No CCP therefore no HACCP plan?? Not really. If it becomes an important
issue to a firm I suggest that you simply write up the plan stating "no
CCPs identified", then in the verification/validation step set up a record
which makes sure you validate the "no CCP" conclusion each time something
changes in the process, or prior to the beginning of a production season,
or at least once per year for 12 month/year production. In my opinion you
would then have a HACCP plan by anyone's definition. In the USA, FDA
requires such a "reassessment of the hazard analysis" whenever something
changes "that could reasonably affect whether a food-safety hazard now
exists. [Sec 123.8 (c)]. But reason tells me that you could not do that
"reassessment" effectively without some written policy or procedure which
would automatically trigger it at least once per year (in other works, "a
HACCP plan").
However, in Ron's hypothetical example, refrigerated crab meat is an
ingredient and, as someone has already pointed out, receiving should
probably be a CCP because transportation is not covered by HACCP and it is
up to the receiver to make sure temperature abuse has not occurred in
transit. Temperature upon delivery would be a logical Critical Limit with
such products.
I have been told that FDA will accept valid "no CCP" plans as meeting the
requirements of their regulations, but I don't think Ron's hypothetical
example would be without a CCP.
Ken Hilderbrand
At 01:23 PM 2/21/99 -0500, Christian Vogl (BCP) wrote:
>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
>>>>
>>>
>>
>
>
------------------------------------------------------
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>
****************************