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CCP determination of critical limits

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qualitymanager

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Posted 09 June 2021 - 03:17 PM

Hello everyone, in our HACCP analysis we have loading as a CCP because we use container to transport our product (liquid) and we check for each container before loading if it is clean or no. The checking is only visual and olfactory. So how can  have a measurable critical limits? I put absence/presence of odours and dirt? Thank you for your advises



Scampi

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Posted 09 June 2021 - 03:37 PM

You need a certificate of washing-----odour and dirt are subjective

 

a tanker wash receipt is measurable---yes = you can load           no = refuse loading    

 

Curious how to reached CCP on this however???????   are the tankers used for non food liquids?


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kingstudruler1

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Posted 09 June 2021 - 03:40 PM

im not sure what hazard you are trying to control.    my opinion would be that that probably isnt a ccp.   absence of dirt and odours are subjective and would not be a good critical limit.     


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SQFconsultant

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Posted 09 June 2021 - 08:05 PM

If visual it contains no proof - thus you either knock it out and don't call it a cp or ccp.

 

If you want to stick with CCP I suggest Scampi's posting above.


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QA2021

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Posted 09 June 2021 - 08:21 PM

This is the last step of our production(loading) and as a control measures we have:
Checking of cleaning (odours, dirt)
Checking the wash certificate
Checking the list of the last loading

In this step we want tonbe sure that tankers are clean without ay chemical/physical or biological riks.
I m confused if i should consider it as a CCP or OPRP



QA2021

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Posted 09 June 2021 - 08:24 PM

im not sure what hazard you are trying to control. my opinion would be that that probably isnt a ccp. absence of dirt and odours are subjective and would not be a good critical limit.


We are trying ton control all hazard( chemical, physical and microbiological).
This is the last step of our production process and we need to be sure that tankers are without risks


QA2021

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Posted 09 June 2021 - 08:27 PM

You need a certificate of washing-----odour and dirt are subjective

a tanker wash receipt is measurable---yes = you can load no = refuse loading

Curious how to reached CCP on this however??????? are the tankers used for non food liquids?

Tankers are not used for no food liquids.We have a list of prohibeted loads and we ask our provider to give such list every time and we ask for a washing certificate. Before loading we check if tankers are clean. I don't know if it should be a CCP or OPRP


Charles.C

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Posted 10 June 2021 - 04:15 AM

We are trying ton control all hazard( chemical, physical and microbiological).
This is the last step of our production process and we need to be sure that tankers are without risks

 

Hi QA,

 

Perhaps French HACCP is atypical compared to typical International, eg Codex, HACCP ?

 

Assuming this is traditional Codex HACCP, potential hazards must be specifically safety related and not already controlled by PRPs within, for example, GMP.

 

The activities you describe are typically handled by PRPs.


Kind Regards,

 

Charles.C


QA2021

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Posted 10 June 2021 - 06:28 AM

Hi QA,

Perhaps French HACCP is atypical compared to typical International, eg Codex, HACCP ?

Assuming this is traditional Codex HACCP, potential hazards must be specifically safety related and not already controlled by PRPs within, for example, GMP.

The activities you describe are typically handled by PRPs.


Hello,

We are working according to ISO 22000 and the risk at this step is significant. The decision tree show that it should be OPRP or CCP. That's why


PQAManager

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Posted 10 June 2021 - 08:01 PM

You can use the decision tree for CCPs.  Also, you can have what you are doing as a CCP, and sign off on the CCP that there was not visual debris of any kind.  However, you can do a risk assessment and put it as low risk because of cleaning preventative maintenance and the visual inspection can be a preventive measure.  It's subjective and depends on auditor.



QA2021

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Posted 10 June 2021 - 08:09 PM

You can use the decision tree for CCPs. Also, you can have what you are doing as a CCP, and sign off on the CCP that there was not visual debris of any kind. However, you can do a risk assessment and put it as low risk because of cleaning preventative maintenance and the visual inspection can be a preventive measure. It's subjective and depends on auditor.


Hello,
I can't put it as a low risk because the liklihood is high. Every month we find tankers with problem of cleaning and we block them. And this is the last step


Charles.C

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Posted 11 June 2021 - 05:03 AM

Hello,

We are working according to ISO 22000 and the risk at this step is significant. The decision tree show that it should be OPRP or CCP. That's why

 

See iso22002-1.

It's a PRP 

End of Story.


Kind Regards,

 

Charles.C




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