2 replies to this topic

[KerryPlentong]

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?

[Tony-C]

Hi Kerry,

 

 

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

 

[GMO]

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.