11 replies to this topic

[makeeno]

Hi all I work at a bakery and we have 3 main CCPs: Allergen check, metal detectors and kill step for raw egg. We also do everyday batch sampling where we test RTE food at the end of the day. When we send the sample we hold onto the finished product until we get a COA then we release it for shipping. If the testing comes back bad we test again for other pathogens and if those return positive we destroy the product. We currently don't have this listed as a CCP but would this be considered one? We are preventing a risk by holding onto it until we receive a COA. Just wanted to get thoughts on this

[Dorothy87]

Hi, 

 

What type of product? I know you mentioned bakery.. but if yes then everything is fully baked? 

 

:)

[makeeno]

Hi, 

 

What type of product? I know you mentioned bakery.. but if yes then everything is fully baked? 

 

:)

It is filled eclairs and cream puffs and everything is post baked

Edited by makeeno, 15 December 2023 - 04:24 PM.

[kingstudruler1]

Random micro sampling and testing is not usually a CCP.  It only proves that the product that you tested is safe.   

 

There should probably be a kill step for the ready to eat product - that is your CCP.  ie How are other ingredients other than egg addressed as being safe (baking?)?   The testing of the final product would be a form of validation that your other biological controls are effective.   

Edited by kingstudruler1, 15 December 2023 - 04:35 PM.

[Dorothy87]

I see,

 

- is the cream prepared from raw material in the high-risk / high-care area from pasteurized milk, and all raw materials are checked at Goods in (COA etc)? 

- did you have any positive results ? if yes - which one ? , for example, Listeria would come from raw materials or the environment

- think about shelf life (inhouse and for customers plus delivery)  

 

I wouldn`t consider this as CCP, rather as positive release but this will dependent on micro results. 

You should be able to eliminate / reduce risk 

 

[jfrey123]

You can't test your way into food safety.  The kill step needs to be rock solid and followed perfectly to your validation to remain a CCP.  I've never run into an auditor that would entertain the idea that a finished good micro test is valid as a control measure, namely because it's far too deep in the process to prevent the hazard from occurring.

[makeeno]

You can't test your way into food safety.  The kill step needs to be rock solid and followed perfectly to your validation to remain a CCP.  I've never run into an auditor that would entertain the idea that a finished good micro test is valid as a control measure, namely because it's far too deep in the process to prevent the hazard from occurring.

 

No we have a kill step for the egg and we have metal detection. Im not worried about those I know they are CCP's. I was just curious if end product testing should also be a CCP in my HACCP plan or positive release? If its not a CCP why? Am I not reducing or a eliminating a product but not shipping it if the tests come bad?

[makeeno]

I see,

 

- is the cream prepared from raw material in the high-risk / high-care area from pasteurized milk, and all raw materials are checked at Goods in (COA etc)? 

- did you have any positive results ? if yes - which one ? , for example, Listeria would come from raw materials or the environment

- think about shelf life (inhouse and for customers plus delivery)  

 

I wouldn`t consider this as CCP, rather as positive release but this will dependent on micro results. 

You should be able to eliminate / reduce risk 

 

The cream is not high risk or prepared in high risk area. The raw materials all come with COA and checked. Never had a positive result always been negative. We hold onto the product until we received our results back. We do have a kill step for the egg batter. I was just wondering if the holding and testing was a CCP or like you said just a positive release. If it is a positive release why is it not considered a CCP if we are preventing and reducing a hazard by not shipping if results come back positive.

[kingstudruler1]

The cream is not high risk or prepared in high risk area. The raw materials all come with COA and checked. Never had a positive result always been negative. We hold onto the product until we received our results back. We do have a kill step for the egg batter. I was just wondering if the holding and testing was a CCP or like you said just a positive release. If it is a positive release why is it not considered a CCP if we are preventing and reducing a hazard by not shipping if results come back positive.

 

 

Testing does not control, prevent or reduce the hazard.   Testing only shows that the hazard is or is not in the sample tested.   

 

Maybe a poor analogy - it is the equivalent of only running a couple of packages through the metal detector to show that your product is free from metal.    

[jfrey123]

Testing does not control, prevent or reduce the hazard.   Testing only shows that the hazard is or is not in the sample tested.   

 

Maybe a poor analogy - it is the equivalent of only running a couple of packages through the metal detector to show that your product is free from metal.    

 

This.  Testing is also not representative of the entire batch, no matter how well you've composited the samples.  Validations of kill steps are required because testing is not sufficient to demonstrate the hazard has been eliminated.

 

Beyond that, a CCP is a step where if not properly followed, the product is likely to have the hazard pass to a customer (i.e. kill temp not reached, product likely will harbor pathogens).  If you didn't test your product before release, the lack of the test would not increase the likelihood of a hazard.  In practice, you can release the product without testing at all, and because of your CCP's ahead of time, that product should be pretty safe.  So if an entire step can be eliminated and not affect the product's actual safety, then you're hard pressed to argue that it is a critical step that must be controlled.

[makeeno]

This.  Testing is also not representative of the entire batch, no matter how well you've composited the samples.  Validations of kill steps are required because testing is not sufficient to demonstrate the hazard has been eliminated.

 

Beyond that, a CCP is a step where if not properly followed, the product is likely to have the hazard pass to a customer (i.e. kill temp not reached, product likely will harbor pathogens).  If you didn't test your product before release, the lack of the test would not increase the likelihood of a hazard.  In practice, you can release the product without testing at all, and because of your CCP's ahead of time, that product should be pretty safe.  So if an entire step can be eliminated and not affect the product's actual safety, then you're hard pressed to argue that it is a critical step that must be controlled.

Thank you so much. So since we can release product without testing, how often should I realistically be testing? We test every day but is that too much or too little?

[jfrey123]

Testing frequency is up to you depending on your program and customer requirements.  I'm just saying I don't think it's a valid CCP.