13 replies to this topic

[Mendeljev]

Dear all,

We are a meat production company where all products are submitted to a heat processing step (either pasteurisation/ sterilisation)

Our current HACCP plan has 3 CCP's

-1 StorageTemperature (of raw materials before production / of pasteurized product)
-2 Metal detection
-3 Heat processing

Currently the area temperature in the preparation areas are seen as a CCP. This means that we have installed limits on area temperatures.
We have problems mainting these limits and have alarms going of frequently
They have set the limits for the raw meat fridge to 4°C ( raw liver/ raw meat) and also the thawing room has the 4°C limit
The other rooms have 7°C as a maximum.

We had recently asked an external auditor to evaluate our system and he said the area temperature of the preperation area is not necciseraly has to be seen as a CCP


let me know your thoughts about this approach.

thx in advance

[saqibfst]

Hi david
auditor is saying right about the area CCP because you are further gonna treat the meat for cooking , is it right?
if u give the details processing steps of your operation it will be easy to understand what u gonna do in your processing steps and give the map also with labelled the area and temp condition.
regardss
saqib

Dear all,

We are a meat production company where all products are submitted to a heat processing step (either pasteurisation/ sterilisation)

Our current HACCP plan has 3 CCP's

-1 StorageTemperature (of raw materials before production / of pasteurized product)
-2 Metal detection
-3 Heat processing

Currently the area temperature in the preparation areas are seen as a CCP. This means that we have installed limits on area temperatures.
We have problems mainting these limits and have alarms going of frequently
They have set the limits for the raw meat fridge to 4°C ( raw liver/ raw meat) and also the thawing room has the 4°C limit
The other rooms have 7°C as a maximum.

We had recently asked an external auditor to evaluate our system and he said the area temperature of the preperation area is not necciseraly has to be seen as a CCP


let me know your thoughts about this approach.

thx in advance

[Mendeljev]

Hello saqibfst

Thank you for your fast answer, here the different steps (in short)

All meat comes in fresh (stored at 5°-7°C ; max 48 hours) or frozen (stored at -18°C // defrosted before use and put at 5-7°C)
-wheighing of batches / mincing meat , product is stored in troleys, they are put in fridge (5-7°C)
- Product is cooked / cuttered in chopperbowl (no temp control of room)
- Product is packed & Sealed (no temp control)
- Product is going to retort and has pasteurisation (p90/10 = 30 min) or sterilisation (F0= 5-6 min)
Sterilised product is stored at room temp
Pasteurized product goes in refrigirator <7°C

thx

[Charles.C]

Dear DavidS,

I am not familiar with meat production though there are several people on this forum who are experienced in this area and will probably make some more informed comments.

However, based on memories of related queries such as this in the past, the usual conclusion is that specifics like you refer are regulatory controlled in meat plants, quite possibly EC controlled also (whether classified as a CCP or not). I presume you are already well-informed over this aspect so what is the situation in Belgium ?

Rgds / Charles.C

PS I was not quite certain whether you were querying only the CCP (or not) aspect or also the various temperature limits referred in yr post. In USA some of the steps in meat processing are regulatory CCPs and, from memory again, this is (maybe implicitly) the case in UK also but EC I am not so sure .

[KTD]

DavidS -
I am not familiar with EU requirements, but assuming they are not too prescriptive & based on US experience:
- I would change room temps to control points
- room temp can be set several degrees higher than the lowest growth temp of the pathogen(s) of interest, maybe with action & warning temps
- if you require a CCP prior to cooking, then it should be the actual temperature of the stored/thawing meat, again based on the lowest growth temp of pathoge(s) of interest
- I am not familiar with pasteurization...is there a cooling curve requirement to prevent outgrowth of spore-formers?

[MKRMS]

Hi DavidS,

The argument is as old as the HACCP system, respective the rules for CCP-determination: A CCP is defined as "a step at which control can be applied and is essential to eliminate or to reduce a hazard to an acceptable level". Your existing temperature control step is only partially covered by this definition, because it is not essential to eliminate the microbiological hazard - your process includes heat treatment before packaging and distribution. Refrigeration is, however, necesary to prevent microbial growth during storage and supports success of your heat-treatment (which remains a CCP in any case).

Although your external Auditor has a point in highlighting that your temperature control during storage is not necessarily a CCP, there is no need to change anything: any change you make would merely affect the name of the control point - it would be 'degraded' from a CCP to an oPRP (a prerequisite that needs defined control), which would remove it from your HACCP-Plan but the need to monitor would remain, because of its sensitivity. You wouldn't gain anything.

I doubt that any official inspector would invalidate your HACCP-Plan because of your 'unnecessary' CCP, especially if you argue that the (EU legislated) need for uninterrupted cold chain management makes close monitoring of this process step necessary, which IMHO technically warrants the introduction of a CCP.

It would be fatal, however, to stop monitoring your chill step during raw material storage, just because it is not a CCP by definition! The cooling step after pasteurization is a CCP, anyways. It meets the definition.

Hope you can understand my thoughts.

MKRMS

[MKRMS]

P.S. I've just noticed that you mentioned the temperature of the preparation area, which does not necessarily have to be a CCP. Your auditor is right again. Again, you can warrant a CCP in this area, even though the definition is not fully met with the need for cold chain management. If it gives you an economical advantage, replace room temperature control (very expensive, switching off the air conditioning might save huge amounts of energy) with product temperature control (slows down preparation, because only relatively small quantities of meat can be prepared without their temperature rising above your legal limit and frequent temperature monitoring is necessary).

Regards,

MKRMS

[Charles.C]

Dear MKRMS,

(Somewhat OT comments since the OP does not indicate any preference for which flavour of HACCP is of interest in current thread).

oPRP (a prerequisite that needs defined control)

I query the terminology that OPRP is a prerequisite. IMO, Prerequisites are (whatever their nominal risk-based affiliation) assumed to be implemented prior to control measures deriving from significant hazards as found from the hazard analysis. OPRPS are clearly not. ISO attempted to blur this discrepancy by neatly "re-defining" OPRP in ISO 22004 (see sec 7.1). (In the earlier pre-final 22000 formats the OPRPs did have a far closer relationship to a "true" prerequisite).
(Of course, if one could define PRPs as any control measure [program] which can be notionally linked to PAS220 regardless of risk evaluation, this might simplify the issue ).

A similar comment relates to the common notion that OPRPs are a sort of "lower-Grade" CCP. This interpretation was not the ISO intention as is evident from the FS validation requirements, etc as, again, conveniently re-iterated in ISO 22004.

@ DavidS - a response to my earlier post might be helpful.

Rgds / Charles.C

[MKRMS]

Hi CharlesC.,

Thanks for your clarification. :-) You are correct, my definition of oPRP as a prerequisite is incorrect.

It appears from reading ISO2004, section 7.1, that a 'three hurdles' approach is intended with the 'traditional' PRPs as hurdle 1, oPRPs as hurdle 2 and the HACCP plan as hurdle 3. Only a combination of the three hurdles is viewed as adequate control. The advantage over the traditional 2-hurdle approach is that controls that are not defined as a CCPs are no longer overlooked. In this context, the concept of oPRP provides clarification and helps to organise control measures in the framework of HACCP-definitions.

Nevertheless, from a practical view, the re-naming of control measures does not automatically add to the overall quality of every existing system - DavidS' system, which currently uses 3 CCPs would have to be re-organised to introduce the new layer, but no operational improvement (e.g. reduction of paperwork, cost savings, increased process safety) would result from this change. In my opinion, the system would become more complicated and a need for additional training and a chance for additional mistakes would be created.

Thanks again for the clarification,

MKRMS

[beatlevi]

Hi David S, in my experience : for the temperature of storage is not a CCP but must be in your prerequisite of your transport/storage program. Metal detection and meat cooking, I approve as a ccp but I think you must have also a cooling procedure.



Beatlevi

[vukasin]

Hi DavidS,

As others have noted, I also wouldn't say storage room temperature is CCP.
That said, it is true that it has to be monitored. It is definitely a control point, and no matter how you choose to call it you'll have to monitor it.

You said that alarms are going of frequently, and it's quite understandable, because it is hard to maintain cold storage air room temperature at constant levels with all that walking in and out of it. The air temperature usually fluctuate often during work day, but it doesn't mean that the meat temperature is also changing that fast. It is ok to set your cold storage room working air temperature to 4°C, but you can allow it go up to 8°C (or even higher) without alarm, as long as you did checks to ensure that the temperature of the meat doesn't rise significantly. Also, as your raw meat is stored for max 48 h, pathogens of concern are not likely to rise significantly at suggested temperatures.

Also, your thawing room has the 4°C limit. Why did you choose that temperature? It can depend on the size of the meat chunks you are thawing and the time required, but thawing room temperature can be higher.

As for the air temperature in the other rooms, I don't think 7°C is necessary. I believe there is a 12°C air temperature requirement in the EU legislation. And I don't think that you should use sound alarm for this, but if you do you might also want to set it at slightly higher temperature.

As others have said, you should include cooling time in your HACCP plan, because of spore forming bacteria. Note that you have 2 cooling steps, one before packing and one after pasteurization, unless it's continuous process.

[foodsafetyboy]

Dear all,

We are a meat production company where all products are submitted to a heat processing step (either pasteurisation/ sterilisation)

Our current HACCP plan has 3 CCP's

-1 StorageTemperature (of raw materials before production / of pasteurized product)
-2 Metal detection
-3 Heat processing

Currently the area temperature in the preparation areas are seen as a CCP. This means that we have installed limits on area temperatures.
We have problems mainting these limits and have alarms going of frequently
They have set the limits for the raw meat fridge to 4°C ( raw liver/ raw meat) and also the thawing room has the 4°C limit
The other rooms have 7°C as a maximum.

We had recently asked an external auditor to evaluate our system and he said the area temperature of the preperation area is not necciseraly has to be seen as a CCP


let me know your thoughts about this approach.

thx in advance

Hello,

In my experience, the temperature of the preparation area is not really considered as a CCP.
We have temperatures for the preparation area running up to 22oC max. However food handling is minimized for up to 30mins max with product core temp of 12oC for food items that is not going to be cooked and a maximum time of 2hours for items intended for cooking.
7oC as room temperature is very good as you will not be needing to look at the food handling time and product temperature that much.

Regards,
FSB

[Mendeljev]

@ DavidS - a response to my earlier post might be helpful.

Rgds / Charles.C

In Belgium we also have an autocontrole system, this is covered by the governement. They have created HACCP plans for different product groups, and in our group, the room temperature is included as a ccp.
So this means that we have no other choice then looking at it as a ccp

[Charles.C]

In Belgium we also have an autocontrole system, this is covered by the governement. They have created HACCP plans for different product groups, and in our group, the room temperature is included as a ccp.
So this means that we have no other choice then looking at it as a ccp

Dear DavidS,

Thanks. This (rightly or wrongly) suggests that yr auditor's opinion(s) is irrelevant.
And does the government also specify the critical limits ? (Perhaps this is what you meant by "they" in yr original post, i had assumed you meant the producer).

Rgds / Charles.C