CCP for shelf stable (ambient storage), Ready to eat High acid sauce (pH <4.6) without lethality step.
Our company produces shelf stable (ambient storage), Ready to eat High acid sauce (pH <4.6) without lethality step. Based on our process flow, we have set the pH as a CCP1 at acidification step and metal detector as CCP 2 after packing. But recently an auditor disagree, he comment pH and metal detector can’t be CCP, we need to reevaluate process flow with new CCP. What is your opinion?
Hi Kerry,
:welcome:
Welcome to the IFSQN forums.
Whilst the pH will be very important your control will be by product formulation as well so the CCP will be based on pH and formulation. for example, see link and information below.
Some people get hung up on whether metal detection is a CCP or not, as long as it is performing its job as intended I would not worry too much.
NSW Food Authority - Shelf stable acid preserved foods
CONCLUSION
Thermally processed acid or correctly acidified products have a long history of food safety.
Their shelf stability is well understood as are the occasional spoilage issues. In contrast,
• botulism has been attributed to poorly acidified foods, and
• the factors affecting the shelf stability of foods that are not thermally processed are far more complex.
Unless demonstrated otherwise, cold pack acid preserved products will be considered to be perishable and dependant on refrigeration to extend shelf life.
Kind regards,
Tony
Hello!
Metal detection on whether or not it's a CCP has been discussed a lot on this forum. If you search around you will find threads on it. Unless you operate to ISO 22000, i.e. you use oPRPs, then I personally see it as difficult to argue it's not a CCP, the equipment is specifically there to detect and remove metal contaminants. BUT it's also a good argument to say it's not 100% effective and not your only control against metal. (But that doesn't preclude it being a CCP.)
On pH, I'm inclined to agree it's probably not a CCP. But thinking about it, I have to admit I'm finding it hard to articulate why. I'd have no problem with a temperature being a CCP and you could measure a sample from each batch. Total acidity development in cheese making is often a CCP as well for example.
Ultimately though, it's your decision as a HACCP team on what is and isn't a CCP in your process. Some things will be more obvious than others. But ultimately I think HACCP has failed in its intent. Whether or not something is a CCP, how much does it actually matter in the big scheme of things? The reason it was brought in was to put focus on areas of your process where failure was both likely and potentially catastrophic. BUT when you think about it, what actually fails nowadays? It's not normally CCPs or not them directly but the other processes around them. E.g. PPMs, cleaning processes, packaging controls.
But it's your plan and your decision at the end of the day.
I think the argument is that pH can be a CCP if it is something that is being controlled or manipulated. If your product is naturally acidic, than pH is just a characteristic. If you are adding an ingredient to lower the pH of the product to a specific range, like in fermentation, then it's more likely a CCP.
I think the argument is that pH can be a CCP if it is something that is being controlled or manipulated. If your product is naturally acidic, than pH is just a characteristic. If you are adding an ingredient to lower the pH of the product to a specific range, like in fermentation, then it's more likely a CCP.
Thank you for denoodling my thought process. I think that's exactly it.
If you don't have a lethality step, I'm inclined to agree with the auditor, that the acidification is not a CCP.
Hi Kerry,
With regards to pH, if you have identified that it is a step in your process that is required to prevent a food safety hazard then it can be a CCP. I am not familiar with your product or process, however Clostridium Botulinum has been associated with sauces and pH can be used to control this hazard. If your severity, likelihood and CCP determination clearly state a specific microbiological food safety risk such as this, then I do not see how an auditor could question your CCP.
Industry standard to have metal detection as CCP although can always be argued either way. Just easy to have it as one unless you have no metal in your process and neither do your suppliers.
If you don't have a lethality step, I'm inclined to agree with the auditor, that the acidification is not a CCP.
I'm struggling to understand your logic here SHQuality :uhm:
Surely if there isn't a lethality step then the pH and product formulation are more likely to be CCPs?
Kind regards,
Tony
Thanks everyone for the juicy information.
Thanks everyone for the juicy information.
I think pH has to be a CCP. My guess, from the information given, is it is the only thing preventing the growth of pathogens.
If your product is mayonaise, it is most likely safe because you are using pasteurized eggs and ph is low. there may be other factors such as salt an water activity that play a role as well.
I dont understand why auditors feel the need to criticize risk assessments or CCPS with out giving explaintations (maybe they did and you didnt share). At least they should be able to state "you are not adequately controlling X hazard, due to X, etc". The "nope, try again" approach makes not sense to me.