Well, we agree that there needs to be a control for metal, but we don't
agree on the need for a metal detector as a CCP.
If it is reasonably likely that the product could contain metal as part
of the process, that is a safety issue. It isn't like quality issues
(visual defects, weights, appearance, etc.). For some products, metal
is a real risk. Others it is not. For whitefish fillets, we have never
found any metal (not a CCP, only a control step), but I can't say the
same think when grinding is involved as for surimi. For ground product,
metal detector is a CCP. It is a matter of likelihood.
How about cooking for a ready to eat product? Is that a CCP? By your
definition, since the cooking doesn't prevent pathogens from entering
the product, but removes the likelihood of a problem (like a metal
detector), it is not a CCP. Cooking inactivates potential pathogens so
I would argue that it is a CCP.
If we tried to claim that metal detector for surimi or cooking for ready
to eat product was not a CCP, there would major problems with FDA, USDC,
and the state.
Greg Peters
Alyeska Seafoods, Inc.
Larry Wyatt wrote:
> 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 - 12:35:52 PDT