I have a different opinion on CCPs. If you find that a hazard is
reasonably likely to occur and there is a control step that will prevent
harm to a consumer it is a CCP. For the example Larry used of a metal
detector, if that hazard is reasonably likely to occur, as in surimi,
there better be a CCP to control it.
Cold storage would generally not be a CCP because pathogen growth in
cold storage is not reasonably likely to occur. The execption would be
for a product that may already contain parasites that will be consumed
raw. The freezing step may be used as a CCP to inactivate the parasite.
Greg
Larry Wyatt wrote:
> 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 - 11:15:10 PDT