Hector
Some ideas come to my mind reading your excellent insight.
1. Industry must deal not only with science based CCP’s and regulation based
CCP’s but also with Client’s CCP, as is the frequent case with metal
detectors
2. In my opinion, if at a certain stage you have correctly identified the
food safety hazards and the control limits, have in place an adequate
monitoring system and take proper corrective actions when necessary, to call
it a CCP or not is not as transcendental as it looks.
3. Cold storage is rarely a CCP.
JAIRO ROMERO, M. Sc.
Consultor Internacional en Inocuidad y Comercio de Alimentos
Cra. 4 # 16-29 Of 404, Bogotá DC, Colomia
Teléfono (571) 282 4224
Móvil (57) 315 309 5343
_____
De: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] En nombre
de Lupin, Hector (FIIU)
Enviado el: Martes, 11 de Octubre de 2005 03:48 a.m.
Para: richard@fishonline.co.uk; alma tina; seafood@ucdavis.edu
Asunto: RE: inquiry about cold storage being considered as CCP
Dear colleagues:
This is a very interesting discussion, that pops up very frequently. I think
that there are some general considerations:
(i) Regulatory HACCP is not HACCP (e.g. in the sense of HACCP according the
Codex Alimentarius) but a regulation based on HACCP. Therefore, in
principle, you have to comply with a regulation and not just with the dry
HACCP principles and/ or steps.
(ii) Regulations, as any other piece of knowledge, is open to
interpretations. "Interpretations" are usually a problem. Inspection
agencies in general make every possible effort to make interpretations, of
their own officers, uniform. But not always succeed.
(iii) One of the aspects of HACCP-based regulations is that they determine
directly or indirectly "regulatory hazards"; this means hazards that you
shall be taken into account in your HACCP plan, regardless which could be
your own technical opinion. In the case of the US FDA HACCP-based
regulations theoretically you may eventual appeal (if you are in the US),
based on scientific grounds. However, for most "regulatory hazards" the
possibility somebody could demonstrate they are not hazards (e.g. histamine
in pelagic fish) is usually very remote.
Regarding the EU directives there are a couple of things to clarify
(translate from EU English to USA English):
(a) HACCP for fish and fish products is called "own-checks".
(b) CCP is called "Critical Point"
(c) "Hazard is a potential to cause harm to health and is anything covered
by the hygiene objectives of Directive 91/493/EEC" (bold and Italics mine)
(from Commission Decision 94/356/EC of 20 May 1994)
Going to Council Directive 91/493/EEC we found the following:
(1) "- frozen fishery products, with the exception of frozen fish in brine
intended for the manufacture of canned foods, must be kept at an even
temperature of -18 º C or less in all parts of the product, allowing for the
possibility of brief upward fluctuations of not more than 3 º C, during
transport;" (Council Directive 91/493/EEC, Annex, Chapter VIII, Storage and
Transport, Point 1) (bold mine)
(2) "3. Storage rooms must have a temperature recording device in place
where it can easily be read. The temperature sensor of the recorder must be
located in the area furthest away from the cold source, i.e. where the
temperature in the storage room is the highest. Temperature charts must be
available for inspection by the supervisory authorities at least during the
period in which the products are stored." (Council Directive 91/493/EEC,
Annex, Chapter IV, Special Conditions for Handling Fishery Products on
Shore, II Conditions fro frozen products, Point 3) (bold mine)
And finally, and perhaps the most important for this discussion:
(3) "Critical limits may be derived from a variety of sources. When not
taken from regulatory standards (e.g. frozen storage temperature) or from
existing and validated guides of good manufacturing practices, the team
should ascertain their validity relative to the control of identified hazard
and critical points" (Commission Decision 94/356/EC, Chapter II, Point 1).
(bold mine)
In this case the regulation is not saying that the cold storage temperature
is a CP (a CCP); but is given all the indications in that sense (critical
limit, tolerance, measurement and record keeping and use it as regulatory
example). The need for corrective actions, in the case of deviations, is
obviously a result; and the need for verifications of measurement and record
equipment fall into the general principle of verification and calibration
and re-calibration of measurement equipment. Therefore we have our
regulatory hazard and CP (or CCP).
Again, the possibility that in this situation a fish inspector from the EU
do not consider the temperature in a cold storage room a CP (a CCP) is
remote. He/ she may eventually accept that continuous records could be
replaced by recorded lectures, say every 3-5 hours (taking into account the
thermal inertia of cold storage rooms); but hardly that it is not a CP
(CCP).
The discussion about the rationality or not of frozen storage temperature as
a CP (or CCP) is interesting; I am tempted to go on that, but not time now.
In any case we should keep in mind that HACCP based regulations (or by the
case all Risk Analysis) are based on Science, they are not Science.
I have worked with people in developing countries that want to export their
fish. People normally ask you to provide an advice that put them into the
safe side. Which advise would you provide in this case?
(Warning: from 1 January 2006 there will be a new set of EU regulations
dealing with HACCP, and a new careful reading of regulations is necessary
for all trading fish with the EU)
Kind regards.
Hector M. Lupin
Senior Fishery Industry Officer (Quality Assurance)
Fish Utilization and Marketing Service (FIIU)
Fishery Industries Division (FI)
Fisheries Department, FAO, Room F 606
Viale delle Terme di Caracalla
00100 Rome, Italy
Tel + 39 06 570 56459
Fax + 39 06 570 55188
E-mail: hector.lupin@fao.org
-----Original Message-----
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On Behalf
Of Richard Chivers
Sent: 07 October 2005 16:36
To: alma tina; seafood@ucdavis.edu
Subject: RE: inquiry about cold storage being considered as CCP
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
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