8 replies to this topic

[Hongyun]

Hi guys,

My supervisor and I went to a 2 days HACCP course provided by the CIEH (Chartered Institute of Enviromental Health) and it is a requirement to produce an assignment to "pass"... Unfortunately, I've picked up the topic: Sliced Fish Noodles... So, after 2 weeks of making up a bogus process, management, and records, I've finished the project.

But, I thought maybe I should ask you HACCP gurus for comments before I pass it up, just in case i missed out one major step or something...

See attached. Comments needed!
 HACCP_doc.pdf   111.01KB   611 downloads

[Simon]

Hi guys,
My supervisor and I went to a 2 days HACCP course provided by the CIEH (Chartered Institute of Enviromental Health) and it is a requirement to produce an assignment to "pass"... Unfortunately, I've picked up the topic: Sliced Fish Noodles... So, after 2 weeks of making up a bogus process, management, and records, I've finished the project.

But, I thought maybe I should ask you HACCP gurus for comments before I pass it up, just in case i missed out one major step or something...

See attached. Comments needed!
 HACCP_doc.pdf   111.01KB   611 downloads

Tremedous job Honeygun. Very comprehensive, I cannot suggest any alterations. I'm sure you will pass with distinction. When you do remember to tell us.

Regards,
Simon

[MartLgn]

Nice work Hongyun, you didn't miss anything

I haven't seen a HACCP study before with the CCP's listed on a seperate page but there's nothing in Codex that says you can't. I was very interested in your review at the end and your conclusions on the value of HACCP and its place in an organisation.

Best of luck but Im sure based on this you won't need it

[Charles.C]

Dear Hongyun,
Interesting and detailed presentation. Also pretty brave if you are not a regular seafood operative. I liked the format very much + the summary.
I noted that you present a rather narrow range of microbiological species which are normally considered to represent a significant hazard for typical seafood. Perhaps you had already done an elimination process here ?
Would be interested to know how the Ls and Ms combined for the SIG. column if this is not copyright. I use a similar method and I find the degree of subjectivity (imagination) required in the obtaining of these parameters is occasionally enough to produce a headache.
Did find it a bit surprising that you considered that all the hazards which ultimately led to CCPs were themselves unlikely to occur (L) ?
Not a criticism but some HACCP plans for the metal CCPs simply state the metal detector pass/fail requirement with associated corrective actions etc.
Not sure if I saw explicitly stated anywhere the intention to validate (not verify) the critical limits employed (would seem to be fairly self-specifying for your CCPs).
One item (yr last page) you might think about is that microbial counts (I assume you mean aerobic plate counts) as such are not normally regarded as relevant to a (safety) seafood HACCP plan, which strictly focuses on pathogens only from a CCP point of view (I realise yr analysis includes some kind of control points also where there may be relevance). Nonetheless the implication of yr comment is totally relevant to pathogens also.
Your comments regarding control of raw materials are accurate and represent an area of some disagreement in seafood HACCP in my experience. The aspect of a consumer cooking a final product and thereby 'neutralising'a possible raw material CCP was as far as I know first published in a USA guide. The possible degrading of the factory environment and possible consumer inability seem to have been classified L in this decision.
Hope you don't mind the comments, I enjoyed the reading very much.
Congratulations!.
Rgds / Charles.C

Edited by Charles.C, 17 July 2006 - 07:05 PM.

[Hongyun]

Wow, didn't know it was that OK. Thanks for all the encouraging words. Felt so much more confident in handing this up now.

I noted that you present a rather narrow range of microbiological species which are normally considered to represent a significant hazard for typical seafood. Perhaps you had already done an elimination process here ?

Actually, I don't really know alot about fishes and their pathogens... Sites like these doesn't help also:

http://seafood.ucdav...ans/fillets.htm
http://www.cdc.gov/n...l3no2/fryer.htm
http://aquanic.org/p...rac/nrac113.pdf

There are just so much information online that it's confusing to a non-fishery person... The first site did not mention the names of the pathogen, the second gives alot of information, but i think the pathogens are related to the COO (Country of Origin) of the fish and what type? Maybe I should include Renibacterium salmoninarum, Yersinia ruckeri, and Aeromonas salmonicida as mentioned in the third site? And all the above information are dated 1997 and before.

Would be interested to know how the Ls and Ms combined for the SIG. column if this is not copyright. I use a similar method and I find the degree of subjectivity (imagination) required in the obtaining of these parameters is occasionally enough to produce a headache.
Did find it a bit surprising that you considered that all the hazards which ultimately led to CCPs were themselves unlikely to occur (L) ?

The SIG column would have to be based on experience in the company or logic, but in this case, rationale and imaginary. Those hazards with CCPs may have a L under "Likelyhood" because they are not likely to happen. The first check point would have been the manufacturers, second would be the receival of raw materials. Upon discovery of non-confomity, they will reject straight away, thus preventing it from reaching the final end-user. I've given them a CCP/CQP because if the non-conformance product reaches the consumers (due to negligence), it may result in severe poisoning, thus SEV is H. Not sure if this rationale is good enough though...

Not a criticism but some HACCP plans for the metal CCPs simply state the metal detector pass/fail requirement with associated corrective actions etc.

Any websites that i can refer to? Not experienced on the metal detector thingy.

One item (yr last page) you might think about is that microbial counts (I assume you mean aerobic plate counts) as such are not normally regarded as relevant to a (safety) seafood HACCP plan, which strictly focuses on pathogens only from a CCP point of view (I realise yr analysis includes some kind of control points also where there may be relevance). Nonetheless the implication of yr comment is totally relevant to pathogens also.

Well, TPC included, but in this document, I meant the pathogens. Imagine the high salmonella count in the fish... If consumers did not cook according to the instructions (some may like their noodles warm, perhaps?), then it would result in a catastrophe! (OK, maybe i was being a little drama here ) But I'm not going to argue with the creator of the decision tree. If it's not a CCP, then it's not. And like you said, the statistic from USA established the inability to neutrlize the hazard as L. Maybe I should change the Self-evaluation part a little.

Thanks all! Appreciate all the comments given.

[Charles.C]

Dear Hongyun,
I agree there is not too much IT info.readily available for your chosen product.
The blue book / purple book are two favourites for seafood HACCP -

http://seafoodhaccp....anuals_pdf.html


Metal detection - Master guru CharlesChew organised this informative thread -

http://www.saferpak....wtopic=317&st=0

Three more comments (!) -
(1) I didn't understand the symbol meanings for yr initial 'Hazard Analysis of Final Product'. Not seen this type of analysis in modern HACCP plans. Maybe it's just me.
(2) Since the recommended storage was at -20degC, maybe you should give a shelf life for that in addition to -10degC.
(3) It might be worthwhile to state 'frozen or cold' storage on yr flowchart where it is -18degC or cooler.

Rgds / Charles.C

[Hongyun]

Dear Hongyun,
I agree there is not too much IT info.readily available for your chosen product.
The blue book / purple book are two favourites for seafood HACCP -

http://seafoodhaccp....anuals_pdf.html
Metal detection - Master guru CharlesChew organised this informative thread -

http://www.saferpak....wtopic=317&st=0

Three more comments (!) -
(1) I didn't understand the symbol meanings for yr initial 'Hazard Analysis of Final Product'. Not seen this type of analysis in modern HACCP plans. Maybe it's just me.
(2) Since the recommended storage was at -20degC, maybe you should give a shelf life for that in addition to -10degC.
(3) It might be worthwhile to state 'frozen or cold' storage on yr flowchart where it is -18degC or cooler.

Rgds / Charles.C

Thanks for info Charles! Just what i need to update my assignment.

As for point one, the HA of final product was not actually required by the Codex Guidelines, but advisable to have one. As they provide "information on how the ingredients and finished goods must be stored, handled, processed, and distributed to ensure that they remain safe to eat."

So, since this was inside the handbook, I think it would stand a certain percentage of marks on the assignment.

One more question, how would an allergen (Chemical hazard) look like if i were to add it in?

Receving of wheat flour
Cause: Identified as allergen
Sev:M
Like:M
Sig:L
Control measures: Label to be printed accordingly (??)
Rationale: With Labelling, consumers can better protect themselves by making a decision on whether to purchase the product or not, resulting in a "L" under sig. (???)
CCP Q1:Y
CCP Q2:Y
CCP Q3:N
CCP Q4:N
--> Not CCP, but it's a CP.

How accurate is the above information? Have been reading on another thread that mentions allergen issues. Seems like the main thing is labelling, as there isn't a fixed limit to certain types of allergen, except gluten?

[Charles.C]

Dear Hongyun,
Highly topical but tricky question as demonstrated in the recent thread on allergens to which you refer.
As you saw, for your type product I think there is not as yet a consensus. Seems the trend is to label everything but sometimes so small as to be unreadable.(Regulatory requirements may come before HACCP, different question).
It's ok to cover yr back if you are prepared to defend it. If not, perhaps you should stick to the sure items. Maybe some other gluten specialist can help here??. I bet Simon's suspect fish fingers didn't say anything about gluten but now, not so sure.
(Ch.19/Ap6 (purple book) or Ch6-Pg7 (blue book) has some general allergenic control ideas).

Normally sig.L means not-CCP whereas H (or possibly M) can be CCP. Yr handbook is a bit unusual. Some risk decision matrixes have more levels so as to provide increased flexibility (more zigzags). Whatever, the risk analysis has to support yr conclusion and be validatable.
I don't use D-tree layouts (don't like method) so perhaps some other reader can answer this one.
Rgds / Charles.C

[Jean Michel]

very interesting the Assignment you made . It can be used as a source of inspiration for all those who are trying to find a good HACCP Plan