16 replies to this topic

[Maverick1985]

Hi,

 

Just quick question.

We have a sieves/filters fitted on chocolate tanks (3mm/10mm) Partly for quality, partly for foreign body removal.

All marked on process flow. However, last auditor mentioned, that if it is for food safety, foreign body removal reason, it should be a CCP.

But...Because it is early stage of the process (melting), I 'm not sure if it is CCP. at the end of the process we have a Metal Detectors fitted and this is the only CCP we have. (Process flow attached)

 

TIA

[kconf]

Hi Maverick,

You are correct. It is not CCP. 

[Maverick1985]

 

So in your opinion, How I can justify this is not CCP

[Marshenko]

 

So in your opinion, How I can justify this is not CCP

 

 

Do you have a subsequent step that would also control foreign material inclusion?

[kconf]

By definition CCP is a step at which control must be applied in order to prevent hazard as at will not be removed at a later step. In your case metal detectors at the end is a CCP because nothing happens after that. What may have been missed by tank's strainer would be caught by the MD in your flow. 

 

I hope this helps. 

[Maverick1985]

Do you have a subsequent step that would also control foreign material inclusion?

Sieve/filter on tank and another one on depositor, then nothing until metal detector

[kconf]

It is just a preventive measure rather than a control measure. It does contribute to food safety, but it is not a CCP. 

[Maverick1985]

By definition CCP is a step at which control must be applied in order to prevent hazard as at will not be removed at a later step. In your case metal detectors at the end is a CCP because nothing happens after that. What may have been missed by tank's strainer would be caught by the MD in your flow. 

 

I hope this helps. 

What about foreign bodies which are not metal detectable? 

[Maverick1985]

It is just a preventive measure rather than a control measure. It does contribute to food safety, but it is not a CCP. 

So should I keep it on process flow and Hazard Analysis list or remove in your opinion?

[kconf]

They are just PRPs. It is a basic food safety practice, just like prewashing agriculture products. 

[kconf]

I would keep them on flow diagrams to show that it passes through filters/magnets etc. along the line. I would only call MD as CCP. 

[gummybear2021]

Having worked in confectionery and audited the same all of the above is true.  I have used OPRP for the first stainer and metal detection as the CCP.  OPRP adds to operational excellance by proactively identifying and mitigating potential hazards.  You have increased your food safety and quality and demonstrated regulatory compliance.  All this is accomplished by your risk assessment.  What are you trying to control other than metal( foreign material?).  Hope this helps and adds to the above replies

[Marshenko]

Having worked in confectionery and audited the same all of the above is true.  I have used OPRP for the first stainer and metal detection as the CCP.  OPRP adds to operational excellance by proactively identifying and mitigating potential hazards.  You have increased your food safety and quality and demonstrated regulatory compliance.  All this is accomplished by your risk assessment.  What are you trying to control other than metal( foreign material?).  Hope this helps and adds to the above replies

 Good stuff here.

[Maverick1985]

Having worked in confectionery and audited the same all of the above is true.  I have used OPRP for the first stainer and metal detection as the CCP.  OPRP adds to operational excellance by proactively identifying and mitigating potential hazards.  You have increased your food safety and quality and demonstrated regulatory compliance.  All this is accomplished by your risk assessment.  What are you trying to control other than metal( foreign material?).  Hope this helps and adds to the above replies

Hi,

Any foreign bodies which may come from raw material we using. we are using chocolate buttons, melting them, then make a chocolate bars, truffles , etc. 

Buttons bags are approx 10-15kg, buttons going straight from bag to big tank, so to prevent potential foreign bodies coming from those chocolate buttons bag, we are using this sieves/filters fitted on chocolate tank's tap. Bags are made from material detectable on metal detectors, so I'm not worry about piece of bag in chocolate. More likely about whatever can be accidently packed by our supplier:)

[jfrey123]

You're using pre-manufactured chocolate to melt down into your new product, so you can refer to your supplier approval program and nature of the ingredient to show that FM is an unlikely hazard at this melting step.  Make sure you double check against your risk assessment tool, but a low likeliness generally requires a high severity to trigger a CCP for any point, and I'm struggling to think of any FM that would be a severe hazard from that input material.  I would focus on the fact the screens are there for quality purposes (sounds like to ensure large chunks of partially melted chocolate don't flow down the pipe), that basically the sieve's job isn't a requirement for safety.

 

The first HACCP plan I wrote was in a spice plant where we used sifters to sort product by particle size.  Auditors always wanted us to denote them as CCP's, but they were strictly for sorting to achieve the correct powder/granule size to meet a specification after a grind.  Yes, they were helpful in FM control, but that wasn't what they were there to do, and we used other methods downstream to control FM just like you describe.

[kconf]

Even if the chocolate used was not pre-manufactured and were blocks of liquor and butter, it would still not be a CCP. The screens/sifters also help block occasional plastic, paper material (from liquor, butter, sugar packaging) from getting further down the line. 

Edited by kconf, 03 October 2024 - 05:51 PM.

[zuoli]

i think the process is OPRP