17 replies to this topic

[Meow]

Hello colleague,

I am writing up a HACCP plan for popcorn production, very clear production, start from receiving, storage, unbag, batching, poping, and packing, storage and distribution.

 

I had defined all the hazard related to raw material and process step. However, I am kind of stuck at the popping step as I am not sure if I should define it as CCP. I had been browsing all the related post in the forum, but still couldn't find the answers.  Hoping anyone who see the post can help with this. 

 

So as for popping step, one of the biological hazard I described is "Survival of pathogen due to insufficient cooking temperature or time", I had been doing some research, scientifically, as popcorns requires at least 355'F and certain pressure to pop. and After production, considering the popcorn nature, individual popcorn will be cooled down out of danger zone within 2 hours for sure, and the water activity of popcorn will be very low (we haven't done lab testing yet), even though there is chance that the popcorn might get cross contaminated with pathogen at the sifting table, there is no way still for the pathogen to grow on the popcorn. I will use sanitation program, and employee training (GMP) to mitigate the risk at the sifting step. 

 

But when it comes to the CCP decision tree, the popping step is not specifically designed to kill the micro, it is the original production process, it does requires to reach out to 355'F in order to get popped. thus I don't think this step shall be a CCP. However, this step did also serve a function to eliminate the microbes to certain level.... So I want to declare it as a Process Control instead of CCP.  I am using a severity and frequency matrix to rate each hazard. 

 

So, after consideration, there are 5 Process Control in my process:

1. Allergen information verification at receiving step (as we also have a allergen line in the same facility, thus there is might contain information on the packing bag)

2. Unpopped kernel warning information verification at receiving step (on the packing bag) to mitigate the risk of unpopped kernel

3. Popping step (Temperature Control); During poping process, there is another biological hazard I declared as "cross-contamination from the uncleaned kettle" and will be addressed by sanitation program and employee Training. Verify by daily or weekly ATP check.

4 &5. Cooling and Sifting Step (Cool down within 2 hours, and sift out the unpopped kernel - this one I don't think it is necessary, as we also declare the warning on the packing bag, still it doesn't hurt) 

 

Other hazard I declared shall be all controlled by the Preventive Control (we call PC in Canada, but in US it will be prerequisite Program)

 

Want to know your suggestion on this. Thanks!

 

[MOHAMMED ZAMEERUDDIN]

Metal Detector can be a CCP as Metal pieces can enter through raw material and machines.

[Evans X.]

Greetings Meow,

 

A question first. Does your popping step include some medium (eg oil) or just air heating?

 

In order to reach the 355^oF then the center of the kernel should propably have reached the ~162^oF required for pasteurization and this temperature should be lasting for at least 12 seconds throughout the process.

Point is that you don't seem to have another kill step than the temparature - time control during the popping and the conditions are there (maybe even exceeding them) for it to be considered a CCP. Cross contamination from unclean kettle is highly unlikely at these temperatures, at least microbiological ones.

 

Regards!

[kingstudruler1]

At least in terms of the popper CCP the below article may be of interest.   Especially in terms of survivability of the process.   Also the presence of 

 

Low moisture foods require a more significant time and temp than other products.  

 

 

https://www.scienced...n 0.86 and 0.89.

[Charles.C]

Hi Meow,

 

I am confused, Is this  HARPC (ie Process Controls), or HACCP (Ie CCPs) ?.

At the moment seems to be a mixture of both.

[Scampi]

Hi Meow,

 

I am confused, Is this  HARPC (ie Process Controls), or HACCP (Ie CCPs) ?.

At the moment seems to be a mixture of both.

Hey Charles

 

In Canada we use HACCP as the foundation, but require a preventative control plan (as we always have)  no HARPC here     I think the PP got the naming convention a little mixed up.......the term process control is a misnomer  (at least by CFIA standards) unless of course PP import/exports across the border of both countries

[Charles.C]

Hey Charles

 

In Canada we use HACCP as the foundation, but require a preventative control plan (as we always have)  no HARPC here     I think the PP got the naming convention a little mixed up.......the term process control is a misnomer  (at least by CFIA standards) unless of course PP import/exports across the border of both countries

Hi Scampi,

 

Thks for attempting clarification.

 

I tried some googling around "PCP" and ended up here -

 

https://inspection.c...7/1512152952810

 

I also downloaded the claimed "Help" text offered here -

 

https://inspection.c...492029286734#a2

 

Above is an absolute gem of, IMO, gobbledegook !

 

I get the overall impression, ie speculate, that the net result is that -

 

(1) the terminology "HACCP" has (amazingly !) almost no current FS usage in Canada anymore.(zero search hits for "HACCP" in above pdf) (***)

(2) the well-known "FSEP" manual is now obsolete and is no longer Canadian FS relevant.(zero search hits for "FSEP" in above pdf) (***)

(3) the so-called PCP (ie 1st link above) has totally replaced (1,2).(***)

 

(***) With the virtually single exception for anyone who has the Patience/Fortitude to reach the last section  of 2nd link above

 

Does the PCP aspect over-ride SQF (traditional) HACCP options  ?

 

Based on some of the terms appearing in OP, I'm not sure whether the OP appreciates all the above subtleties, does - Meow ???.

[Scampi]

Sorry Charles to split hairs but I respectively disagree

 

https://inspection.c...2/1525869759693

 

AND

 

https://inspection.c...08092049?chap=0

 

 

A PCP    IS   a GFSI plan

 

12 steps of HACCP no more and no less and yes, this is a hill I'm willing to die on

[Meow]

Metal Detector can be a CCP as Metal pieces can enter through raw material and machines.

Thanks Mohammed, I agree, but at this point they don't have a metal detector, it will for sure be a ccp if they have a metal detector in place.

[Meow]

Greetings Meow,

 

A question first. Does your popping step include some medium (eg oil) or just air heating?

 

In order to reach the 355^oF then the center of the kernel should propably have reached the ~162^oF required for pasteurization and this temperature should be lasting for at least 12 seconds throughout the process.

Point is that you don't seem to have another kill step than the temparature - time control during the popping and the conditions are there (maybe even exceeding them) for it to be considered a CCP. Cross contamination from unclean kettle is highly unlikely at these temperatures, at least microbiological ones.

 

Regards!

Thank you Evans. The popping step include medium - Canola Oil.

 

Yes, from my pespective, the popping step is the only step that can kill the microbes, I wonder if there is any way that we will be able to verify the core temperature per popcorn reached up to minimum 162'F to declare that potential microbes are killed during popping step. Once the popcorn are popped, the water activity of each popcorn will be very low that wouldn't support microbes to growth. So I even wonder should I put cooling step as the process control..

[Meow]

Hi Scampi,

 

Thks for attempting clarification.

 

I tried some googling around "PCP" and ended up here -

 

https://inspection.c...7/1512152952810

 

I also downloaded the claimed "Help" text offered here -

 

https://inspection.c...492029286734#a2

 

Above is an absolute gem of, IMO, gobbledegook !

 

I get the overall impression, ie speculate, that the net result is that -

 

(1) the terminology "HACCP" has (amazingly !) almost no current FS usage in Canada anymore.(zero search hits for "HACCP" in above pdf) (***)

(2) the well-known "FSEP" manual is now obsolete and is no longer Canadian FS relevant.(zero search hits for "FSEP" in above pdf) (***)

(3) the so-called PCP (ie 1st link above) has totally replaced (1,2).(***)

 

(***) With the virtually single exception for anyone who has the Patience/Fortitude to reach the last section  of 2nd link above

 

Does the PCP aspect over-ride SQF (traditional) HACCP options  ?

 

Based on some of the terms appearing in OP, I'm not sure whether the OP appreciates all the above subtleties, does - Meow ???.

 

 

Sorry Charles to split hairs but I respectively disagree

 

https://inspection.c...2/1525869759693

 

AND

 

https://inspection.c...08092049?chap=0

 

 

A PCP    IS   a GFSI plan

 

12 steps of HACCP no more and no less and yes, this is a hill I'm willing to die on

Hello Charles and Scampii,

 

Thanks for the discussion. Preventive Control plan is required for the firm that is doing interprovincial trade, export and import in Canada, and one of the requirement before the company apply for the Safe Food for Canadian Act license. 

 

Refer to: 

https://inspection.c...6/1427304469520

Preventive food safety controls address hazards and risks in such areas as:

• sanitation and pest control
• treatments and processes
• equipment
• maintenance and operation of establishments
• unloading, loading and storing food
• employee competence
• employee hygiene
• employee health
• complaints and recalls

 

It seems to me that these are considered as prerequisite program in US.

 

The other PC is process control, which is broadly used in HACCP plan, where there are some steps that does partial control to mitigate the risk but not the critical one, so those step can be considered as process control.

 

When I was writing the hazard analysis, after thinking, I want to make the changes as below:

 

 

1. Allergen information verification at receiving step (as we also have a allergen line in the same facility, thus there is might contain information on the packing bag) - CCP , no other step can eliminate the risk after this step.

2. Unpopped kernel warning information verification at receiving step (on the packing bag) to mitigate the risk of unpopped kernel - Process Control (PC), it's more quality concerns other than food safety concerns.

3. Popping step (Temperature Control); During poping process, there is another biological hazard I declared as "cross-contamination from the uncleaned kettle" and will be addressed by sanitation program and employee Training. Verify by daily or weekly ATP check. CCP , no other step can eliminate the risk after this step. I am kind of confused here as after heating, the popcorn will be cooled down on the sifting table, there is chance to contamination again after popping step due to insanitary sifting table, but at the same time, the Aw of popcorn will be very low, which won't support the microbes growth even contaminated...  I really not sure which step is CCP.    

4 &5. Cooling and Sifting Step (Cool down within 2 hours, and sift out the unpopped kernel - this one I don't think it is necessary, as we also declare the warning on the packing bag, still it doesn't hurt) 

[Charles.C]

Hi Meow,

 

Thks yr response.

 

I had a look at yr linked "Importer's Guide" page.

It appears that Canada are attempting to eradicate the term "HACCP' from their primary FS textual information (ot a single appearance of this fundamental FS terminology, similar to my analogous observations in Post 7.)

Despite this "Re-education", I suggest you might usefully look at the downloadable (HACCP) Codex 1969/2020 revision document.

 

No offence intended but I get the impression that you have limited technical experience with HACCP Plans (or any of the Canadian "Equivalents") ?.

Some of your queries are discussed in detail in basic HACCP texts but do tend to require some fairly in-depth background study. There are also several previous threads here discussing HACCP-related aspects of the popping process, eg -

 

https://www.ifsqn.co...orn-haccp-plan/

(2023)

https://www.ifsqn.co...al/#entry127998

(2018)

https://www.ifsqn.co...ry/#entry105008

(2016)

https://www.ifsqn.co...limits-popcorn/

(2012)

 

As you can see, it may be necessary to make a few assumptions to simplify the HACCP Plan (>>>PCP).

 

You might also consider  using a Consultant familiar with Canadian "HACCP" if a rapid PCP-compliant solution is sought.

 

PS - IIRC the US Popcorn Association (or name-related Organisation) offer a free HACCP Plan to their members. Maybe something similar in Canada.

 

PPS - this instrument article maybe of interest -

 

https://www.yourbest...-popcorn-maker/

[Evans X.]

Hello Meow,

 

There are ways to measure it on the spot, as it will cool up very fast if you take samples and carry them to another area. But it is kind of self-proven since the popping temperature is sigificantly higher, taking into considertion also the nature, size and the fact that each popcorn opens up.

In my opinion I don't think a cooling step is necessary, unless you want to speed up the process.

[Meow]

Hi Meow,

 

Thks yr response.

 

I had a look at yr linked "Importer's Guide" page.

It appears that Canada are attempting to eradicate the term "HACCP' from their primary FS textual information (ot a single appearance of this fundamental FS terminology, similar to my analogous observations in Post 7.)

Despite this "Re-education", I suggest you might usefully look at the downloadable (HACCP) Codex 1969/2020 revision document.

 

No offence intended but I get the impression that you have limited technical experience with HACCP Plans (or any of the Canadian "Equivalents") ?.

Some of your queries are discussed in detail in basic HACCP texts but do tend to require some fairly in-depth background study. There are also several previous threads here discussing HACCP-related aspects of the popping process, eg -

 

https://www.ifsqn.co...orn-haccp-plan/

(2023)

https://www.ifsqn.co...al/#entry127998

(2018)

https://www.ifsqn.co...ry/#entry105008

(2016)

https://www.ifsqn.co...limits-popcorn/

(2012)

 

As you can see, it may be necessary to make a few assumptions to simplify the HACCP Plan (>>>PCP).

 

You might also consider  using a Consultant familiar with Canadian "HACCP" if a rapid PCP-compliant solution is sought.

 

PS - IIRC the US Popcorn Association (or name-related Organisation) offer a free HACCP Plan to their members. Maybe something similar in Canada.

 

PPS - this instrument article maybe of interest -

 

https://www.yourbest...-popcorn-maker/

 

 

Hi Charles,

 

Thanks for the reply. Can you share the link access to the US Popcorn Association. I googled, but couldn't find any website related to it.

 

I think to make all those assumption, validation study need to be done in order to declare it as non CCP. 

 

From the few post you shared, yes, you can control entry of salmonella or alfatoxin through supplier control program (Which is preventive control in Canada, and Prerequisite in US), but through the process, there are still ways that the product can get contamination from E.coli, Salmonella, Listeria through mishandling or condensation, cross-contamination.

The reason why I was thinking to make Popping as CCP as popcorn requires at minimum 355'F to pop, I was trying to find some scientific paper to research to validate the bacteria will all get killed at certain temperature and time, and I use Combase for deactivation proof. At the same time, I was thinking initial validation study of popcorn Aw is necessary, as you will be able to justify the low Aw wouldn't support micro growth. If in this case, I don't think poping need to be a CCP.

 

Thanks

[Meow]

Hello Meow,

 

There are ways to measure it on the spot, as it will cool up very fast if you take samples and carry them to another area. But it is kind of self-proven since the popping temperature is sigificantly higher, taking into considertion also the nature, size and the fact that each popcorn opens up.

In my opinion I don't think a cooling step is necessary, unless you want to speed up the process.

 

Hi Evans, 

 

We speed up the cooling process, if the cooling is not sufficient before packing, humidity will form in the bag, and affect the crunchy texture. 

 

With the Aw of the popcorn after poping, it won't support microbe growth. We may need to do a testing to validate the popcorn Aw to declare cooling is not CCP. How do you think?

 

Thanks

Meow

[Charles.C]

Hi Charles,

 

Thanks for the reply. Can you share the link access to the US Popcorn Association. I googled, but couldn't find any website related to it.

 

I think to make all those assumption, validation study need to be done in order to declare it as non CCP. 

 

From the few post you shared, yes, you can control entry of salmonella or alfatoxin through supplier control program (Which is preventive control in Canada, and Prerequisite in US), but through the process, there are still ways that the product can get contamination from E.coli, Salmonella, Listeria through mishandling or condensation, cross-contamination.

The reason why I was thinking to make Popping as CCP as popcorn requires at minimum 355'F to pop, I was trying to find some scientific paper to research to validate the bacteria will all get killed at certain temperature and time, and I use Combase for deactivation proof. At the same time, I was thinking initial validation study of popcorn Aw is necessary, as you will be able to justify the low Aw wouldn't support micro growth. If in this case, I don't think poping need to be a CCP.

 

Thanks

Hi Meow,

 

Re ^^(red) -  Sorry, I think the link was inside a popcorn pdf which i uploaded around 10 years ago but cannot find it in my archives. From a quick look on the IT may well have been "National Association of Popcorn  Manufacturers".

 

USFDA apparently consider the only significant micro. hazard in the popping process to be Salmonella, eg -

 

 FDA Draft Guidance Food Hazards, Popped Popcorn.pdf   113.98KB   14 downloads

Source -

 FDA Draft-Guidance-for-Industry--Potential-Hazards-for-Foods-and-Processes-(Appendix-1)-2.pdf   1.9MB   13 downloads

 

The above and its application within a popping  CCP appears to be confirmed by the opening post in another popcorn thread -

https://www.ifsqn.co...on/#entry124768

 

JFI, this is a classic (2012) document on Validation of Pathogen Reductions -

 

 Validating the Reduction of Salmonella, etc in Heat Processed Low-Moisture Foods.pdf   4.59MB   11 downloads

 

Again, JFI here is a Flowchart/CCPs/Product Spec. for salted, (to be) microwaved popcorn -

 haccp plan for salted,RTC, popcorn.pdf   555.22KB   12 downloads

[Meow]

Hi Meow,

 

Re ^^(red) -  Sorry, I think the link was inside a popcorn pdf which i uploaded around 10 years ago but cannot find it in my archives. From a quick look on the IT may well have been "National Association of Popcorn  Manufacturers".

 

USFDA apparently consider the only significant micro. hazard in the popping process to be Salmonella, eg -

 

FDA Draft Guidance Food Hazards, Popped Popcorn.pdf

Source -

FDA Draft-Guidance-for-Industry--Potential-Hazards-for-Foods-and-Processes-(Appendix-1)-2.pdf

 

The above and its application within a popping  CCP appears to be confirmed by the opening post in another popcorn thread -

https://www.ifsqn.co...on/#entry124768

Thank you Charles.

 

But, page 221 of Source -

 FDA Draft-Guidance-for-Industry--Potential-Hazards-for-Foods-and-Processes-(Appendix-1)-2.pdf

Shows that Bacterial pathogen survival of a lethal treatment as one of the hazard of popped popcorn. 

 

I couldn't find any research done for the pathogen lethality rate of popcorn production. I found one research about salmonella survival in conventional cooking process in popcorn production. https://pubmed.ncbi....h.gov/16793250/

 

There are tons of research of pathogen lethality in meat production. Wonder if I can use those research.

 

Related research I found: 

https://royalsociety.../rsif.2014.1247

Thermal Inactivation Studies of Escherichia coli O157:H7, Salmonella, and Listeria monocytogenes in Ready-to-Eat Chicken-Fried Beef Patties - ScienceDirect

69_567.pdf (cerealsgrains.org)

[Charles.C]

Thank you Charles.

 

But, page 221 of Source -

 FDA Draft-Guidance-for-Industry--Potential-Hazards-for-Foods-and-Processes-(Appendix-1)-2.pdf

Shows that Bacterial pathogen survival of a lethal treatment as one of the hazard of popped popcorn. 

 

I couldn't find any research done for the pathogen lethality rate of popcorn production. I found one research about salmonella survival in conventional cooking process in popcorn production. https://pubmed.ncbi....h.gov/16793250/

 

There are tons of research of pathogen lethality in meat production. Wonder if I can use those research.

 

Related research I found: 

https://royalsociety.../rsif.2014.1247

Thermal Inactivation Studies of Escherichia coli O157:H7, Salmonella, and Listeria monocytogenes in Ready-to-Eat Chicken-Fried Beef Patties - ScienceDirect

69_567.pdf (cerealsgrains.org)

 

Hi Meow,

 

^^(red) - Yes, this viewpoint is a typical, haccp logic basis for setting the step to be associated with a CCP,

 

It seems there are no Salmonella Lethality Charts in the FDA Fishery Hazards/ECC chillled foods so maybe US meat charts are only option..

Offhand, any value over 75degC usually equates to instantaneous Salmonella elimination if representative of the slowest heated point. The values needed for popping look well over this level but obviously some validation required eg pdf in Post 16 or latest version.
 

Edited by Charles.C, 02 June 2023 - 07:08 PM.
edited/corrected