It is the HACCP debate that is as old as time. Is metal detection a CCP?
Temperature control a CCP in a chilled or frozen FBO?
labelling a CCP?
Coding a CCP?
Cooking a CCP?
Spray tunnel chemical disinfection of items in packaging a CCP in high care sites?
Positive release or a CoA a good control measure?
The answers are YES, NO!, Yes*, Maybe, Maybe, Maybe, Never and Never, ever, ever!
Let me explain . . .
- Metal Detection
- Metal detection as the last process step before the product leaves site is a CCP. It is critical. There are no further steps that will reduce or eliminate the hazard. I hear my continental European colleagues say it is a PRP or even better an OPRP. Well, it’s not it’s a CCP otherwise nothing is a CCP and everything is pre-requisite or operational pre-requisite. Agree or not? Let me know.
- Temperature Control
- Temperature control is never a CCP in a month of Sundays in a chilled or frozen FBO. This is an example of a PRP, after all if the FBO does not have adequate refrigeration, they might as well pack up and go home. HACCP teachers, academics and trainers will not agree, but believe me after 20 odd years in the front face of a working HACCP that the site will engage with – I am right.
- Coding is not a CCP if it is a BBE ie frozen or ambient. It is potentially a CCP if the product is chilled and has a UB. If your product is susceptible to Listeria or C botulinum growth over life, I would suggest it could be a microbiological CCP.
- Cooking is a CCP if we are talking about raw chicken. If we are talking about blanching peas to deactivate enzymes before they are packed in a low risk environment, then it is not a CCP. If we are taking about cooking pasta that is packed or is packed into a pasta salad it is not a CCP. It is a quality cook. Just like baking bread or baked goods in a bakery – not a CCP.
- Sieving is a CCP, I would argue for the #C15 dry powder FBOs. Specially if it is the most robust way of foreign body elimination. It could also be a CCP in other categories like #C12 and #C13, where it is filtration. It is NOT a CCP because certain retailers make the FBO do it like a pizza manufacturer having to sieve bagged salt or flour.
- Spray tunnel into high care is not a CCP. If it is, it is the most flawed CCP in history. Skillets in a sandwich site normally don’t get decontaminated, in fact, neither do loaves of bread, so how can decontaminating other materials be a CCP? And . . .if I walked in one morning to find that Hygiene had never cleaned the factory the night before or we had a fault with the spray tunnel and the items were not decontaminated, as a risk to product in terms of micro, the last thing I would choose would be for the factory not to be cleaned. Why? Because this is a big risk to product safety. And is cleaning a CCP? Of course not, it’s a PRP. And spray tunnel is just an extension of that.
- Positive release or a CoA is never a control step. If we think in purely HACCP terms, it is monitoring procedure not a control measure.
Share your thoughts here . .