İn My opninion ;
Scenario 1: Cold Dressing Process (No Cook Step)
Question: Is the acidification step considered an oPRP or a CCP?
Answer: It is almost certainly a CCP.
Reasoning:
In a process with no kill step (like cooking), the acidification step is the primary, and often only, control for preventing the outgrowth of pathogenic bacteria (e.g., Salmonella, E. coli., Listeria). The safety of the product is entirely dependent on achieving a pH low enough (typically below 4.6) to prevent the growth of these pathogens.
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Hazard: Biological (pathogen survival and outgrowth).
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Control Measure: Lowering pH to a specific, validated target (e.g., pH ≤ 4.2) within a specified time.
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Critical Limits: A specific pH value and a maximum time to achieve it.
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Monitoring: Continuous or frequent pH checks.
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Corrective Action: Divert and hold the non-compliant product for rework (by adding more acid) or discard it.
Because this step is absolutely essential to product safety and its failure would render the product unsafe, it meets all the criteria for a CCP.
Is the cooking step considered as a CCP?
Answer: Yes, the cooking step is very likely a CCP.
Reasoning:
The cooking step is specifically designed as a "kill step" for microbial pathogens. This is a classic example of a CCP.
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Hazard: Biological (pathogens in the spices and other ingredients).
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Control Measure: Application of heat for a specific time and temperature.
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Critical Limits: A minimum temperature and a minimum hold time at that temperature (e.g., 165°F for 15 seconds).
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Monitoring: Continuous temperature recording via a chart recorder, with frequent manual checks.
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Corrective Action: Hold the undercooked product, recook if possible, or discard.
Question 2: With a validated kill step (cooking) in place, is the subsequent acidification step an oPRP or a CCP?
Answer: It is most likely an oPRP.
Reasoning:
Once the significant biological hazard (pathogens) has been controlled by the cooking CCP, the primary food safety function of the acidification step is diminished. However, it is still crucial for the following reasons, which align it with an oPRP
Scenario
Cooking Step
Acidification Step
Rationale
1. Cold Process (No Cook)
Not Applicable
CCP
It is the only control for preventing pathogen growth. Failure = unsafe product.
2. With a Cook Step
CCP
oPRP
Cooking is the primary kill step (CCP). Acidification is a secondary barrier for spores and controls spoilage (oPRP).
These are logical conclusions based on standard HACCP principles. The final decision must be made by your facility's HACCP team based on a thorough hazard analysis of your specific product, ingredients, process, and intended use. This analysis should be documented in your HACCP plan.