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

I've just been reading this forum topic and find it fascinating that people seem to introduce CCP's because their enforcement authority seems to want them.

I had a very animated discussion with our plant OVS some time ago regarding CCP's. He was trying to tell me that I needed to introduce more because he didn't think I had enough. I explained that I work on the basis of the Codex and therefore use a decision tree to determine whether a CCP should be set in place.

Furthermore, whenever I have written out HACCP plans for anyone I always insist of justifying the inclusion of a CCP rather than justifying not having it and the justification for one can never be that the enforcement authorities think you should have one!

And beware some food safety consultants - they will introduce unnecessary CCP's on the unsuspecting food producer because they then want to verify them. Which means at consultant rates it's goes to cost a small fortune (in my experience, you could probably run a small town on the budgets that some of these guys want to work to!).

by the time our FSA is complete, we are going to come out with 0 CCP's in our plan.

we are a small pork processing facility in the U.S.A. we have at elast 5 CCP's in our HACCP Plans. (fully cooked, not shelf stable; fully cooked, heat and control oven; raw-ground; and raw, not gorund)

I don´t think it matters how many CCP you have. But obvously a lot CCP is a big burden in your hands. You just need to control them, if there is any other way to control a hazard, then it might be PRP or OPRP. Also, an OPRP could have been controlled once as a CCP.

Good control measures (validated and executed as planned) = low or no food hazard.


Regards,

FSSM

The CCPs are decided applying DECISION TREE. And there is no reason to why not have even one CCP, which will not be allowed by Decision tree.

So IMO there will be definately CCP if we go by DT.

Rgrds,

Sanjay.

Dear Sanjay,

It is possible you are slightly over-simplifying the situation. Don't forget it is also necessary to validate any implemented CCPs, or their non-existence.

Rgds / Charles.C

BTW, Welcome to the forum !

The CCPs are decided applying DECISION TREE. And there is no reason to why not have even one CCP, which will not be allowed by Decision tree.

So IMO there will be definately CCP if we go by DT.

Rgrds,

Sanjay.

Dear All,

When this topic was raised years back, I never had the slightest notion that it will remain active until today. IMO, the concern is not about the need to have a HACCP Plan or otherwise. The key is whether your risk assessment has been correctly performed/justified otherwise risk management becomes inadequate in supporting the intended food safety objective(s) if the performance criterion is inappropriately selected or identified.

Since process environment differs vastly, there are certainly instances where Food Safety Systems do not require the support of a HACCP Plan but instead supported by the SOP/SSOP program.

I hope my opinion will open another angle of thought where according to the great "Peter Synder"

HACCP has no process performance criteria / numbers. Applying HACCP principles, one uses food science to specify and develop process performance criteria and to set controls in a process to achieve the desired consumer ALOP"

HI ,

Even in my company we have no CCP, but instead we have 2 OPRPs.

Regards

Bhavin

HI ,

Even in my company we have no CCP, but instead we have 2 OPRPs.

Regards

Bhavin

Don't forget it is also necessary to validate any implemented CCPs, or their non-existence.

Hi Bhavin

What products are you manufacturing?

Regards,

Tony

HI Tony,

We are manufactruring and exporting steam sterilized spices and oil seeds.

Though we had steam sterilizer, if we follow decission tree, it will become CCP, but i am following ISO 22K method for risk analysis and based on that i have got 2 OPRPs.

Regards,

Bhavin

Dear FSSM,

Dear Charles.C,

When I looked again to this post, you made me wonder the details of a non CCP´s validation, could you explain a little more?

Regards,

FSSM

Dear FSSM,



Sorry delay, only just saw yr post. My English was probably a bit illogical. I think I was trying to say that occasionally, in the process of validating a proposed CCP, one realises that it isn't a CCP after all.

Rgds / Charles.C

Dear FSSM,

in the process of validating a proposed CCP, one realises that it isn't a CCP after all.

Rgds / Charles.C

Dear Charles,

I think that the number of CCP certainly vary from system to another but i don,t know how to be zero ?
for example, in poultry processing plant CCP are 5-6 and may be more in some plants and may reach 8-9.
so I want you to explain the basis on which the CCP is determined .

Kind Regards,
Amr Mekky

Dear mekky,

I suggest you try posts # (61-72) in this thread, especially the generic haccp plans.

BTW - Good searching

Rgds / Charles.C

Just want to say:

What a great topic... About 23000 viewers + 91 replies!

I think no more topic could beyond this record !


By the way, mekky. Your poultry factory could hardly achieve 0 CCP.

However, some companies only have the packing activities do have the possibility to determine 0 CCP due to no hazard identified during the hazard analysis.

So different factories have different number of CCPs. I guess determination of CCPs usually based on decision tree.

Best regards

Jason

For your information, my colleagues think I am mad to even suggest that it is possible to have 0 CCP in a Haccp Program.

That was the question I confronted a very senior and world renowned food consultant. The answer was YES and we both knew the reason why. Before, any viable foodsafety management system came into our daily working life, no one ever heard about Haccp.

All that everyone knew was 'end product testing" for all finished products prior to shipment of goods delivered or worse, incubate the finsihed products in the warehouse for a period of time and observe for signs of microbial actitivies.

Haccp principles allow us a lot of freedom to do what we want to do so long as we can proof that we are IN CONTROL . No CCPs means requiring a very strong in-process-quality-control programs which would require you to perform VALIDATION ACTIVITIES at all major critical steps of the process.

It appears not to be practical but achievable to ZERO CCPs. In summary, using this approach would mean that you could be operating a beverage manufacturing facility (like OJF case) in an ALMOST similar environment as that of a "pharmaceutical GMP" status.

So, is it not better to control a couple of CCPs than having to deal with None?

Comments on the above is welcome. On the number of CCPs we should consider appropriate, the poll shows a vast range which means this topic is still wide open

Charles Chew

A lot of very good points have been made about CCPs in this thread. I have to agree that the more you have the harder it will be to control them and validate them. Not having a CCP where you should have one is not an option though either. It will depend on the operation/industry/processes as to how many are needed.

I know this forum talks a lot about HACCP/ISO 22000 for food processing, but I'll add my thoughts for what they are worth. I am QM for a feed manufacturing company, with 3 separate facilities. We have two CCPs at two of them and 0 CCPs at the third one.
The question was raised by an auditor last fall as to why we don't have one and we explained that we beleive we have assessed all the products and processes using Decision Tree and have adequate controls at all points of the process, and do not have any CCPs. All areas of the process have controls in place to ensure product safety.

The CCPs that we do have at the other two facilities have to do with medication (drug) use. One is in the amount used and the second one is in sequencing of medicated ingredients. Ensuring that no two incompatible medications follow each other without a system flush being done.

That was set as a CCP when I started this position. We have since that time done a software upgrade where we can flag medications and it will not let the operators do incompatible sequencing. Can I drop the CCP and use the system flag as a CP?

A lot of very good points have been made about CCPs in this thread. I have to agree that the more you have the harder it will be to control them and validate them. Not having a CCP where you should have one is not an option though either. It will depend on the operation/industry/processes as to how many are needed.

I know this forum talks a lot about HACCP/ISO 22000 for food processing, but I'll add my thoughts for what they are worth. I am QM for a feed manufacturing company, with 3 separate facilities. We have two CCPs at two of them and 0 CCPs at the third one.
The question was raised by an auditor last fall as to why we don't have one and we explained that we beleive we have assessed all the products and processes using Decision Tree and have adequate controls at all points of the process, and do not have any CCPs. All areas of the process have controls in place to ensure product safety.

The CCPs that we do have at the other two facilities have to do with medication (drug) use. One is in the amount used and the second one is in sequencing of medicated ingredients. Ensuring that no two incompatible medications follow each other without a system flush being done.

That was set as a CCP when I started this position. We have since that time done a software upgrade where we can flag medications and it will not let the operators do incompatible sequencing. Can I drop the CCP and use the system flag as a CP?

I believe it can be possible to not have any CCP's in a system that has been in place for quite some time. It depends on your product and the serverity of the hazard getting so out of control that it poses a severe risk to the final consumer. Just imagine all the tomato and spinach producers who have been producing their products for years without haccp. Those of us producers whose product doesn't touch the ground have been involved with haccp for over 10 years. Where's the logic in that concept.

Dear Moochie,

I work in a potato pack house, we have 0 CCP's but 3 QCP, we were actually given a non conformance on a BRC audit for putting the QCP's as CCP's

There can be HACCP plans with zero CCPs and this can only be deduced from conducting a risk assessment. As Simon has pointed out that packaging suppliers can have no CCPs but at the same time there can be other direct contact food packaging supppliers and they may have a CCP(s) such as critical limits on heavy metals on the packaging supplied. each baytch of packaging must be accompanied by a Certficate of Analysis (COA) to state what the levels are.

I have designed a HACCP plan for a packaging supplier and they only had one CCP and the auditor was happy with the HACCP plan.

As long as you can justify that you have conducted a proper risk assessment that would be a case for discussion with the auditor. One can always request for a second opinion of another auditor if they feel the auditor is not agreeing with the proof that you have provided.

Cheers

Ajay

Dear Moochie,



Out of idle curiosity, what were the CCPs ?

Rgds / Charles.C