2 replies to this topic

[kfromNE]

First, if anyone has an example of a more complex Seafood HACCP plan than just processing a seafood item - that would be great.

Oregon State University has some examples but not exactly what I need to clear up my confusion.

 

Processing facility/secondary processor

Seafood Items being made: Non-RTE salmon patties and Non-RTE seafood soups

 

I want to double check that I'm doing it right. It also needs to be SQF compliant as well. (I've written FDA FSMA plans and HACCP Plans)

 

Seafood plan flow charts: for receiving in seafood/separate, do I need to specifically call it out from other FDA ingredients in the flow diagram.

 

Seafood Soups: Do I need to separate plans for different soups. The process is the same but the species would be different. For example: Lobster bisque and clam chowder.

 

Salmon patties - I assume since the salmon would be the same but different ingredients - I could have one HACCP plan for different varieties of salmon patties?

 

CCPs. Do process related hazards mentioned in the Guidance Document need to be CCPs. For example, metal inclusion and allergens. For our USDA and FDA items - we have those as SOPs not CCPs. 

Edited by kfromNE, 01 February 2023 - 03:32 PM.

[Sayed M Naim Khalid]

Hello KfromNE, 

 

You have 3 questions: 

1. Salmon patties: If you have 2 distinct finished products at the end because either the ingredient or the processing might make it a unique end product, I recommend consider different HACCP plans. 

 

2. CCP determination: I would highly recommend doing a detailed hazard analysis/ risk assessment to determine a CCP. Guides can certainly help but they are not the solution. You may use a "5x5 Risk matrix" for every step of the process. Based on that you can quantify and justify a CCP and the need for a CCP. 

 

3. Lastly, your question regarding SOP replacing CCP is tricky. Because if you are able to quantify the risk using this formula: 

"Risk = probability of occurrence or likelihood x impact". 

 

If both the Likelihood of occurrence and Impact are HIGH, I would choose CCP. If the impact and likelihood are minor in that case, you may consider an SOP or PRP (if using FSSC/ISO 22000). 

 

Thus, in choosing CCP or SOP consider the following: 

1. Load of work for documentation/record keeping

2. Cost associated to recording/record keeping.

3. Cost associated to training

4. Cost associated to potential changes in the equipment/infrastructure 

[Brothbro]

For wondering if you need different plans, it can come down to if your products have different hazards that need attention. Does clam chowder have different hazards and/or different CCPs that would need to be added to control these hazards? If so then they would likely need different plans. When I worked in soup, we had many products under 2-3 separate plans because so many were processed/controlled in the same way.