't created as a hazard control 2) because it is inherent to the product being valid, the hazard doesn't technically exist.
Without that one phrase in the tree, I see a risk assessment assuming a CCP acceptable on paper. Its context. But who wants to have this discussion with the customer!? We have as an OPRP of course, but they are hung up on those magical letters "C-C-P."
I'm always up for some auditorial "discussions", but not with the document administrator.
IMO the terminology OPRP as introduced by ISO has wasted more time via interpretive argumentation than possibly any other aspect of HACCP.
There are trees other than Codex which do not utilize your above-mentioned clause (the latter IIRC was initially introduced to facilitate designating metal detectors as CCPs).
Depends on the situation but IMEX (seafood) "blanching" is typically not an intended "kill-step". Ruined due inadequate shelf-life or ?
PS - Offhand, I think yr comments are more or less identical to the baking situation I previously noted, ie there is no significant hazard/"kill-step" since an "insufficient" T/t bake will generate a visibly useless product (= ruined ?). Nonetheless the (for example) well-known AIB website seemingly belies this argument for practical HACCP implementations. (An initial draft for ISO22000 mentioned the baking case as a possible "exception" but the related text was subsequently deleted). Opinions as to a significant hazard in numerous earlier threads here are, from memory, roughly 50/50. I believe FSMA also "expect" a CCP in baking as intimated in Post 2?
PPS - thks for having revisited several "tricky" haccp situations !