Alma,
I just want to offer my thoughts on the absence of a CCP for a product
or a process. After you have conducted a Hazard Analysis and even
though you find a hazard, does not mean that you have to have a CCP. If
the hazard cannot be controlled by a specific point in the process, it
is not a CCP. You may have Control Points (CP) that are part of GMP's
and SOP's that are used to control a hazard and not have a CCP in your
HACCP program.
An example is metal detection. A metal detector is after the fact. It
doesn't control getting metal into the product, it helps control getting
metal contaminated product to the consumer. It is not a CCP, but it is
a CP and should be controlled as such. The same would be true for
refrigeration. Storing perishable products at ambient temperatures
would allow contaminated product and probably unsafe product to get to a
consumer. However, refrigerated storage is after the fact and does not
control the process for pathogens on the product.
This does not do away with monitoring and controlling CP's since they
are part of the process, but their administration is addressed as part
of the GMP program or process SOP and would be intact with or without a
HACCP program.
I have seen HACCP programs with 300 CCP's and programs with 0 CCP's.
The one with 300 actually should have been 0 CCP also. The key is to
conduct a valid hazard analysis and to identify what is a true CCP vs. a CP.
Larry Wyatt
FoodHorizon Inc.
www.foodhorizon.com
Richard Chivers wrote:
>
> 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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This archive was generated by hypermail 2b29 : Fri Oct 07 2005 - 08:39:16 PDT