Gas Analysis as a CCP

Hi everyone just need a bit of advice. 

We are changing our old gas analyser as it is extremely old and the maintenance of it is costing a fortune. We currently test for oxygen (<1%) and C02 (25-30%). We produce a ready to eat product which is bacon, and I was wondering if we need to test for CO2?

We currently use a blend of 30% co2 and 70% nitrogen for packaging. To buy a gas analyser that only tests for oxygen is twice as cheap as one that tests for both CO2 and O. 

If we test the % of oxygen alone would this be acceptable for BRC ver 7 and customers as long as it is justified correctly in our HACCP plan?

Thanks in advance 

Donna 

Hi Donna,

Possibly involves para.4.5.4

What is the critical LImit for the CCP ?

(I thought this activity was only related to shelf-life or is there a minimum O2 req. regarding C.botulinum?)

Hey Charles, excuse my lack of knowledge but what do you mean by para 4.5.4 lol

We have a critical limit set for <1%, our consultants had created our HACCP long before I started but they haven't set a critical limit for the CO2 its more like a target as it says it should be 25%-35%, I think its more for our shelf life than anything else tbh. 

<1% for O2 sorry

Hi Donna,

para 4.5.4 in BRC7 standard ? (following yr OP comment?)

My O2 comment was whether there was a >X% O2 as well as a <Y% O2. Just curious.

If it's purely shelf-life, no relationship to haccp.

addendum

I assumed the shelf-life is based on non-safety-related criteria only. Is it ?

no Charles just <1% Oxygen......

The consultants have justified it as 'Microbiological - This step is specifically designed to control this hazard to an acceptable level and there will be no further steps in the process where the hazard will be controlled' ive a few issues with this, if we are cooking this correctly our CCP Cooking/cooling records will prove this as will micro results the, product should be safe to eat and the gas should be used for shelf life. 

I really haven't been at this QA job long so I'm not sure if im making sense or sounding stupid lol

no Charles just <1% Oxygen......

 

The consultants have justified it as 'Microbiological - This step is specifically designed to control this hazard to an acceptable level and there will be no further steps in the process where the hazard will be controlled' ive a few issues with this, if we are cooking this correctly our CCP Cooking/cooling records will prove this as will micro results the, product should be safe to eat and the gas should be used for shelf life. 

 

I really haven't been at this QA job long so I'm not sure if im making sense or sounding stupid lol

IMHO "Microbiological" is not acceptable as a defined hazard.

The relevant question IMO is what specific , significant, safety hazard the critical limit of <1% O2 is intended to "control".?

From a regulatory POV i imagine the shelf-life criteria are "revealed" by whether date labelled as Use By or Best Before ? The choice was presumably validated by "Consultants".

addendum2

The topic of MAP as a CCP, PRP, OPRP, none of the previous, is also discussed (at length !) here -

http://www.ifsqn.com...ccp/#entry51337

http://www.ifsqn.com...map/#entry17495

With respect to yr OP, one specific, operational, reason for monitoring CO2 might be in the attachment "go1a" in this post -

http://www.ifsqn.com...ccp/#entry53919

Dear DonnaC:

CO2 is typically used in packaging meat products in order to slow down the growth of aerobic bacteria in order to increase shelf-life. Of course, this can result in growth of anearobic bacteria. So, as Charles.C has indicated, your first order of business is to determine why the CO2 is being added - food safety or product quality. That will help you decide how imperative it is to measure CO2 and what degree of variablity is allowed. Does your food safety regulatory agency provide any sort of food safety guidance for your product(s)? This might help in the determination.

Keith