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Procedure to release re-processed materials after failing it's CCP

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Marloes

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Posted 19 August 2022 - 09:35 AM

Hi all,

 

We have a procedure in which we analyse our incoming ingredients for certain parameters (CCP1). If it is below a certain levels we can release it. We know that in our processing we can reduce this parameter until below desired limit (no legal limits apply, only industry limits).

We have recently found that the quality and availability of our ingredients is decreasing. Causing us to needing to accept ingredients which are above the parameters of our incoming ingredient CCP.

I have talked to our directors and agreed to release the ingredient for processing only if we analyse the end-product and verify that it is in spec. This might still result in a downgrade if it is not in spec, but hopefully we can at least release some of this product which is in spec into the market.

However, this product still failed our CCP for incoming limits. My QA heart is not happy with releasing product that failed it's CCP.
So I am now looking to re-define our process to allow a second control measure if the first CCP fails.
But I am not sure how to put that into our HACCP plan.

Making a final ingredient analysis a mandatory CCP is not an option because the analysis for this parameters can take days. And our product and supply chain cannot handle that on a regular basis.

 

Does any of you have any brilliant suggestions?



pHruit

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Posted 19 August 2022 - 12:25 PM

Which certification scheme(s) are you operating under? That might have a bearing on how creative/constrained you are by their particular interpretation/corruption of Codex.

Without knowing the specifics of the process and materials it's difficult to speculate with any precision, but in terms of throwing out ideas on the basis that one of them may provide a useful avenue for further exploration:

 

If the receiving step CCP is such that product that fails it isn't necessarily unsafe, and that it isn't necessarily the last step at which you can control this hazard, can you recategorise it away from being a CCP?
You could for example then have a process flow that bifurcates at this point - material that passes the existing CCP limits goes down the existing flow, whereas material that fails goes down a modified version that is largely identical but with the addition of an extra step at the end for the final release testing. I'd expect this to get quite a bit of scrutiny, but equally it is arguably the case that the material goes through two slightly different processes depending on this first receipt step.

Alternatively you could look at splitting the process flow at the end of the current one, with a new "branch" coming off into the extra testing step before release, so you stick the CCP there.

 

I'm not sure I'd envy you trying to defend this in an audit though.

Obviously you'd need your risk assessments and hazard analysis to somehow justify this, and it's a little bit back-to-front deciding where your CCPs are and structuring the assessment around that.

May also be worth looking into different decision tree options and tactically choosing one that helps most in your situation - for example the five questions in the  Campden* one could possibly be answered as no/yes/no/yes/yes for your receipt step, in the right circumstances. Question three would perhaps be the most contentious, as your receipt step testing originally presumably was specifically designed to address a hazard, but under your revised flow you'd possibly argue that it instead is designed to determine which processing "route" (i.e. with or without the extra testing step at the end) your material takes.

 

As I've been typing this out, I haven't entirely convinced myself that it could work, but equally I also haven't convinced myself that it couldn't work ;)

In any case, hopefully it give some possibly useful ideas to explore, buried amongst the meandering drivel.

 

*If you don't own a copy of the Campden practical HACCP guide and don't want to purchase one, you can find the decision tree for free here: https://myhaccp.food...ine42page41.pdf



Marloes

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Posted 19 August 2022 - 12:39 PM

Thanks for your brainwave pHruit! 

Which certification scheme(s) are you operating under? 

 

 

We are operating under FSSC 22000 v5.1

 

I'm not sure I'd envy you trying to defend this in an audit though.

 

As I've been typing this out, I haven't entirely convinced myself that it could work, but equally I also haven't convinced myself that it couldn't work ;)

In any case, hopefully it give some possibly useful ideas to explore, buried amongst the meandering drivel.

 

Yeah, it's still a bit sticky/gray.

I believe that the end result is going to be the same: either a full in spec product or a downgrade.
Just not convinced on the technicalities in our HACCP plan yet.
 



Brothbro

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Posted 19 August 2022 - 05:40 PM

If the hazard exists in your process, but you have a step engineered to reduce this hazard to an acceptable level, would that reduction step not be the true CCP? Your testing of incoming materials is good monitoring, sure, but there is no actual hazard reduction applied. If during your hazard analysis you're conceding to the fact that the hazard is known to exist, it's reasonable that it will appear during testing. The importance then is the application of your control point to reduce this hazard. Why was the initial testing chosen as a CCP, and not the processing step that actually reduces this hazard to an acceptable level? To me, it makes more sense to validate the effectiveness of this processing step, then monitor its activity through testing. My plan would be to set the CCP on the processing step that reduces this hazard, and remove the CCP designation from your initial testing step.



oxkjs1

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Posted 19 August 2022 - 10:01 PM

It seems that you are currently collecting evidence to correlate a value in the ingredient to a value in the final product.  Once you have enough data, couldn't you take a 3 range approach:

 

range 1:  ingredients below a certain limit are used without any additional final product testing (your original critical limit) 

range 2:  ingredients that are between your original critical limit and your new critical upper limit (you must validate this new limit based on the correlation data you are collecting) would require an additional correction of testing the final product before it can be released 

range 3:  ingredients that exceed the new upper limit you established are obviously rejected 

 

This approach would turn the CCP to more of an OPRP (in my opinion) and you would need to do all the required updating of your food safety plan, hazard assessment, validations, monitoring, corrections, corrective actions and related records and documentation... and have it signed off by upper management prior to implementation....



Charles.C

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Posted 19 August 2022 - 10:23 PM

Hi Marloes,

 

I am rather amazed that you have implemented CCPs (or OPRPs for that matter) for your raw material inputs. This HACCP approach is afaik (long) obsolete and I would have thought anathema to FSSC22000 auditors.

 

One possible (simple) solution is self-evident (> PRPs) ?.


Kind Regards,

 

Charles.C




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