Greg,
Actually I think cooking may or may not be a CCP. It depends on the
cooking process. I once was responsible for cooking products in racks
ovens. The requirement was that the product be baked to an internal
temperature of 165F. This was so the ingredients would set up. It had
both egg and dairy products as ingredients so it would be considered as
potentially hazardous so the cooking step might be considered as a CCP
for killing any pathogens that might be inhabiting the eggs and dairy
products. However, it was not a critical control point to kill the
pathogens, it was a control point to insure that the product was cooked
correctly. The killing of the pathogens was incidental. If after the
set cooking time, the internal temperature did not reach 165F when
tested, the rack was placed back in the oven and cooked until it did
reach 165F. This relates back to what I was saying about using GMP's
and SOP's to control hazards although they are not CCP's.
If you are cooking a Ready To Eat product on a continuous cooking line,
the time and temperature are critical to achieve the internal and
external temperatures necessary to kill the pathogens. This is
definitely a CCP because time and temperature control the process. If
either go awry, the CCP limits will be violated. Product in the system
at that point will be subjected to Corrective Action as described in the
HACCP plan.
That is why it is critical to do a thorough hazard analysis and
understand what each step in the process provides.
Larry
Greg Peters wrote:
> 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 - 12:58:52 PDT