Hi Alma,
These are my views:
1. There are no EU directives that set CCPs, these are up to the processor
to determine.
2. I assume you refer to the Competent Authority. I would not consider cold
(frozen) storage a CCP simply because a product that is intended to be kept
in be frozen condition would be in breach of specifications and GMP, drawing
in quality and safety issues. I would set the temperature control as a
prerequisite programme; a given if you like. I.e. if the product
temperature were outside the limits, that would be the end of it for its
primary purpose and disposal or alternative use should be considered.
3. Pathogen growth is unlikely to present a food safety hazard due to the
reasonable expectation that the product would be cooked. That is unless
there were an issue with spore formers or with heat resistant toxins then
there would be a problem. These matters would be highlighted in the
analysis part of the HACCP. Unfortunately it is not an argument that sways
opinion in international trade which will set stringent micro counts.
4. It is not illegal but may mean that your analysis was invalid if a CCP
were missed. In the UK this alone would not lead to prosecution but could
become evidence to support a prosecution if there were more serious matters
arising from temperature abuse i.e. food poisoning.
I hope this helps
Richard Chivers
-----Original Message-----
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu]On Behalf
Of alma tina
Sent: 07 October 2005 06:34
To: seafood@ucdavis.edu
Subject: inquiry about cold storage being considered as CCP
Dear List,
Please give me some insight or enlightening regarding the issue of
considering cold storage as CCP.
These are my questions:
1.Is there an EU directives that considers storing at cold storage as CCP.
2.Can the competitive authority insist on us to consider storing at cold
storage as CCP.
3. Is my thinking correct, that since our product is to be fully cooked
before consumption, then pathogen growth is not a hazard? By the way our
products are frozen octopus and shrimps.
4. Is it illegal not to have CCP for a particular item?
Plese provide some information on this issue, we badly needed the info.
Thanks,
Alma O. Tina
almaorodiotina@yahoo.com
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