CCP controlled by a third party

Hello, I hope somebody has experience with this. The company i work for is outsourcing HPP processing for 5 log reduction in juices. Generally, my experience is when your company does not control a CCP and pass this to the costumer. The company get a letter of the costumer is aware that CCP has not being controlled and they are going to deal with it later. What is the requirement (or if there is not requirement) a good practice for when you deal with your CCP being outsourced? I am not asking about the supplier documentation side of this. I know as a third party we need to get all the documents for the supplier. My question is related to the CCP itself, records for the CCP, anything related to this? 

If you have approved them as a supplier, you shouldnt have to have their CCP documentation on hand, surely? You could have a contract which states clearly the expectations, further you could verify under a supplier audit. You also need to include this outsourced process in your own HACCP plan. 

That's true M YUSUF, they are either a supplier, or a supplier of a service (outsourced processing), depending. They are an outsourced process if it leaves your site, gets processed, then comes back to your site. 

There is a specific claus which covers outsourced processing. You need to ensure that this step is covered in the HACCP plan. The supplier of this service needs to ensure that the product is processed according to YOUR defined parameters and expectations. Their should be a written agreement as to how they handle the product/service specification. 

Hi Estrellita3,

My question would be, is it a CCP? If your customer is further processing the juice to reduce the same hazard then I would suggest that it is not.

Also, for significant hazards controlled by the supplier, the appropriate supplier verification activity is an onsite audit of the supplier not just documentation.

Kind regards,

Tony

...

My question would be, is it a CCP? ...

If it is not happening at your facility or under your physical control, I don't see how it could be identified in your HACCP documents as a CCP.  When it leaves or someone else physically takes over, it's inherently out of your control.  The lethality is occurring after it exits your flow chart.

Labeling the container as requiring thermal lethality might be identifiable as a CCP -- we've done a labeling step as CCP for a further processing item.

Similarly, if this juice is then coming back to you for bottling etc. after the lethality is performed it is no different than newly purchased ingredients, which you would require LOG/COA type documentation for.

If it is not happening at your facility or under your physical control, I don't see how it could be identified in your HACCP documents as a CCP.  When it leaves or someone else physically takes over, it's inherently out of your control.  The lethality is occurring after it exits your flow chart.

 

Labeling the container as requiring thermal lethality might be identifiable as a CCP -- we've done a labeling step as CCP for a further processing item.

 

Similarly, if this juice is then coming back to you for bottling etc. after the lethality is performed it is no different than newly purchased ingredients, which you would require LOG/COA type documentation for.

 I completely agree to GM's opinion.

I worked for a facility that processed walnuts which can either be used as an ingredient that would undergo further processing or eaten raw as it is. We used to outsource lethality in the final product upon customer's request. It was identified in the HACCP plan as an optional step that would be outsourced upon customers request only and not the CCP.

The product would come back from the outsourced company with a proof that lethality was complete or a COC. Apart from that, it was a part of our approved supplier program and would provide other documents as regular ingredient suppliers. We would however test the final product for target microorganisms before releasing the final product to customers.

Thank you so much for all your comments. It has been really helpful. We are doing cold press juices and sending to for HPP. the third party company is used for HPP and shipping. the product does not return to us. Anyways, after reading your comments i have a better idea on how to do this.

Hello, I hope somebody has experience with this. The company i work for is outsourcing HPP processing for 5 log reduction in juices. Generally, my experience is when your company does not control a CCP and pass this to the costumer. The company get a letter of the costumer is aware that CCP has not being controlled and they are going to deal with it later. What is the requirement (or if there is not requirement) a good practice for when you deal with your CCP being outsourced? I am not asking about the supplier documentation side of this. I know as a third party we need to get all the documents for the supplier. My question is related to the CCP itself, records for the CCP, anything related to this? 

Firstly, I'd highly recommend not outsourcing a CCP as that adds unnecessary points for contamination, adulterants, etc. but if its a costly process (IK HPP can be) I'd require the person or 3rd party performing the CCP to have all the documentation follow specifics I'd need/feel necessary to track.

If the cost is driving this decision, I'd advocate to bite the bullet and purchase the equipment as it will save you money in the long haul...

https://www.jbtc.com...re-processing/?

gclid=CjwKCAjwloynBhBbEiwAGY25dFdNSYprPl2mPNhzPBobdiiBa3u7ynhqkmFIKAMxhQjPvk8ZpinCWBoCobEQAvD_BwE

^ added link to HPP equipment