A CCP that always fails

Hi,

I am currently confused on whether we should categorize manual sorting as a CCP. This is a roasted peanut factory which has peanuts without shells (I do not know the term in english) as its raw material. The manual sorting step is where we manually separate pebbles and low-quality nuts before they get into production.

Now the risk assessment showed that pebbles are a significant hazard in the production line. However, we already have an x-ray inspection (categorized as CCP) after the product is packed that regularly - by regularly I mean every shift - still detects pebbles that contaminate the product. The HACCP plan currently categorized manual sorting as a CCP and the critical limit that it currently has is "No pebble contamination".

I still think that it is not a CCP because its failure doesn't necessarily mean the product is unsafe since a subsequent step (X-ray) will eliminate the significant hazard from the product. Moreover, as I said in the previous paragraph, the x-ray inspection always finds pebbles contaminating the product every shift, so the critical limit of the manual sorting step is clearly not met, therefore it always fails, no? 

any thoughts on why it should or should not be a CCP?

Thanks

Hi,

I am currently confused on whether we should categorize manual sorting as a CCP. This is a roasted peanut factory which has peanuts without shells (I do not know the term in english) as its raw material. The manual sorting step is where we manually separate pebbles and low-quality nuts before they get into production.

 

Now the risk assessment showed that pebbles are a significant hazard in the production line. However, we already have an x-ray inspection (categorized as CCP) after the product is packed that regularly - by regularly I mean every shift - still detects pebbles that contaminate the product. The HACCP plan currently categorized manual sorting as a CCP and the critical limit that it currently has is "No pebble contamination".

 

I still think that it is not a CCP because its failure doesn't necessarily mean the product is unsafe since a subsequent step (X-ray) will eliminate the significant hazard from the product. Moreover, as I said in the previous paragraph, the x-ray inspection always finds pebbles contaminating the product every shift, so the critical limit of the manual sorting step is clearly not met, therefore it always fails, no? 

 

any thoughts on why it should or should not be a CCP?

 

Thanks

Hi vanmikhael,

Yr situation seems analogous to possible contamination of raw material (or in-process) by metal which subsequently controlled by a MD.

Some comments -

(1) IMO the critical limit for yr x-ray is illogical from a quantitative, operational POV. I suggest to study the numerous threads here on CLs/metal detectors.

(2) I note the standard is iso22000. Difficult to see how yr sorting step would fulfil the CCP requirements (cf OPRP) for this standard, eg "continuous" monitoring, lack of a subsequent, effective, control measure. In fact it's difficult (for me) to see how you can even justify a significant hazard in the first place but this may depend on how you interpret the iso definition of a "significant" hazard.

(3) BUT, I have nonetheless seen a textbook example using Codex haccp where a magnet was utlised prior to an end-of-line MD in an equivalent way to yr manual sorting step. The author chose (ie subjectively) to declare the magnet as a CCP since it was "felt" this step was "critical" for the process to be satisfactorily ran although most textbooks would probably regard the magnet as a non-significant step from haccp POV. Of course, the pairing (ie sorting/X-ray) could  be regarded as a combined control measure  which is also compatible with iso22000.

So I agree with yr basic conclusion(s). (You may also find a reference to "sorting" as handleable via PRPs in iso22002-1)

Hi vanmikhael,

 

Yr situation seems analogous to possible contamination of raw material (or in-process) by metal which subsequently controlled by a MD.

 

Some comments -

 

(1) IMO the critical limit for yr x-ray is illogical from a quantitative, operational POV. I suggest to study the numerous threads here on CLs/metal detectors.

 

(2) I note the standard is iso22000. Difficult to see how yr sorting step would fulfil the CCP requirements (cf OPRP) for this standard, eg "continuous" monitoring, lack of a subsequent, effective, control measure. In fact it's difficult (for me) to see how you can even justify a significant hazard in the first place but this may depend on how you interpret the iso definition of a "significant" hazard.

 

(3) BUT, I have nonetheless seen a textbook example using Codex haccp where a magnet was utlised prior to an end-of-line MD in an equivalent way to yr manual sorting step. The author chose (ie subjectively) to declare the magnet as a CCP since it was "felt" this step was "critical" for the process to be satisfactorily ran although most textbooks would probably regard the magnet as a non-significant step from haccp POV. Of course, the pairing (ie sorting/X-ray) could  be regarded as a combined "significant hazard" which is also compatible with iso22000.

 

So I agree with yr basic conclusion(s). (You may also find a reference to "sorting" as handleable via PRPs in iso22002-1)

Hi Charles, 

Definitely going to check the iso2002-1 and the topics you suggested. (3) is quite interesting though I am not familiar with the term "combined significant hazard" (but maybe that's just because of the language barrier).

Thank you for the reply!

Hi vanmikhael,

If we look at ISO 22000 Clause 8.5.2.4 Selection and categorization of control measure(s)

8.5.2.4.1 Based on the hazard assessment, the organization shall select an appropriate control measure or combination of control measures that will be capable of preventing or reducing the identified significant food safety hazards to defined acceptable levels.

The organization shall categorize the selected identified control measure(s) to be managed as OPRP(s) (see 3.30) or at CCPs (see 3.11).

The categorization shall be carried out using a systematic approach. For each of the control measures selected, there shall be an assessment of the following:

a) the likelihood of failure of its functioning;

b) the severity of the consequence in the case of failure of its functioning; this assessment shall include:

1) the effect on identified significant food safety hazards;

2) the location in relation to other control measure(s);

3) whether it is specifically established and applied to reduce the hazards to an acceptable level;

4) whether it is a single measure or is part of combination of control measure(s).

All of the above would indicate that the sorting process is a Prerequisite Programme and X-Ray a Critical Control Point or Operational Prequisite Programme.

Also, Clause 8.5.2.4.2 requires an assessment of feasibility including for establishing critical limits/action criteria, monitoring to detect failures and applying timely corrective actions. The sorting process isn’t really feasible in terms of any of these really.

One other thing, I still use a Decision Tree to help me distinguish between Critical Control Points and Operational Prequisite Programme. See attached Decision Tree Slides, the second page is a different example.

IFSQN HACCP Training New Decision Tree.pdf   686.4KB   77 downloads

For your process at the sorting step:

Question 1: Can the significant hazard be controlled to an acceptable level at this step by prerequisite programs (e.g. GHPs)?

No – go to Question 2

Question 2: Do specific control measures for an identified significant hazard exist at this step?

Yes – Go to Question 3

Question 3: Will a subsequent step prevent or eliminate the identified significant hazard or reduce it to an acceptable level?

Yes – That subsequent step should be a Critical Control Point

Kind regards,

Tony

Hi,

I am currently confused on whether we should categorize manual sorting as a CCP. This is a roasted peanut factory which has peanuts without shells (I do not know the term in english) as its raw material. The manual sorting step is where we manually separate pebbles and low-quality nuts before they get into production.

 

Now the risk assessment showed that pebbles are a significant hazard in the production line. However, we already have an x-ray inspection (categorized as CCP) after the product is packed that regularly - by regularly I mean every shift - still detects pebbles that contaminate the product. The HACCP plan currently categorized manual sorting as a CCP and the critical limit that it currently has is "No pebble contamination".

 

I still think that it is not a CCP because its failure doesn't necessarily mean the product is unsafe since a subsequent step (X-ray) will eliminate the significant hazard from the product. Moreover, as I said in the previous paragraph, the x-ray inspection always finds pebbles contaminating the product every shift, so the critical limit of the manual sorting step is clearly not met, therefore it always fails, no? 

 

any thoughts on why it should or should not be a CCP?

 

Thanks

Hi Vanmikhael,

I think one of the solutions if you wanna put the sortir process as CCP is, you must have a machine that can separate the peanuts and the pebble,

such as the principle of rice sorting. Maybe the machine is called "De Stoner" CMIIW. 

and at first, you must make sure the supplier of the peanuts is already Sortir also (in case you do not buy the peanuts with lower grade).

if you wanna discuss this with Indonesia, just send me a DM or email.

Thanks

Hi vanmikhael,

If we look at ISO 22000 Clause 8.5.2.4 Selection and categorization of control measure(s)
8.5.2.4.1 Based on the hazard assessment, the organization shall select an appropriate control measure or combination of control measures that will be capable of preventing or reducing the identified significant food safety hazards to defined acceptable levels.
The organization shall categorize the selected identified control measure(s) to be managed as OPRP(s) (see 3.30) or at CCPs (see 3.11).
The categorization shall be carried out using a systematic approach. For each of the control measures selected, there shall be an assessment of the following:
a) the likelihood of failure of its functioning;
b) the severity of the consequence in the case of failure of its functioning; this assessment shall include:
1) the effect on identified significant food safety hazards;
2) the location in relation to other control measure(s);
3) whether it is specifically established and applied to reduce the hazards to an acceptable level;
4) whether it is a single measure or is part of combination of control measure(s).

All of the above would indicate that the sorting process is a Prerequisite Programme and X-Ray a Critical Control Point or Operational Prequisite Programme.

Also, Clause 8.5.2.4.2 requires an assessment of feasibility including for establishing critical limits/action criteria, monitoring to detect failures and applying timely corrective actions. The sorting process isn’t really feasible in terms of any of these really.

One other thing, I still use a Decision Tree to help me distinguish between Critical Control Points and Operational Prequisite Programme. See attached Decision Tree Slides, the second page is a different example.

IFSQN HACCP Training New Decision Tree.pdf

For your process at the sorting step:

Question 1: Can the significant hazard be controlled to an acceptable level at this step by prerequisite programs (e.g. GHPs)?
No – go to Question 2
Question 2: Do specific control measures for an identified significant hazard exist at this step?
Yes – Go to Question 3
Question 3: Will a subsequent step prevent or eliminate the identified significant hazard or reduce it to an acceptable level?
Yes – That subsequent step should be a Critical Control Point

Kind regards,

Tony

CCPs should always have a measurable value attached and "no pebbles" is neither feasible nor practical.

Humans are fallible, so manual sorting will never get all the pebbles out. It's not a CCP. 

What do you do if the X-ray detector detects pebbles? How many boxes are (percentage) are detected to be contaminated?

As per a thorough hazard analysis, manual sorting is not a CCP as it's not the final step (your x-ray is) for foreign material control

The manual sorting should be a process control and/or PRP with monitoring as a support to the CCP 

As per a thorough hazard analysis, manual sorting is not a CCP as it's not the final step (your x-ray is) for foreign material control
 
The manual sorting should be a process control and/or PRP with monitoring as a support to the CCP

THIS is why Scampi is Member of the Month. Completely concise

Agree.  I basically wanted to say exactly what she wrote.  Handsorting is not a CCP here since it's followed by a control point that addresses the same risk, not to mention I wouldn't want to try and write a calibration and validation for handsorters sufficient to meet a CCP standard lol.

Hello Tony,

Is this decision tree confirmed by Codex? Should I update our documents to this?

Hi Dyvinil,

Codex-related queries may not be relevant to iso22000. Note also that Codex (2020) no longer included  it's long utilised tree.

I think Tony/Codex's proposed trees are slightly amplified (easier to understand/use) versions of the famous Campden Decision tree which was published many, many years ago in UK. For example -

FSA (Campden) HACCP Decision Tree.pdf   76.26KB   30 downloads

(Codex does not restrict the use of alternative trees or Procedures.)

afaik, Iso22000 is not governed by Codex Rules although some overlaps may exist..

I was unable to see an option for sorting of raw material to be a PRP via iso22002-1.

There is at least one crucial step in the hazard analysis of iso22000 -

Is the hazard identified actually a  Significant hazard (SH) ? [ie See Post 2,(2)]

The procedure to determine  a "significant hazard"  is defined in para 8.5.2.3. Use of 8.5.2.3 obviously indicates that there is a significant (Physical) hazard at the sorting step. (This new ISO approach (modified from original version) is afaik contrary to some other  previously published, Codex-based, haccp procedures and, I deduce, has been modified to add conformity with the, IMO, analogous and equally peculiar (to me) hazard logic requirements in FSMA's haccp system. (Extensively, previously, discussed on this Forum but not afaik leading to any final conclusion).

IMO a "conventional" haccp, L x S, hazard analysis would not yield a Significant Hazard (ie sorting is just a "routine" process step with respect to Physical/pebble hazard)  particularly due to observations such as those in posts 8-10. Blame FSMA (or my inability to understand it).

Regardless. assuming a SH does exist, will presumably be necessary to apply the list of items in post 4 (et al) to determine between CCP/OPRP .

(as per the Standard, it seems to me that "PRP" is no longer a possible choice of control measure following implementation of 8.5.2.4.1).

This step involves selecting a Decision Tree. Many, many proposed decision trees exist for iso22000(2005) and at least one on this Forum for iso22000(2018). The FSSC22000 ver5 Guidance material for iso22000(2018) also offers a decision procedure but for which i have significant reservations as detailed elsewhere on this forum.

I tried the tree developed on this forum for iso22000(2018) (see link below) and the result was (easily) OPRP.

https://www.ifsqn.co...18/#entry138153

The above result is different to the (PRP) conclusion in Post 4. I'm unsure as to whether the Posts 8-10 relate to iso22000. Further comments anticipated :smile: .

(A combined control measure could probably achieve CCP but may be documentation-messy)

PS - regarding "combined sig. hazard", my apologies for the conceptual typo, should be " combined control measure", eg  para 3.44. 

Hi Charles,

The decision tree posted was adopted by CAC45 last month and is from REPORT OF THE 52nd SESSION OF THE CODEX COMMITTEE ON FOOD HYGIENE in 2022

Hygiene Committee Conclusion

52. CCFH52 agreed to forward:

i. the “Tools to determine the critical control points (CCPs)” to CAC45 for adoption at Step 5/8 and subsequent inclusion as Annex 2 in the General Principles of Food Hygiene (CXC 1- 1969) (Appendix III, part A); and

ii. the consequential amendment to Section 3.7 of Chapter two of CXC 1-1969 to cross-reference Annex 2 (Appendix III, part B)

Appendix III with proposed Decision Tree attached.

Appendix III_Proposed decision tree 2022.pdf   210.25KB   20 downloads

Draft Report of the 45th Session of the Codex Alimentarius Comission dated 6^th December 2022

CODEX COMMITTEE ON FOOD HYGIENE (CCFH) (Agenda Item 4.3)

Final adoption

54. CAC45 adopted the:

i. Guidelines for the Management of Biological Foodborne Outbreaks) at Step 8; and

ii. Revision to the General Principles of Food Hygiene (CXC 1-1969).

55. The Chairperson noted that with the adoption of the decision-tree, Codex had now completed a major revision of the General Principles of Food Hygiene (CXG 1-1969). Recalling that this was the foundational text for many of the Codex food hygiene texts and was also extensively cross-referenced in other Codex texts, it was now necessary to ensure that, where relevant, Codex texts were fully aligned with the latest version of the General Principles on Food Hygiene (CXG 1-1969).

Kind regards,

Tony

Hello Tony,

Is this decision tree confirmed by Codex? Should I update our documents to this?

Hi Dyvinil,

See my previous post.

You could use the Decision Tree or the CCP determination worksheet included in file attached in post 12 if you wish. They will be included when a revised version of CODEX General Principles of Food Hygiene is published. You would hope it would be published quite quickly now but given it has taken 9 months to get the nod, don’t hold your breath  :rolleyes:

Kind regards,

Tony

Hi Charles,

 

The decision tree posted was adopted by CAC45 last month and is from REPORT OF THE 52nd SESSION OF THE CODEX COMMITTEE ON FOOD HYGIENE in 2022

Hygiene Committee Conclusion

52. CCFH52 agreed to forward:

i. the “Tools to determine the critical control points (CCPs)” to CAC45 for adoption at Step 5/8 and subsequent inclusion as Annex 2 in the General Principles of Food Hygiene (CXC 1- 1969) (Appendix III, part A); and

ii. the consequential amendment to Section 3.7 of Chapter two of CXC 1-1969 to cross-reference Annex 2 (Appendix III, part B)

 

Appendix III with proposed Decision Tree attached.

 

Appendix III_Proposed decision tree 2022.pdf

 

Draft Report of the 45th Session of the Codex Alimentarius Comission dated 6^th December 2022

CODEX COMMITTEE ON FOOD HYGIENE (CCFH) (Agenda Item 4.3)

Final adoption

54. CAC45 adopted the:

i. Guidelines for the Management of Biological Foodborne Outbreaks) at Step 8; and

ii. Revision to the General Principles of Food Hygiene (CXC 1-1969).

 

55. The Chairperson noted that with the adoption of the decision-tree, Codex had now completed a major revision of the General Principles of Food Hygiene (CXG 1-1969). Recalling that this was the foundational text for many of the Codex food hygiene texts and was also extensively cross-referenced in other Codex texts, it was now necessary to ensure that, where relevant, Codex texts were fully aligned with the latest version of the General Principles on Food Hygiene (CXG 1-1969).

 

Kind regards,

 

Tony

Hi Tony,

Many thanks for the above. 10+ years to, seemingly, add one line and take one away.

I note the pdf footnotes have the same, I guess again FSMA inspired, comment  as  referred in my Post 11. So now I can include Codex in the semi-rant. :smile:

I like the tree but it seems somewhat limited from an ISO22000 POV in that it excludes the majority of factors listed in 8.5.2.4.1.

IMO the candidate control measure(s) for 8.5.2.4.1 could be (i) X-ray step or (b) sorting step + X-ray step. However the sorting step is obviously problematic regarding CL/action limits.

Both (i,ii) score as CCPs in the excel referenced in Post 11.

A decision tree to handle both (i,ii) could IMO also be readily assembled from the original Procert ISO22000/CocaCola decision trees. The result for (i,ii)  would also be CCP.

I have briefly investigated FSMA's haccp "handling" of metal contamination potentially acquired during early processing stages in respect to a MD at a later location. The model FSMA example attached seems to implement the "traditional"  haccp logic whereby the early hazard is satisfactorily controlled by the later MD. Perhaps, at least for FSMA, commonsense has (quietly) over-ridden, IMO, twisted textual logic. I recommend iso and Codex to follow the same path.

FSMA,HARPC - Food Plan Example.pdf   841.74KB   26 downloads

Hi everyone, 

Hi Vanmikhael,

 

I think one of the solutions if you wanna put the sortir process as CCP is, you must have a machine that can separate the peanuts and the pebble,

such as the principle of rice sorting. Maybe the machine is called "De Stoner" CMIIW. 

 

and at first, you must make sure the supplier of the peanuts is already Sortir also (in case you do not buy the peanuts with lower grade).

We do have a destoner and it's placed before the manual sorting process and it's currently categorized as an OPRP (Still questionable for me, but that's a different topic). I'll be glad to contact you if I have further questions. 
 

CCPs should always have a measurable value attached and "no pebbles" is neither feasible nor practical.

Humans are fallible, so manual sorting will never get all the pebbles out. It's not a CCP. 

 

What do you do if the X-ray detector detects pebbles? How many boxes are (percentage) are detected to be contaminated?

I agree that "no pebbles" is neither feasible nor practical. 

if the x-ray detector detects pebbles, the product (in flexible packaging) and the box which contains the contaminated product will be terminated. The pebbles will also be collected for further evaluation. I do not know the exact percentage for the contaminated boxes, but every shift we usually detect one or two pebbles.

Hi vanmikhael,

 

If we look at ISO 22000 Clause 8.5.2.4 Selection and categorization of control measure(s)

8.5.2.4.1 Based on the hazard assessment, the organization shall select an appropriate control measure or combination of control measures that will be capable of preventing or reducing the identified significant food safety hazards to defined acceptable levels.

The organization shall categorize the selected identified control measure(s) to be managed as OPRP(s) (see 3.30) or at CCPs (see 3.11).

The categorization shall be carried out using a systematic approach. For each of the control measures selected, there shall be an assessment of the following:

a) the likelihood of failure of its functioning;

b) the severity of the consequence in the case of failure of its functioning; this assessment shall include:

1) the effect on identified significant food safety hazards;

2) the location in relation to other control measure(s);

3) whether it is specifically established and applied to reduce the hazards to an acceptable level;

4) whether it is a single measure or is part of combination of control measure(s).

 

All of the above would indicate that the sorting process is a Prerequisite Programme and X-Ray a Critical Control Point or Operational Prequisite Programme.

 

Also, Clause 8.5.2.4.2 requires an assessment of feasibility including for establishing critical limits/action criteria, monitoring to detect failures and applying timely corrective actions. The sorting process isn’t really feasible in terms of any of these really.

 

One other thing, I still use a Decision Tree to help me distinguish between Critical Control Points and Operational Prequisite Programme. See attached Decision Tree Slides, the second page is a different example.

Thank you for the decision tree.

I agree that it isn't feasible to establish CL/action criteria, monitoring to detect failures, and so on. 

Hi vanmikhael,

My eventual opinion for this tricky scenario for iso22000-2018/absence prior control actions is -

(1) Sorting is a significant hazard.

(2) Sorting step is not associated with a CCP, OPRP or PRP(last one possibly somehow debatable via iso22002-1)

(3) X-ray step is a significant hazard and associated with a CCP (cf CCP1,2 in excel attached,Pg2)

The attached excel contains extracts which assisted my conclusion, particularly the locational analogies to FSMA (+ FSMA example in Post 14).

related extracts.xlsx   857.53KB   30 downloads

PS - the destoner is an interesting accessory also. So why the manual sorting ?  :smile:

Hi vanmikhael,

 

My eventual opinion for this tricky scenario for iso22000-2018/absence prior control actions is -

 

(1) Sorting is a significant hazard.

(2) Sorting step is not associated with a CCP, OPRP or PRP(last one possibly somehow debatable via iso22002-1)

(3) X-ray step is a significant hazard and associated with a CCP (cf CCP1,2 in excel attached,Pg2)

 

The attached excel contains extracts which assisted my conclusion, particularly the locational analogies to FSMA (+ FSMA example in Post 14).

 

related extracts.xlsx

 

PS - the destoner is an interesting accessory also. So why the manual sorting ?  :smile:

Hi Charles,

Could you elaborate on your first point? thanks

to answer your PS; even though we process the RM through the destoner (which works greatly, but not that perfect since we still find some stones/pebbles that managed to get through), we added the manual sorting process to further ensure that there are no stones/pebbles before entering the production line. But even after those 2 steps, we still find pebbles/stones contaminating the product (hence why the topic started)

Hi Charles,

Could you elaborate on your first point? thanks

to answer your PS; even though we process the RM through the destoner (which works greatly, but not that perfect since we still find some stones/pebbles that managed to get through), we added the manual sorting process to further ensure that there are no stones/pebbles before entering the production line. But even after those 2 steps, we still find pebbles/stones contaminating the product (hence why the topic started)

Hi vanmikhael,

I was perhaps a little over-concise, should have stated (1) Sorting is associated with a Significant (Physical) Hazard, ie pebbles.

To elaborate the reason, can read the attached extract and re-read the last paragraph in Post 14.

HACCP, HARPC, Significant Hazards.pdf   547.5KB   26 downloads

Can also see this, ageing, Post -

https://www.ifsqn.co...al/#entry100927

(see (1))

If the underlined (red) text in Post 16 did not exist, then my opinion would be Non-significant.

Hi Charles,

Could you elaborate on your first point? thanks

to answer your PS; even though we process the RM through the destoner (which works greatly, but not that perfect since we still find some stones/pebbles that managed to get through), we added the manual sorting process to further ensure that there are no stones/pebbles before entering the production line. But even after those 2 steps, we still find pebbles/stones contaminating the product (hence why the topic started)

Hi Vanmikhael,

i think you should review again the destoner machine that your company already used, just like maybe there is wrong with your machine or the method that you already have

Thanks

thanks for your inputs, charles and Rafif  :spoton: 
 
There's an update to this,

An opinion came from someone from the haccp team, they said that the preparation of the raw material before the production and the production itself is different/divided. They created 2 flow diagrams (one for the prep of RM, and one for the production) in the haccp plan for the roasted peanuts. They argue that since the prep of RM line ended with the manual sorting step, therefore there is not a subsequent step that removes the hazard. Now this is something new to me (dividing the process in one haccp plan when one part is followed by the other), I want to ask*:

1) Does the division of processing line mean that the MD and x-ray steps are not subsequent steps for this product? and please give the reasons why

if they aren't,

2) If we put aside the feasibility and practical side of the CLs and monitoring of the manual sorting step (so let's assume that we can establish the CL and monitoring and so on), can we then categorize it as a CCP?

3) If we deal with this like we are supposed to (establishing measurable CLs and so on), will it be okay if there's an oprp (destoner) but no ccp in the prep line (I reckon from this forum that it's okay not to have a ccp, but usually in those cases there are no mentions of other OPRPs)

*I think I should've clarified that roasted peanuts are not the only product they make (but I'm reviewing the roasted peanuts line). However, every single production line that uses peanuts from that prep line has an MD and an xray. 

Thanks

thanks for your inputs, charles and Rafif  :spoton: 
 
There's an update to this,

An opinion came from someone from the haccp team, they said that the preparation of the raw material before the production and the production itself is different/divided. They created 2 flow diagrams (one for the prep of RM, and one for the production) in the haccp plan for the roasted peanuts. They argue that since the prep of RM line ended with the manual sorting step, therefore there is not a subsequent step that removes the hazard. Now this is something new to me (dividing the process in one haccp plan when one part is followed by the other), I want to ask*:

1) Does the division of processing line mean that the MD and x-ray steps are not subsequent steps for this product? and please give the reasons why

 

if they aren't,

2) If we put aside the feasibility and practical side of the CLs and monitoring of the manual sorting step (so let's assume that we can establish the CL and monitoring and so on), can we then categorize it as a CCP?

 

3) If we deal with this like we are supposed to (establishing measurable CLs and so on), will it be okay if there's an oprp (destoner) but no ccp in the prep line (I reckon from this forum that it's okay not to have a ccp, but usually in those cases there are no mentions of other OPRPs)

 

*I think I should've clarified that roasted peanuts are not the only product they make (but I'm reviewing the roasted peanuts line). However, every single production line that uses peanuts from that prep line has an MD and an xray. 

Thanks

Hi vanmikhael,

It sounds like yr haccp team have insufficient work to occupy their time so they are trying to maximise the number of CCPs/OPRPs.  :smile:

HACCP Plans certainly exist where complex, non-linear, flow systems are split into chunks (eg multiple end products) although this may then involve the necessity to evaluate if any further hazards where transitions are introduced. Afaik splitting is atypical (illogical?) if a visibly continuous linear flow with one end product is involved (the present case ?). Can compare the attachment/process in Post 14.

In respect to yr additional flowchart comments and queries (1-3) i note  that  -

(i) The flowchart/determination of significant hazards should presumably, minimally meet (all) the conditions stated in clauses -

8.5.1.5.1 (a), (c)

8.5.2.2.2 (a), (b)

8.5.2.3 (a), (b)

(ii) The significance/feasability of a (quantitative)CL in respect to differentiating between CCP/OPRP  is illustrated in the Procedures shown in the excel of Post 18.

Afaik, there is no restriction on the final number of CCPs or OPRPs or the ratio of CCPs to OPRPs. This was discussed in iso22004(2005).