What you are in essence referring to is whether the receiving step is a
CCP. Lets assume that a supplier's HACCP plan is indeed working properly.
For example, they are processing cooked, chilled seafood. Their
obvious CCPs are cooking and cooling steps, which are controlled
correctly. What happens during post-heating handling of the product prior
to receipt at your plant can have food safety implications independant of
the success or failure of a supplier's HACCP plan. Some examples include
temperature abuse during storage and transportation that could lead to
outgrowth of heat-resistant pathogens and cross-contamination
during subsequent handling leading to introduction of pathogens. A
receiving CCP to monitor temperature of incoming product could control the
first hazard since there is no HACCP requirement for transportation. The
second hazard is likely thrown out of a HACCP plan because we assume that
GMPs and SSOPs control cross-contamination.
FWIW,
Douglas L. Marshall, Ph.D.
Associate Professor, Mississippi State University
Director, Food Safety Institute
On Tue, 16 Feb 1999, 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
>