5 replies to this topic

[Bevsafety]

hello!

i am struggling to determine what my CCPs would be for non-alc beer and soft drinks. i have read every forum but can't seem to find the insight i am looking for, so i'm hoping someone can help me out:)

 

1. non-alc beer is flash pasteurized and requires <4.5 pH. we specifically target this pH to control pathogenic risks (survival). we pasteurize mostly for stability although is does eliminate the risk as well. but, because it's flash, the pH is really what will prevent growth in package should a contamination occur in packaging (which we have controls and testing for).

 

2. soft drinks are not pasteurized, but contain preservatives and require the <4.5 pH.  I believe the pH in this case would be the CCP and the preservatives are the PC as they are there is stifle any growth and extend the shelf life.

 

 

in both cases the pH "CCP" testing would be prior to packaging as a positive release measure. the products would be tested for pH, micro, CO2, etc. once packaged again just to verify no contamination occurred from tank to package (chem, etc.).. 

 

any different perspectives on this? 

 

thanks!

[AltonBrownFanClub]

Depending on your process, I might be tempted to also include labeling as a CCP.

 

Incorrect packaging was the main cause of recalls in 2024 in the United States.

It would just be a shame to make perfectly "safe" food, only to cause an allergic reaction. 

 

(Disregard if you have no allergens or you already consider this step a PC/PRP)

[GMO]

I would not include pH nor labelling as a CCP.  I would support either being a preventive control or an oPRP if you have allergens for the latter, if not, then it's neither to my mind.

 

Both pH and labelling are adequately controlled in a system like that as a prerequisite and if prerequisites are in place and controlling that hazard step one on the codex decision tree would point it towards not being a CCP. 

 

The pH would suggest the flash pasteurisation is not food safety to my thinking but it would be good to sense check that.  What would happen if you didn't pasteurise it?  Is it about inactivation of the yeast rather than food safety reasons?  Could that cause your cans or bottles to explode without it?  If not and you're only pasteurising for quality reasons, again not a CCP.

 

Just on an aside those flash pasteurisers in beverage are really interesting and it's worth getting your head around what happens if it goes into divert and doesn't reach the temperature required.  Put it this way, the designs vary a lot and some would not be deemed acceptable for dairy...

[Bevsafety]

Interesting!

 

Labels i haven't considered for PC or CCP, so i will have another look at that, for sure. 

 

 

From a more general viewpoint, If i just look at pH from a CCP definition perspective, then it is a CCP even though it's full controlled.

 

Following the 2023 decision tree, i feel like ALL critical steps can be covered with GHP (Fundamental measures and conditions applied at any step within the food chain to provide safe and suitable food). my pH step could be covered under this, but couldn't cooking steps, hot fills, metal detection, etc all be justified as fully covered with PRPs/GHP (recipes, equipment, process control, training, sanitation, etc.)

 

I guess my big question is, how do you best despiser between "i have this fully covered"  vs. "This is a step at which a control measure or control measures, essential to control a significant hazard, is/are applied in a HACCP system"? what if it's both?

 

In this case, the pH is fully covered with PRP, but, the pH is also essential to control significant hazards that has been applied (pH adjustments, etc) - so decision tree tells me it's not a CCP, but the CODEX definition tells me otherwise. 

 

The way i was taught to look at it, was if you have any step that will kill/protect your product from pathogens, it's a CCP regardless of whether you have it fully controlled, because essentially, and with this reasoning once you put those monitoring steps in place, a CCP becomes fully controlled and therefore no longer a CCP.

 

Do you have any way of approaching this that helps one decide CCPs?

[GMO]

I think this muddle you're currently in is largely created by FSMA.  At least to my understanding, global control is pretty clear on CCPs and governed by Codex definitions.  Yes there are nuances but no absolutely you do not need a CCP just because it's controlling a microbiological hazard.

 

Let me give you some examples.  In a ready meal factory you will have cooking of, say chicken - yep, CCP.  Cooking of a sauce - same.  But you will also have barrier control - nope, prerequisite.  You'll have planned preventive maintenance (which is a control for pathogens as well) nope, prerequisite.  Sanitation - nope, prerequisite.

 

Some of these will be "preventive controls" in FSMA speak.

 

The adequacy of your control is for you and the HACCP team to investigate.  But I think it's entirely possible you have minimal (if any) CCPs and I certainly wouldn't name pH as one.  Filtration, possibly.  

 

It's not necessarily "wrong" per se to have something as a CCP which Codex would define as not one, but I think it gets you into a sticky situation.  No pun intended.  At what point are you going to separate safe from unsafe with your pH and how much would you have to overdilute for this to happen?  Probably quite a lot.  

 

I do think the preventive controls approach has benefit.  Too many HACCP practitioners don't give enough attention to prerequisites and prerequisites does not mean "hey we don't give a stuff about this control!"  But CCPs which are difficult to monitor in real time are a pain and probably better suited to being prerequisites if that doesn't sound a**e about face!  I'm guessing you are measuring the pH of the beer before you finish the fermentation?  And the soft drinks you'd be making a syrup to recipe and diluting on the line?  All sounds very "prerequisite-y" to me.  But I do appreciate that there are decades of what I'd call "bizarre decisions" for CCPs on HACCP from people with decades of experience.  I remember once a chocolate mould breakage procedure was assigned one in a factory I visited in that if that procedure wasn't followed, it could result in plastic contamination.  Er...  Nope.  Not to my training and experience.

 

But ultimately as long as you can evidence what you do and why, as long as you're not tying yourself up in knots because you've got something really hard to monitor then... I'd never raise it as a non con as an external auditor because that falls into my "hey it's not how I would do it but it still works" category.

[Bevsafety]

this is helpful insight, thanks GMO!