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No CCPs in a HACCP Plan - Can This Be Possible?

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Poll: How many CCP's in your HACCP System? (1042 member(s) have cast votes)

How many CCP's in your HACCP System?

  1. Voted 0 (Zero) (320 votes [30.68%])

    Percentage of vote: 30.68%

  2. 1-2 (419 votes [40.17%])

    Percentage of vote: 40.17%

  3. Voted 3-4 (192 votes [18.41%])

    Percentage of vote: 18.41%

  4. 5-6 (72 votes [6.90%])

    Percentage of vote: 6.90%

  5. 7-8 (17 votes [1.63%])

    Percentage of vote: 1.63%

  6. 9-10 (9 votes [0.86%])

    Percentage of vote: 0.86%

  7. More than 10 (14 votes [1.34%])

    Percentage of vote: 1.34%

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* * * * * 5 votes

Charles.C

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Posted 05 October 2015 - 09:46 PM

My answer is yes as long as the Operational Prerequisite Programme validates the risk of Hazardous Contamination as low tending to zero Risk Priority Number( RPN) 

and any previous CCP,s Risk of breaching the Hazardous limits are validated as having a low probability of occurrence.  

 

Hi djames,

 

Do you think it's possible to have a (ISO/FSSC22000) HACCP Plan with neither CCPs nor OPRPs ?


Kind Regards,

 

Charles.C


Kehlan

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Posted 21 December 2015 - 04:33 PM

It is possible and not just in food retail.  Its common in fresh produce where the produce is not being processed but just brought in, stored and packed before going out.  We have no CCPs and the BRC auditor was very impressed with our HACCP.



Charles.C

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Posted 23 August 2016 - 04:35 PM

It is possible and not just in food retail.  Its common in fresh produce where the produce is not being processed but just brought in, stored and packed before going out.  We have no CCPs and the BRC auditor was very impressed with our HACCP.

 

Hi Kehlan,

 

Thks for the input. The conclusion might have been different if yr haccp scope extended to a pre-farmgate scenario. I also deduce that yr input may have been somewhat post-farmgate "processed" prior to yr own reception. ( "packed" can have variable interpretations IMEX).

 

i wonder if the auditorial satisfaction may also be related to history ?

 

Afaik, the UK fresh produce industry has so far not been touched by any of the various major troubles reported elsewhere, notably pathogenic E.coli/USA. Whether due to luck or some genuine FS control differences i am unaware. (I recall seeing a comparative (US/GB) article on this happy (GB-wise) distinction a few years back which suggested the latter cause but i forget the explanations given).


Kind Regards,

 

Charles.C


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Kehlan

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Posted 06 September 2016 - 01:14 PM

Packed as in taking a number of whole fruit (eg oranges) and placing them in a net or bag.  No processing whatsoever, just storage and packing.  No metal detection required as product is whole and needs to be peeled.  Everything else is covered by an extensive programme of prerequisites.  Really, what CCPs can there be when you buy in a load of whole fruit, store it in a fridge for a few days, bring it out of the fridge, put it in a box, on a pallet, on a lorry and off to the customer?



Kushal

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Posted 14 September 2016 - 05:53 AM

:coffee:



melsm57

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Posted 14 September 2016 - 07:00 PM

I'm sure HACCP studies of some processes, especially for example in food packaging manufacturing do not identify any CCP's and they happily assure food safety by implementing just the prerequisite systems. IMO it doesn't matter though if they have done the hazard analysis professionally.

As many packaging professionals visit SDF it will be interesting to run a poll to see how many CCP's, and what type of CCP's we have identified in our HACCP systems. Charles I will leave it till Sunday evening GMT so that the thread doesn't disappear over the weekend.

On that note have a good weekend. :thumbup:

Regards,
Simon

I agree - in my previous incarnation as  QM at a plastic container injection moulding facility which made direct food contact plastic pails and lids - initially we had no CCPs - one of our sister facilities continues to have no CCPS based on their risk assessment. However, at my location we had shown ourselves unable to successfully control correct label/ (In mould labeling added at the time of injection moulding) in the finished product resulting in a few instances of one odd pail mislabeled in a skid. So we introduced Line Clearance as a CCP as the only way to control the risk. Our sister facility has never had a mix up and is content to control their risk via PR program. Horses for course.



Michelle Grace Astorga

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Posted 11 April 2017 - 12:31 AM

We are producing multiple food products, so we have many CCPs



usmanashraf

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Posted 30 August 2017 - 06:50 AM

Yes, its possible depending upon your product and manufacturing process



tharinduth

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Posted 05 January 2018 - 06:44 AM

Hi all,

 

Very interesting topic.

 

I was combating with me since last month on this same topic. We were going to establish new food product facility and while I was analyzing hazards, i found zero CCP in process. But deeply I thought about the system without CCPs is not looks nice or professional. When I present my study results to my superior, he asked to put at least a CCP in process. I argued with him that there is no mandatory requirement to insert CCP to the process if we analyse it professionally. 

 

What ever, I learned following things through above incident. Please leave your comments and I need to improve my knowledge.

 

1. When we have 1 or 2 processing steps, probably it is zero CCP process.

2. If we do not change the temperature of product or do not treat them to change their microbiological and chemical quality, same as above.

 

Best regards



Charles.C

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Posted 05 January 2018 - 07:11 AM

Hi all,

 

Very interesting topic.

 

I was combating with me since last month on this same topic. We were going to establish new food product facility and while I was analyzing hazards, i found zero CCP in process. But deeply I thought about the system without CCPs is not looks nice or professional. When I present my study results to my superior, he asked to put at least a CCP in process. I argued with him that there is no mandatory requirement to insert CCP to the process if we analyse it professionally. 

 

What ever, I learned following things through above incident. Please leave your comments and I need to improve my knowledge.

 

1. When we have 1 or 2 processing steps, probably it is zero CCP process.

2. If we do not change the temperature of product or do not treat them to change their microbiological and chemical quality, same as above.

 

Best regards

 

Hi tharinduth,

 

It depends on (a) yr CCP methodology, (b) yr hazard analysis, (c) yr product/process.


Kind Regards,

 

Charles.C


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immortal

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Posted 03 July 2018 - 07:27 PM

You cant explain this to auditors. :giggle:  :giggle:


Kind regards,

Nothing is perfect, just try to improve ...

 

https://foodsector.net/


Donie

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Posted 05 July 2018 - 06:24 AM

We Haven't conducted a Risk Assessment yet but I think our CCP's would range from 0-2. 

 

I would also agree that there could be no CPP in a HACCP plan. I would take our plant as an example. We manufacture secondary packaging such as labels, corrugated cartons, and stickers and these kind of products pose no risk to human health since it will not have a direct contact with food.



Charles.C

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Posted 05 July 2018 - 07:30 PM

We Haven't conducted a Risk Assessment yet but I think our CCP's would range from 0-2. 

 

I would also agree that there could be no CPP in a HACCP plan. I would take our plant as an example. We manufacture secondary packaging such as labels, corrugated cartons, and stickers and these kind of products pose no risk to human health since it will not have a direct contact with food.

 

I don't disagree with yr comment but actually the poll was in a Food forum.

 

HACCP is subjective of course.

 

= 187 Posts.


Kind Regards,

 

Charles.C


Donie

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Posted 07 July 2018 - 12:46 AM

I don't disagree with yr comment but actually the poll was in a Food forum.

 

HACCP is subjective of course.

 

= 187 Posts.

 

:oops2:  My Bad..  Would packaging not affect the HACCP plan of those who practice Food safety? Could be a risk if products are mislabeled right?



CEA_safety

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Posted 02 August 2018 - 09:55 PM

It is definitely possible! For example: in the packing of fresh produce from a greenhouse where there are no wash steps or processing, such operations tend not to have identifiable CCPs; however, if a packinghouse is GFSI certified, it must still create a HACCP plan.



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daniela.vasquez

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Posted 13 August 2018 - 04:51 PM

This topic has helped me a lot. We have a chocolate manufacture company and we have no CCPs with our actual production line. I was concerned this would be an issue with audits.

 

We are planning to add a magnet soon, so until that happens, we will continue with 0 CCPs.

 

Thank you all for clarifying.



Scampi

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Posted 29 August 2018 - 06:10 PM

Daniela...do you NEED a magnet? Have you ever had metal in your finished goods?


Please stop referring to me as Sir/sirs


daniela.vasquez

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Posted 30 August 2018 - 03:12 PM

Daniela...do you NEED a magnet? Have you ever had metal in your finished goods?

 

In cacao, it's usual to find unwanted pieces (wood, metal, stones) so we're looking at rare-earth magnets. We also work with a ball mill, and once we had an event where a small metal ball made it through all the way to the finished chocolate. This was a very rare, very unlikely to happen again event, but made us wonder if it was a good idea to add a magnet for finished products in the future.



Brendan Triplett

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Posted 21 September 2018 - 02:43 PM

I have worked with a warehousing and distribution center that had zero CCPs.   Everything was handled through a robust set of GDPs and PRPs and was confirmed by NSF as being accurate before approved for SQF.  Only time and temperature were controlled and it definitely had zero repack, raw product handling or any other issues.  Everything was boxed and left in a temperature zone before being picked and shipped.  it was a pretty sweet set up.


Vice President and SQF Practitioner in Pennsylvania
Brendan Triplett


John muendo

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Posted 25 September 2018 - 11:48 AM

I Currently work in a zero CCP production warehouse.

I would say it all depends on the nature of risks and  PRP that are in place.

 

 

Regards 

 

John



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Posted 15 April 2019 - 03:08 PM

Hello All,

What do we say if local laws mandate certain process steps , e.g. storage of chilled ready to eat food should be below 5 C , in such scenario it becomes a legal requirement , can I still skip it as CCP and just consider a CP or being a legal requirement it will become a CCP

 

thanks

Shelendra



Jpainter

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Posted 15 April 2019 - 09:37 PM

Based on CCP decision trees, yes it should be possible to have a HACCP plan with zero CCP's, however USDA would never let that slide. 



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Posted 16 April 2019 - 08:16 AM

I think in a processing, depend on risks and control of HACCP team have analysis so have many CCP or not.

If have many CCP: you must control, not bad products.



zanorias

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Posted 16 April 2019 - 10:44 AM

I think in a processing, depend on risks and control of HACCP team have analysis so have many CCP or not.

If have many CCP: you must control, not bad products.

 

If a plan has many CCPs, my first curiosity would be the team's understanding of a CCP itself.

My previous employer was a distributor of finished product and had only 1 CCP: temperature control. If their scope excluded chilled and ambient products I suppose they would have had 0 CCPs.



tamer123

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Posted 11 November 2019 - 07:21 AM

yes a lot of factories did,t had CCPS  so they have control for all production steps 





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