Secondary - Primary Packaging CCP

Hi,

We are currently reviewing our HACCP and have an issue in determining if a process step is a CCP or if it is covered by PRP's.

The step is loading primary packaging into a machine from some secondary packaging, with the hazard being identified as physical contamination from the secondary packaging (in this case plastic from a torn liner). Historically this was covered by PRPs but we now believe, due to changes in plant capacity and manning, that the risk has increased and the PRPs are no longer adequate to mitigate the risk to the end user.

My understanding is that just because a process step did not used to be a CCP, does not mean that circumstances can't change and that it could become one. To make a (possibly poor) analogy, an operator could watch individual apples coming down a converyor and remove the bad ones. If capacity increases and the apples are suddenly six deep, he's going to have a hard time getting all the bad ones out. Since there is no 'subsequent step that will reduce or eliminate' the identified hazard and we no longer feel that the controls that are in place (PRPs) are sufficient, is this step a CCP or not?

Or have I answered my own question?

Your views would be greatly appreciated.

Seaotter.

Dear Seaotter,

When circumstances change, conclusions may also change. Fundamental HACCP.
Whether the result is yes or no depends on yr HACCP Plan formulation (eg product description, specific hazard, specific risk analysis [presumably for safety only ?]).
Eg –
How did you define PRPs ?
How much safety aspect is involved anyway ? (ignoring any regulatory aspect ??)
Have you already experienced a failure (s) ?

Rgds / Charles.C

When circumstances change, conclusions may also change. Fundamental HACCP.
Whether the result is yes or no depends on yr HACCP Plan formulation (eg product description, specific hazard, specific risk analysis

Welcome to the forums seaotter

Charles has it in a nutshell there, a review of an altered process should be taken as a clean sheet of paper.

Historically this was covered by PRPs but we now believe, due to changes in plant capacity and manning, that the risk has increased and the PRPs are no longer adequate to mitigate the risk to the end user

It seems as though you have indeed answered your own question there, if the HACCP review shows that risk is no longer adequately controlled and no subsequent step will control that risk either then you have a CCP. One point to bear in mind is that if the process step in question is indeed a CCP you need to establish critical limits and a method to measure the contamination from the seccondary packaging.