7 replies to this topic

[Andy_Yellows]

Hi all,

 

My company runs a small production unit within what is mainly a S&D facility and makes a small number of products including squeezed citrus (lemon, lime, grapefruit) juice. We've always had the sieving of the squeezed juice as a CCP to ensure no pips make it through into the finished product as a choking hazard but I'm on the fence with this. It doesn't really feel "critical" to the safety of the product for me, particularly the lemon and lime juice given that this isn't something that any sane person will drink neat.

 

So my question is to other juice manufacturers- is this considered a CCP generally or would more people have this as a PRP or QCP? Is there any documentation that references choking and a size of pip that would present a choking hazard rather than just an unpleasant addition to the juice?

 

Thanks in advance

[Brothbro]

I think the intended use of a product plays into its safety risks, and regarding fruit pips (assuming you mean seeds here) I would think you would classify it as a QCP. What is the design of your packaging? Perhaps a risk assessment could show that even if a seed made it into the bottle, the packaging designs would further prevent the seed from making it into the customer's recipe. Most citrus juice bottles I've seen have very small outlets that would not allow a seed to pass through. And like you mentioned, the juice is not consumed directly from the bottle. Therefore the seed in a bottle would be more an inconvenience, because it would clog the bottle. I would suggest that you should absolutely test your product for the presence of seeds post-filtration via some kind of sieve test on x number of bottles per y number produced to determine the effectiveness of your seed control. And if seeds are detected, would you not be able to re-filter the product to ensure seeds are removed?

 

Perhaps another question here is if a seed counts as "foreign material", considering it's part of the product's ingredients. I have no history in juice manufacturing, so my suggestions are just some brainstorming. Would be curious to hear what other more experienced users would think.

[Sayed M Naim Khalid]

Hello,

Pips (if hard) can be considered physical hazards. In order to decide whether it should be a CCP or not, I would do a risk assessment answering the following questions: 

 

1. How often pips pass through the sieve to the juice (frequency of mistake/occurrence)?
2. What is the potential risk of having pip in juice? 
3. What will be the severity of the risk? let's say that person swallow it? or chew it? What is the size of pips? 

Risk = occurrence x severity of impact 

 

If all the 3 questions answered with "high" (high occurrence and high risk and high severity), I would consider it CCP. 

 

But if this is just an occurrence of 1 in every 1000, the occurrence is minimal. If the size of the pips is small, then, the severity of the risk is also less. Thus, we can consider PRP or QCP. 

 

I would recommend doing a risk a assessment and contextualize that to your company environment. 

[SQFconsultant]

A processor in Panama had pips/seeds listed as a cp and not a ccp.

A risk analysis was completed and based on customer reports and consumer feedback it was changed from a ccp to a cp.

[SQFconsultant]

I looked at that again and it is not worded correctly.

The juice company in Panama used to have this as a ccp but when a new QA manager came in it was reviewed with us and it was changed to a cp.

[Tony-C]

Hi Andy,

 

For the size of object, I often reference the US FDA - Foods, Adulteration Involving hard or Sharp Foreign Objects Regulatory Action Guidance.

 

From the Guidance - The following represent the criteria for recommending legal action to CFSAN Office of *Compliance, Division of Enforcement* (HFS-605). :

d. The product contains a hard or sharp foreign object less than 7 mm in length and if a special-risk group, as defined in the background section, is among the intended consumers of the product.

 

Whether this is a CCP or not would depend on a few things:

1. Intended Use/Consumers/Potential Customer Use – What is the intended use of the product by the customer, and expected alternative uses, the consumer target groups, including the suitability of the product for vulnerable groups of the population (e.g. infants, elderly, allergy sufferers).

2. Sieving -  Is it removing other potential foreign bodies as well?

3. Labelling – Is there a warning that the juice “may contain” pips?

 

My view would be that you want to remove the pips and wouldn’t want to get too hung up on whether it is a CP/PRP or a CCP.

 

Kind regards,

 

Tony

[Charles.C]

Hi Andy,

 

Yr query is haccp-wise just like for metal, ie Is the pip significantly hazardous ?.

 

If UK follows USFDA (??) (the latter IIRC has a potential exemption for native constituents) and labelling not specifically including vulnerable populations, or implying pip-free, maybe measure some pips.

[Andy_Yellows]

Thanks all for your contributions. We do sieve the juice, removing all pips and have never had any feedback to the contrary. As a few of you have described, the intended use for the product is a part of my thinking, as is the frequency with which pips appear (more common in lemons than in limes or grapefruits).

After discussing with FS team members I have decided to change the sieving to a QCP rather than a CCP, after assessing all the factors described above and thanks to the guidance document posted by Tony above.

 

Thanks everyone for your help.