Grade - Active
Posted 15 October 2016 - 01:59 PM
Hi Experts,
I have a query regarding considering the antibiotic testing of milk in dairy. How can it qualify as CCP when all Dairy does is checking milk for the presence of antibiotic. If present the load is rejected. There is nothing that a dairy can control at their end to resolve the issue other then rejecting a load. I assume it's an CCP for a farmer not for Dairy. Any help in would be greatly appreciated.
Grade - FIFSQN
Posted 15 October 2016 - 11:36 PM
Hi Experts,
I have a query regarding considering the antibiotic testing of milk in dairy. How can it qualify as CCP when all Dairy does is checking milk for the presence of antibiotic. If present the load is rejected. There is nothing that a dairy can control at their end to resolve the issue other then rejecting a load. I assume it's an CCP for a farmer not for Dairy. Any help in would be greatly appreciated.
Hi Bob,
It likely depends on yr implemented FS Standard/yr HACCP system.
For example you can find it as a (Receiving) CCP in some Traditional Codex-based schemes. Hazard = receiving contaminated milk which will then continue through to the consumer. Control measure = to reject if not in compliance at reception. > Significant Risk (Sev. x Likhood).
In contrast, It could be within the scope of PRPs in iso22002-1 for fssc22000.
I have also seen examples of your opinion but this would likely reflect back onto the relevant Supplier Approval/monitoring program.
Kind Regards,
Charles.C
Grade - FIFSQN
Posted 17 October 2016 - 04:32 AM
Hi Bob,
It would normally be covered by prerequisite programmes for raw materials (supplier assurance & goods in tests).
A positive release of the delivery for antibiotics not detected would be the norm for acceptance. I personally wouldn't get too hung up if someone had decided that it was a CCP as long as it is controlled.
Kind regards,
Tony
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Grade - Active
Posted 18 October 2016 - 05:34 AM
Hi Bob,
Following a decision tree to categorize the risk and the severity of failure may be the way to go. I shall also evaluate how many times loads were rejected in the past due to antibiotic presence. Yes, it is in the first place the responsibility of the farmer to control this, but we know accidents happen (withdrawal times for antibiotics as indicated on product labels are averages and may differ between individual cows).
Grade - FIFSQN
Posted 19 October 2016 - 12:44 AM
Hi Bob,
Following a decision tree to categorize the risk and the severity of failure may be the way to go. I shall also evaluate how many times loads were rejected in the past due to antibiotic presence. Yes, it is in the first place the responsibility of the farmer to control this, but we know accidents happen (withdrawal times for antibiotics as indicated on product labels are averages and may differ between individual cows).
Hi Leonie,
I deduce you are suggesting that if history supports a "significant" frequency of non-compliance/serious consequences, the hazard shud be a CCP.
In Principle i agree with you, and so did the original versions of haccp, but over time haccp has progressively modified so that, I think, many interpretations now (rightly or wrongly) tend to define it to be a PRP. But probably not all.
Kind Regards,
Charles.C
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