Is Hot Filling a CCP
So we just passed our AIB audit and i am rethinking our HACCP program a bit. We currently repack a liquid malt product in small plastic pouches. In the process we heat it up to 161 for 15sec for pasteurization purposes and in order to actually get the stuff to flow through our repack system. We did the pasteurization temp because we have had in the past some mold issues from our supplier, so now a visual check of product and temperature to ensure a quality product.
So my question is, if we visually check for mold/spoilage is it really neccesary to pasteurize the product/document the CCP. Ideally i want to downgrade the CCP but i am having a hard time with the process and reasoning if an auditor asked me. Thanks for any help!
A well executed hazard analysis will tell you if pasteurisation should be a CCP or not. It is however dependent on a lot of factors.
Why exactly are you pasteurising - is it the control step for pathogenic microorganisms or have you built other hurdles into the product to control pathogens (e.g. Preservatives, pH, water activity). If you have these hurdles in place which one will be the CCP for the control of the presence of pathogenic microorganisms in the final product.
Hot filling is often used to control microbiological hazards associated with packaging material - is this why you are doing it or is it purely for the convenience of easy filling.
So the bottom line for me would be the simple question would be:
Why am I doing these steps and are they specifically there to provide absolute control over a specific hazard.
Hope this helps.
Cobus has set it out very well. In addition, a good tip is to go back to the basics of HACCP (i.e. Principles) Why? Because a good auditor will do the same. Pasteurization as a process step is usually based on the principle of a log reduction in the numbers of a specific target pathogen following a hazard analysis. This hazard (and others) can be characterized and then controls can be designed e.g. temperature and time profiles which themselves can be validated. So that's the HACCP bit out of the way. Now you have to ask yourself have you identified a target pathogen and is your pasteurization step specifically designed to control this hazard? Also is there a subsequent step or combination of steps later on that will control the hazard?
It is likely that your pasteurization step is designed more for shelf life issues and in particular yeast and molds. If so you need to ensure that these themselves and their toxins do not pose a risk. Will a reduced shelflife impact on safety? You can also pose the question from the opposite angle. If you were to remove the pasteurization step completely what would be the impact on the risk and safety of the product? In short you need to do a complete risk assessment.
George
Another question you need to ask, is whether or not hot filling is being used to control pathogens after the lethality step.
For example, how are you controling L. mono, in the post lethality environment? Is this product considered RTE? Are there other hurdles to control this hazard?
Many facilties here indicate hot fill is a reason to not meet the Health Canada Guidelines for environmental swabbing. Since the product is being packaged at lethality (72C), any environmental contamination will be controlled through this process. If this is your thought process as well, then this needs to be a CCP, because there will be no control for this further down the process flow.
TJ
Another question you need to ask, is whether or not hot filling is being used to control pathogens after the lethality step.
For example, how are you controling L. mono, in the post lethality environment? Is this product considered RTE? Are there other hurdles to control this hazard?
Many facilties here indicate hot fill is a reason to not meet the Health Canada Guidelines for environmental swabbing. Since the product is being packaged at lethality (72C), any environmental contamination will be controlled through this process. If this is your thought process as well, then this needs to be a CCP, because there will be no control for this further down the process flow.
TJ
Just a comment to yr own comment. I appreciate the OP relevant, L.mono legalistic background to yr post but this approach is surely a purely US/Canadian workaround. Other (less hysterical?) people would say this interpretation simply implies a (frequent?) failure to control the factory environment, ie a PRP collapse which itself needs to be "root analysed" at source.?
Rgds / Charles.C
So we just passed our AIB audit and i am rethinking our HACCP program a bit. We currently repack a liquid malt product in small plastic pouches. In the process we heat it up to 161 for 15sec for pasteurization purposes and in order to actually get the stuff to flow through our repack system. We did the pasteurization temp because we have had in the past some mold issues from our supplier, so now a visual check of product and temperature to ensure a quality product.
So my question is, if we visually check for mold/spoilage is it really neccesary to pasteurize the product/document the CCP. Ideally i want to downgrade the CCP but i am having a hard time with the process and reasoning if an auditor asked me. Thanks for any help!
Hi Pandy,
You need to also consider if the hot filling is also killing mold in the packaging.
Regards,
Tony
Thanks for the input everyone. Because we visually check for spoilage and reject all containers that show signs of mold(seasonal and the supplier has conducted an in depth analysis of the issue and found spoilage was due to differences in cooling and condensation), we are basically hot filliing for ease of packaging. The hot fill process has been in place/pasteurizing process for ages and if we are taking the precautions before hand to prevent spoilage in the product then is it necessary to consider it pasteurization as the water activity is <.1?
Hello Mr Pandy,
You have to establish your raw material specification for APC,YEASTS AND MOLDS AND OTHER PATHOGENS Which should be absent.
Visually molds can be checked only if they are growing and are superficially present in raw material.
Normally bacteria, Molds and yeasts are inherent in raw materials and products which cannot be seen with naked eyes.you have to carry out microbial analysis of your raw material and finished products to establish maximum Limits for microbes and they are also regulatory requirements for microbial limits for finished products.
Malt products are very Nutritious products and ideal for growth of micro-organisms.
Hence to prevent contamination form your equipments.filling machines,packing materials etc you have to carry out hot filling of your malt product and verify your filled product by Microbial analysis from an accredited lab at periodic intervals and thus establish your specifications for microbials parameters for APC,Yeasts and Molds and free of pathogens.
Regards,
sushil