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Bakery HACCP Hazard Analysis and CCPs

HACCP SQF CCP Hazard Analysis Bakery

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jdeangelis2898

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Posted 27 May 2022 - 03:15 PM

I have been working at a bakery manufacturer for about 5 month now and we just passed our SQF audit! Points were primarily lost because our only CCP is for our metal detectors. The auditor stated that baking didn't need to be a CCP but did at least need to be a Preventive Control with monitoring. I was under the impression that those were the same thing, one for a Food Safety Plan and one for a HACCP plan. The owners do not want to add a CCP so I am trying to find alternative ways to add in monitoring without creating a CCP that will also be acceptable for corrective actions.

 

Additionally, I am reviewing our Hazard analysis and I am trying to figure out how much I can combine in one category. For example, can I have 'Receive liquid ingredients' and under that include oil, juice, flavorings, etc. even though they all have slightly different microbiological concerns? Can i just list all hazards combined into one or do I need to separate it out?

 

I hope that makes sense. Thank you in advanced for your help!



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Posted 27 May 2022 - 03:46 PM

I have been working at a bakery manufacturer for about 5 month now and we just passed our SQF audit! Points were primarily lost because our only CCP is for our metal detectors. The auditor stated that baking didn't need to be a CCP but did at least need to be a Preventive Control with monitoring. I was under the impression that those were the same thing, one for a Food Safety Plan and one for a HACCP plan. The owners do not want to add a CCP so I am trying to find alternative ways to add in monitoring without creating a CCP that will also be acceptable for corrective actions.

 

Additionally, I am reviewing our Hazard analysis and I am trying to figure out how much I can combine in one category. For example, can I have 'Receive liquid ingredients' and under that include oil, juice, flavorings, etc. even though they all have slightly different microbiological concerns? Can i just list all hazards combined into one or do I need to separate it out?

 

I hope that makes sense. Thank you in advanced for your help!

 

Preventative control and CCP. A CCP is a preventative control but not all preventative controls are ccps. Think of a preventative control as a SOP. Weights for example. Most people don't have product weight as a ccp but it is documented and monitored.

 

For receiving liquids - you can put them into one category if you are including all the hazards and controlling the hazards is the same.



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jdeangelis2898

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Posted 27 May 2022 - 03:59 PM

Preventative control and CCP. A CCP is a preventative control but not all preventative controls are ccps. Think of a preventative control as a SOP. Weights for example. Most people don't have product weight as a ccp but it is documented and monitored.

 

For receiving liquids - you can put them into one category if you are including all the hazards and controlling the hazards is the same.

Thank you, that clears up a lot for me. What would then give the distinction of a CCP over a preventive control. Is it the severity of the repercussion if the process control was not in place?



Bansal

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Posted 27 May 2022 - 04:30 PM

I have been working at a bakery manufacturer for about 5 month now and we just passed our SQF audit! Points were primarily lost because our only CCP is for our metal detectors. The auditor stated that baking didn't need to be a CCP but did at least need to be a Preventive Control with monitoring. I was under the impression that those were the same thing, one for a Food Safety Plan and one for a HACCP plan. The owners do not want to add a CCP so I am trying to find alternative ways to add in monitoring without creating a CCP that will also be acceptable for corrective actions.
 
Additionally, I am reviewing our Hazard analysis and I am trying to figure out how much I can combine in one category. For example, can I have 'Receive liquid ingredients' and under that include oil, juice, flavorings, etc. even though they all have slightly different microbiological concerns? Can i just list all hazards combined into one or do I need to separate it out?
 
I hope that makes sense. Thank you in advanced for your help!


Hi jdeangelis2898, Yes you should have temperature as preventive control- we are a bakery too and we document temperature of oven every our and time & temperature of product (every rack- top, middle bottom) to make sure that product coming out of oven has cooked to particular temperature for specific time.

Yes , you can combine all the liquids in one group- as in hazard analysis we consider all types of microbes in associated risk.

Thanks


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Scampi

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Posted 27 May 2022 - 04:45 PM

A critical control point is a hazard that CANNOT BE CONTROLED TO ACCEPTABLE LEVELS

 

So your hazard analysis must have said that foreign material could not be adequately controlled upstream, so you've added the additional step who'd sole function is to control that hazard

 

Also note: your CCP should be VALIDATED and have written deviation steps should the CCP fail

 

A process control would be bake time/temp as either the baked good isn't saleable because it's raw/under cooked and visually noticeable OR is burnt for the opposite reason so you don't have the same risk at this step as there are other controls in place


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jdeangelis2898

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Posted 27 May 2022 - 04:59 PM

A critical control point is a hazard that CANNOT BE CONTROLED TO ACCEPTABLE LEVELS

 

So your hazard analysis must have said that foreign material could not be adequately controlled upstream, so you've added the additional step who'd sole function is to control that hazard

 

Also note: your CCP should be VALIDATED and have written deviation steps should the CCP fail

 

A process control would be bake time/temp as either the baked good isn't saleable because it's raw/under cooked and visually noticeable OR is burnt for the opposite reason so you don't have the same risk at this step as there are other controls in place

Great, thank you!
 



Charles.C

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Posted 28 May 2022 - 03:23 AM

Great, thank you!
 

 

Some rather questionable  statements in this thread. I suggest to consult terminologies and definitions in Codex HACCP or your (unstated) auditorial Standard.

 

Regarding OP, the (HACCP) decision as to whether the baking step is a CCP or not can be (afaik) acceptably argued either way (see numerous threads on this Forum) unless its haccp status is pre-defined by the (unstated) Standard.


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AJL

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Posted 28 May 2022 - 07:54 PM

Havent read it thoroughly, and I know all standards have different names, but we called baking a QCP (quality control point).
Because yes it is something that needs monitoring in a way (think product quality but also formation of acrylamide).
Hope that helps ;)



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Posted 29 May 2022 - 01:49 AM

Havent read it thoroughly, and I know all standards have different names, but we called baking a QCP (quality control point).
Because yes it is something that needs monitoring in a way (think product quality but also formation of acrylamide).
Hope that helps ;)

Hi AJL,

 

Ahhh QCP ! :smile:

 

This is a multi-multi-flavoured acronym. Can mean, inter alia, quality control point, quality critical point, quality control plan. Each of these 3 items can itself have a variety of definitions/interpretations depending on the particular source.

 

For example this 2017 thread -

 

https://www.ifsqn.co...as/#entry112989

 

Here is some background (these are relatively old examples)-

 

Attached File  QCP-1.png   296.41KB   0 downloads

(Book - Application of HACCP for Distribution System Protection)

Attached File  QCP-2.png   143.5KB   0 downloads

(https://www.food-saf...ts-camera-haccp)

 

Then again, can compare -

 

Attached File  QCP-3.PNG   24.68KB   0 downloads

https://www.riskedge...k-like-a-coder/

Attached File  QCP-4.png   199.03KB   0 downloads

https://www.scienced...956713597000789


Kind Regards,

 

Charles.C


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Posted 29 May 2022 - 03:09 AM

Hmmm, all very interesting.

We've had 17 clients that were bakeries, each are SQF certified and each has their metal detectors as their CCP.

Have never had an SQF Auditor do this.

Scratching me head!


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jdeangelis2898

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Posted 31 May 2022 - 05:03 PM

Hmmm, all very interesting.

We've had 17 clients that were bakeries, each are SQF certified and each has their metal detectors as their CCP.

Have never had an SQF Auditor do this.

Scratching me head!

They have had this HACCP plan for years and had a consultant help to build it. They never had an issue in the past but now we must put something in place for corrective actions. I believe the issue was that there were no monitoring systems in place for baking (i.e. time/temp controls) because if the item isn't baked, its not a viable product and therefor did not need a monitoring step. We are trying to find the least expensive and least time consuming way to monitor everything while still being compliant.



AJL

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Posted 31 May 2022 - 05:08 PM

Our monitoring is based on:calibration of the oven temp gauge.... And that a sign off that the correct time and temperature was chosen. Easy as all of our times and temperarures are programmed in the oven. You should be able to get away with it. Verified by sensory analysis, lack of complaints and yearly test for acrylamide.
Give it a try. It is def not CCP, because there is no safety hazard. More a quality hazard (hence the QCP, quality control point).


Edited by AJL, 31 May 2022 - 05:09 PM.


Charles.C

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Posted 31 May 2022 - 06:54 PM

Our monitoring is based on:calibration of the oven temp gauge.... And that a sign off that the correct time and temperature was chosen. Easy as all of our times and temperarures are programmed in the oven. You should be able to get away with it. Verified by sensory analysis, lack of complaints and yearly test for acrylamide.
Give it a try. It is def not CCP, because there is no safety hazard. More a quality hazard (hence the QCP, quality control point).

The (relevant) safety hazard is microbial pathogens/Salmonella/B.cereus (et al).

 

Try -

 

https://www.aibinter...tep-validation/


Kind Regards,

 

Charles.C


AJL

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Posted 31 May 2022 - 07:25 PM

Hi Charles thank you!!!
What I meant to say actually is that the safety hazard (microbiological) should be removed by the high temperature and time of the baking process.

Yes Charles is right, that you should ensure that the inner temperature comes above the time And temperature required to reduce/remove the hazard of salmonella and E.coli. We actually didn't end up doing this, because completely honestly out oven rotates and I couldn't quite work out how to get my hands on a suitable logger.


Bacillus is relevant but often has to be controlled by supplier management because it needs a temperature of 121 if I remember correctly to kill bacillus?
It is likely that you won't have a decent reduction of bacillus, as although the oven air temperature is high, that doesn't mean the product reaches that temperature at the core.
When we sold egg powder to bakeries they requested egg powder with <50cfu/g.
It was also fascinating for me learning recently about the flora of flour!
Definitely a raw product. !!
Thanks for letting me follow the thread and add my 2 cents worth, it's definitely an interesting topic.
(I am new to the baking world)


Edited by AJL, 31 May 2022 - 07:29 PM.


Charles.C

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Posted 31 May 2022 - 07:30 PM

Yes Charles is right, that you should ensure that the inner temperature comes above the time And temperature for salmonella and E.coli.
Bacillus is relevant but often has to be controlled by supplier management because it needs a temperature of 121 if I remember correctly to kill bacillus?
It is likely that you won't have a decent reduction of bacillus.
When we sold egg powder to bakeries they requested egg powder with <50cfu/g.
It was fascinating for me learning recently as well about the flora of flour!
Definitely a raw product. !!
Thanks for letting me follow the thread and add my 2 cents worth, it's definitely an interesting topic.
(I am new to the baking world)

B.cereus is a potential problem due it produces spores. Initial control is typically via limits on raw materials, eg flour.


Kind Regards,

 

Charles.C


AJL

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Posted 01 June 2022 - 04:46 AM

Yes exactly right. It can also be in high numbers in egg powder. We had anywhere from <10 all the way up to the 1000s.
I think it's from the processing, dust on the shells etc.



jfrey123

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Posted 01 June 2022 - 07:12 PM

I just completed a PCQI course through FSPCA, and the use of preventative control versus CCP was an interesting section for me (as my HACCP training was nearly a decade ago).

 

Here's an example from FSPCA about performing a hazard analysis to identify where the need for a preventative control/CCP/etc is required.

 

Microsoft Word - FSPCA Ap2 Worksheets _V1.2 (iit.edu)

 

I haven't worked in a baking plant, but from my layman's perspective I can see where an auditor might believe a cooking step should be a CCP for pathogen controls (depending on ingredient composition).  They might have believed you have a pathogen hazard from your ingredients that needs a validated kill step, which would make your cook the CCP step.  Within your hazard analysis, if you can justify no risk exists from product not hitting your desired temperature, then no CCP would exist.

 

OP mentioned in post 11 that undercooked product cannot be sold, ergo no monitoring required.  That in itself describes a monitoring step:  you're checking that the product has fully baked and is ready for sale.  Documentation of that evaluation after your cook could be the answer you're seeking.



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Posted 01 June 2022 - 07:39 PM

As I have always worked in historically FSEP/CFIA controlled facilities, I'm shocked how far behind some other locations are when it comes to food safety. The FSEP program has now gone away due to our new SFCR, however, I have always had a control in place for every single step in our process, my hazard analysis for even the simplest process is always many pages long---if I do not have a pre requisite program in place that can control a hazard (which in the very name is a process control), then and only then is a CCP required

 

There are some resources here: bakery specific

https://www.aibinter....com/resources/


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Charles.C

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Posted 01 June 2022 - 08:58 PM

JFI - There are numerous examples of baking haccp plans on this Forum though mostly not recent. The one attached below was published as a model example of Codex haccp ca 2012 and afaik is the longest hazard analysis on this Forum.

 

Attached File  haccp plan - cheesecake.pdf   1.18MB   34 downloads

(3 of the CCPs given would probably be PRPs nowadays and might even have been designated as such at that time)

 

 

The longest discussion of various theoretical aspects of the baking process on this Forum is possibly the 1st sublink in below linked post. The latter post also contains an interesting series of self-instructional pdfs on a haccp analysis of making gateaux cakes.

 

https://www.ifsqn.co...cts/#entry63600

(Sadly some of the URLs referred are long gone although possibly recoverable from my archives if any of specific interest)


Kind Regards,

 

Charles.C


Jeffrey Ort

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Posted 02 June 2022 - 07:41 PM

Have you considered the finished product temperature, coming out of the oven as a Preventive Control, to ensure a proper "kill step" for possible pathogens has been achieved?

This would need to include oven temperature validation for cold spots and use the cold spot location for the temperature verification location. 



AJL

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Posted 02 June 2022 - 08:15 PM

We have this rotating oven, and I am really interested in logging product temp vs time. But I can't work out which loggers I can use, it has to either be one that can go into the oven or possibly a button one.
Anyone has a recommendation? Prefer an answer from the EU if I am going to buy one ;)
Or can I just measure the internal temperature when it comes out of the oven?


Edited by AJL, 02 June 2022 - 08:16 PM.


Charles.C

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Posted 03 June 2022 - 06:46 AM

We have this rotating oven, and I am really interested in logging product temp vs time. But I can't work out which loggers I can use, it has to either be one that can go into the oven or possibly a button one.
Anyone has a recommendation? Prefer an answer from the EU if I am going to buy one ;)
Or can I just measure the internal temperature when it comes out of the oven?

Hi AJL,

 

I don't quite understand yr problem although my experience is with validation studies on horizontal cooking lines.

 

The purpose of the probes afaik is to (a) enable an assessment of the internal temperature uniformity with time/location and (b) validate that the desired microbial reduction is (minimally) achieved at the "coolest" location (assuming uniform size product).

 

Capability to use the exit internal temperature depends on the T/t profile/actual results, (eg see the theory/discussion(s) in my link of Post 13) .

 

The minimum (safety) requirement is to demonstrate that the coolest sample receives a lethality sufficient to produce the required xD for yr designated target microbial species and gives a satisfactory product quality.

 

Does the software output overall lethality data ?

 

The oven temperature is also usable as a routine control if calibratable.

 

I anticipate the oven supplier is also a source of typical operational data such as above.


Kind Regards,

 

Charles.C


AJL

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Posted 03 June 2022 - 08:13 AM

My problem is that the only logger we have can't go in the oven. It cant handle the temperature.
So I am looking for either
- a button style logger that can go in the biscuit
- a logger that can handle going IN the oven.
Make sense?
Otherwise I cannot log the thermal profile.

:)


Edited by AJL, 03 June 2022 - 08:14 AM.


jkoratich712

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Posted 03 June 2022 - 10:07 AM

My problem is that the only logger we have can't go in the oven. It cant handle the temperature.
So I am looking for either
- a button style logger that can go in the biscuit
- a logger that can handle going IN the oven.
Make sense?
Otherwise I cannot log the thermal profile.

:)

 

We use the Reading Thermal Scorpion Profiling System to conduct our oven validations. We have a horizontal oven, but the whole device goes in the oven with probes going into the product. You do have to let it cool between runs, or you can overheat it. There are also other sensors that you can get for it to measure other things like humidity and air velocity.



Charles.C

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Posted 03 June 2022 - 11:29 AM

My problem is that the only logger we have can't go in the oven. It cant handle the temperature.
So I am looking for either
- a button style logger that can go in the biscuit
- a logger that can handle going IN the oven.
Make sense?
Otherwise I cannot log the thermal profile.

:)

See this post/thread -

 

https://www.ifsqn.co...on/#entry185566

 

I think there are other miniature wireless brands also.


Kind Regards,

 

Charles.C






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