CCP management

Hi:

I found some HACCP using this approach for cooking and metal detector's CCP.

ei cooking: CL internal Tº at the end of the cooking. ..."if internal Tº it's below the CL the product it's hold on the cooking chamber until it reach the CL".
This way the ccp never goes out of control; the operator don't fill any record becuase the final product meet the CL always.. so it's safe.

or ie metal detector: CL correct function..."if the metal detector it's activated by a contaminated product... reject the product"; but the CCP was always in control because metal detector it's OK.
The CCP it's out of control when you monitor the metal detector's functioning with ferrous patterns and the machine fails to detected it.

I think at list you shut record every time you need to extend the cooking step or when a product it's rejected by the metal detector.


PD: a chilean HACCP expert told me that in the future risk matrix will be replaced by a factory full risk assessment... are you doing this right now in Europe???

Dear Al,

As you imply, the fundamental cooking requirement is derived from a temp/time function. Some processes implicitly or explicitly include a holding step to ensure the overall heat treatment is adequate. Not too sure how the US’s liking for things like underdone hamburgers fits into this scheme.

Another popular alternative to yr suggestion is to use “operating limits”, eg –

As a practical matter it may be advisable to set an operating limit that is more restrictive than the CL. In this way you can adjust the process when the operating limit is triggered, but before a triggering of the CL would require you to take corrective action.
You should set operating limits based on your experience with the variability of your operation and with the closeness of typical operating values to the CL.

( http://seafoodhaccp....le_pdf/Ch20.pdf )

This aspect and other typical general requirements related to the Critical Limit are rather neatly described in the link below which is one of a series of, IMO, well-presented, concise, HACCP articles –
http://edis.ifas.ufl.edu/FS141

With regard to the metal detector, there hv indeed been various interpretations as to suitable methods of setting of the CL. I suppose as long as you can satisfactorily validate……. Some practical variations / consequences are discussed in detail in the first link above. (although developed for seafood, the comments are actually quite general).

a factory full risk assessment

Meaning ??

Rgds / Charles.C

Hi Al,


In the "requirements for a HACCP-based food safety system", issue 4, June 2006 and in ISO 22K:2005 recording of CCP-checks is mandatory.

However there cannot be a failure in the CCP of Internal Temperature, it still has to be recorded, and (for the requirements) signed by the responsible operator.
Probably you wish to know how often the operator has to hold or reheat the products. You can use this both in the verification and for improvement of the efficiency.

So, short: You have to record the temperatures and the corrective actions if the temperature is not satisfaction.

For the metal detector, the check on the metal detector functioning is the CCP. So you should record the results of the tests and the corrective actions taken when the detector is out of spec. Don't forget to record time or product code, so you can trace back the not proper detected products.
For verification you also should record the rejected products and the cause of the rejection.
Every, by the detector, rejected product, is a non-conforming product and cause investigation and corr3ective actions to prevent re-occurrence are necessary.

Like Charles, I do not understand what is meant by a factory full risk assessment. Risk analyses should be based on the factory. Is that what you mean?

Certified regards,

Madam A. D-tor

"a factory full risk assessment" mean.... a risk assessment based on factory process' result, estatistic control's process, and so on.

Dear Al,

Thks yr clarification. Estatistic?? Sounds exciting.

Do you mean that the auditor will give a risk prediction as to his / her “confidence” in the results of various processes actually running in the factory (presumably with particular relevance to the HACCP system including all GMP etc functions??).

Sounds like an implicit assessment of the validity of validation and verification procedures.

Or FMEA ?

Or are you referring to a requirement for a full implementation of the wider topic of risk management.?

None of those ??

Rgds / Charles.C

Hello Al bundy,

I think it's quite right - regarding to CE 2073/2005. Up to now, you had required national regulatories for instance for cooked meats; there were 6 microbiological parameters for cooked meats. Since 2006 only 1 or 2 required bu european legislation; but you have to set a real Haccp study to know in your factory you don't have another issues, to assess your risks and to determine microbiological analysis you have to check

I think that was what your expert told you about it.

To me it's right, because anyone has to apply a real Haccp study, not a 'pseudo'Haccp study,

Regards,

Emmanuel.

thanx Penard... you read my mind.

now, are you doing this in Europe or still attached to the old "not quantitative" HA.

http://www.foodsafet...u/PDFs\Cook.pdf

http://www.fao.org/D...1579e04.htm#bm4

codex say what to do but not how....and I want to learn

Dear Al,

Regarding the use of types of qualitative/quantitative risk assessment, this fao link (2004) is bit more practically oriented. -

http://www.fao.org/d...2e/y4722e00.htm


As I'm sure you know, there are several specific QRAs detailed on the net (hence for example the relatively recent changes in legal requirements for L.mono in RTE foods.) A major difficulty for pathogens is always to get reliable data and to generalise the results,. Ecology resists standardisation perhaps.

Regarding full risk assessment, I interpret previous posts as referring to the situation of "generic vs actual haccp analysis." Frankly, IMO, this is partly due to things like auditor checklists with expected answers. Attempts to present other than traditional CCPs are instinctively frowned upon. eg Labelling as a CCP is a good one to provoke arguments IMEX.

Rgds / Charles.C

Hello Al bundy,

Real difficulties to apply Codex : wherever you are it's pretty difficult to locate right information and good advisers. Moreover when you don't belong to quite big factories or firms.

Unfortunately I had same issues than you to locate right information : our national inspectors just visit factories in order to be sure it's safe, but they do not have to give us some information - although they know much more than you.

To me, 2 tracks to learn more :

- you are able to be a potential customer for suppliers. So don't hesitate to make appointments with them, ask them some accurrate questions; you can compare from one reply to another one and determine who is the best supplier - and adviser for you. Then it's up to you to check if you can let them become suppliers of your factory. This way of learning is very precious for little factories.

- second...this kind of forum and people you meet - with forums, congress...is appreciated to improve one's knowledges.

Hope it helps,

Regards,

Emmanuel.