Greg,
Actually we don't disagree. If metal contamination is a problem in a
plant, it definitely needs a metal detection inspection step. However,
that is an inspection process, and should be addressed as such.
The size of the piece of metal, density of the product, location of the
metal, orientation of the product going through the detector, size of
the detection chamber, etc., all affect the sensitivity of a metal
detector. In fact, a metal detector company informed me that to
increase sensitivity, it was best to have 3 metal detectors at different
angles on every line. All of a sudden it was obvious that the metal
detector controlled nothing. It inspected the product and gave a
pass/fail based on its findings.
Inspection is generally not a CCP because it is not a control step in
the process. Inspection is a Control Point. Inspection of weight,
appearance, presence or absence (i.e, metal), visual defects, microbial
safety and quality, etc., are all important.
Larry
Greg Peters wrote:
> 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
>>>
>>> ------------------------------------------------------------------------
>>>
>>>
>>> Yahoo! for Good
>>> Click here to donate <http://store.yahoo.com/redcross-donate3/> to
>>> the Hurricane Katrina relief effort.
>>>
>>
>>
>
This archive was generated by hypermail 2b29 : Fri Oct 07 2005 - 11:53:34 PDT