Re: CCP or Not?

Ken hilderbrand (ken.hilderbrand@hmsc.orst.edu)
Tue, 16 Feb 1999 09:55:25

Ron, I don't think one has to assume a HACCP failure on the part of a
supplier to be concerned about pathogens in ingredients. The spores of C.
bot in pasteurized crab or smoked fish would be an example. There is a
tolerance for some pathogens in food and even with Listeria (zero
tolerance) you'll probably find it sometime if you look long enough. I
think the prudent processor should not assume that the ingredients are
commercially sterile in a situation where his "in process" time and
temperature would allow for rapid growth of pathogens. The first processor
may have made the product safe for the intended consumer in a specific
form, but as a remanufacturer the second processor needs to evaluate how
the ingredient will react in their own process. For instance, you may
change the salt content or pH which were CCPs in the ingredient.

But I've been wrong once already this week so I look forward to other
opinions.

Ken Hilderbrand

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At 09:51 AM 2/16/99 -0500, Ron Hoelzer wrote:
>Thanks to all who responded to my question concerning the need for a CCP
>or not with a blended seafood and dairy product. I realize it's
>difficult to answer such a questions without all of the details.
>
>I seemed to perceive one matter in at least some of the questions and
>that is that there is an assumption that the original processors HACCP
>plan failed in some way and that the secondary processor must compensate
>for that perceived failure. If that is in fact the case, wouldn't all
>the product on the retail shelf come under that same assumption?
>
>I guess my questions is this. DO we assume the HACCP plan has failed or
>been sucessful. I know we can all site instances of failure, however,
>for every failure (food borne illness)there are an un-countable number
>of sucesses in the market place. Maybe the perception is whether one is
>a regulator who might have the tendancy to assume failure, or industry
>where one might have the tendance to assume success.
>
>A second question comes to mind, if we assume HACCP plan failure, are we
>back to the old style of inspection?
>
>I would appreciate your comments.
>
>Ron
>
>
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Kenneth S. Hilderbrand Jr.
Seafood Processing Specialist
Oregon State University
Marine Science Center
2030 Sth Marine Science Drive
Newport Oregon 97365-5296
telno 541 867-0242 (and voice mail)
faxno 541 867-0138
email <ken.hilderbrand@hmsc.orst.edu>

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