Re: CCP or Not? -RESPONSE

Ben J. Elder (benelder@home.com)
Sun, 21 Feb 1999 21:16:56 -0600

Christian,
It's obvious from your response that you are inspected by FDA rather than
USDA. Under USDA, trying to gain approval of a HACCP plan without CCP's
will only get your plant closed until you come up with some. You can apply
theory and regs all you want, but in actual practice, they will not approve
a plan without CCP's.
Ben Elder
Food Safety Institute
-----Original Message-----
From: Christian Vogl (BCP) <BCPCWV@annicis.bcp.weston.ca>
To: Post to Seafood list <seafood@ucdavis.edu>
Date: Sunday, February 21, 1999 3:30 PM
Subject: RE: CCP or Not? -RESPONSE

>Listers,
>I would like to disagree with Ben's comments below, made in reference to
>Ron's query regarding CCP's...
>I disagree that if you have no CCP's, you have no HACCP Plan. If, through
>working out your hazards and your HACCP plan, you discover it possible to
>produce without a CCP in your 'flow chart', this does not mean that you
have
>no HACCP benefit. The exercise of constructing and implementing a HACCP
>plan is extremely educational and infinitely beneficial to any operation.
>To under estimate the importance of each step in any process because they
>are not CCP's, detracts from the whole point of HACCP plans. I also would
>take issue with the metal detector as a CCP. To me, the point of HACCP
>would be for a processor to be proactive. There are more proactive
measures
>one can take to avoid metal contamination and demonstrate control.
>Christian Vogl
>Allied Pacific Processors
>>
>>>Ron,
>>>If you have no CCP's, you have no HACCP plan. I think under your
>scenario,you would at least have a CCP at the metal detector. If you are
>adding any controlled ingredients such as nitrites, their control is
>critical enough to be a CCP.
>>>Ben Elder
>>>Food Safety Institute
>
>>>-----Original Message-----
>>>From: Ron Hoelzer <rsardine@bangornews.infi.net>
>>>To: seafood@ucdavis.edu <seafood@ucdavis.edu>
>>>Date: Saturday, February 13, 1999 8:18 PM
>>>Subject: CCP or Not?
>>>
>>>
>>>>I have a scenario for discussion since I have encountered several points
>of view:
>>>> A seafood processor is going to make a seafood dish from products that
>have already been processed. He will be combining previously thermally
>treated product. These products will all be purchased from sources which
are
>processing under a HACCP plan, hence, any pathogens will have been
destroyed
>before the product reaches the second processor.
>>>>
>>>> The product will consist of the following:
>>>> Cooked, refrigerated seafood (could be lobster, crabmeat, shrimp)
>>>> Pasteurized dairy products,
>>>> Spices and flavorings
>>>> These ingredients will be heated to blend the flavors, but not heated
>>>>enough to achieve any degree of kill activity.
>>>> After heating the product will be dispensed into retail size containers
>>>>and frozen.
>>>> The question is - would there be any critical control points with this
>>>>product?
>>>>
>>>>Ron Hoelzer
>>>>Maine Food Technology Associates
>>>>
>>>
>>
>