Is a Preventive Control the same as a CCP?

Thank you again, Charles!  I really appreciate it.

Good point.  

In the definition:  "a step" = one particular point in the process.

Pest Control is not applied at one point in the process.  Thus it is usually not considered to be a CCP.

It seems to me that some people are confused about whether a preventive control (FSMA terminology) has to be a CCP (HACCP terminology) because they consider a non-CCP preventive control as being "important", and therefore "critical" so it must be a CCP.

In my opinion, a CCP is a process control activity that is done during the handling, processing or manufacturing of food items.  There are other control activities that occur outside of a production process.

So, Charles C., do you agree:

1. All CCP's are Preventive Controls.
2. Not all Preventive Controls are CCP's.

Yes, I stand corrected.  A CCP is an important and necessary (essential) control activity.  However, there are many control activities that are not CCP's:  Pest Control, Food Defense, Supplier Approval, etc.

The confusion about terminology arises because of so many different codes, schemes, regulations, etc. that are not using the same terms for the same issue.

Maybe you guys have more thoughts on this but the initial reasoning for my questions is our Foreign suppliers HACCP plans show CCP's versus Preventive Controls, PC's.  I am not sure if any of our suppliers would be willing to change wording to satisfy FDA or not.  

And we import the Fish Meals and Fish Oils in Food Grade Totes for meal and Spacekraft or IBC's on the oil.  When the products arrive we store them and then ship "as is" to our customers for further manufacturing.  We do nothing with the product (mixing, etc).  

As I am reading a lot of this is subject matter in this forum on a variety of topics, it appears that interpretation varies.

I was told by my SQF auditor that a process preventative control is equal to a CCP as long as there is scientific evidence.

For example: a filter would not be a process preventative control because their is not scientific data for filters.

mlf

Good point.  

 

In the definition:  "a step" = one particular point in the process.

 

Pest Control is not applied at one point in the process.  Thus it is usually not considered to be a CCP.

 

It seems to me that some people are confused about whether a preventive control (FSMA terminology) has to be a CCP (HACCP terminology) because they consider a non-CCP preventive control as being "important", and therefore "critical" so it must be a CCP.

 

In my opinion, a CCP is a process control activity that is done during the handling, processing or manufacturing of food items.  There are other control activities that occur outside of a production process.

 

So, Charles C., do you agree:

1. All (Codex) CCP's are Preventive Controls.
2. Not all Preventive Controls are (Codex) CCP's.

 

Yes, I stand corrected.  A CCP is an important and necessary (essential) control activity.  However, there are many control activities that are not CCP's:  Pest Control, Food Defense, Supplier Approval, etc.

 

The confusion about terminology arises because of so many different codes, schemes, regulations, etc. that are not using the same terms for the same issue.

Hi CMH,

Re - red ^^^^^

JFI, there is another lengthy thread here on this topic illustrating the persistent level of confusion -

https://www.ifsqn.co...he-same-as-ccp/

Personally i was never able to rationalise the, IMO twisted, hazard logic underpinning the FSMA definition of Preventive Control so unable to meaningfully answer yr query. Sorry.

PS - Offhand, after consulting the attachments/link below I suggest -

(1) Yes although maybe some complications can occur, eg where Multiple/Combination CCPs are involved.

(2) Yes.

(Note that a comparison between a step and a control measure is being made).

 brc_fsma_voluntary-module_and_guidance-7_jun2018_lr.pdf   339.77KB   12 downloads

 BRC compared FSMA regarding preventive controls.2016 - brctag-guidance-document.pdf   1.31MB   12 downloads

https://techni-k.co.uk/BRC_and_HARPC