Just wish to state my opinion based on a submission where I noted the conclusions were marked as "CCP" and "sensitive raw material" as opposed to "Not a CCP" and may be "sensitive raw material" or not.
Are we examining a Critical Control Point [CCP] and / or a sensitive material for raw materials or packaging materials?
The definitions provided in the Standard are:
Critical control point - A point, step, or procedure in a food process at which control can be applied and, as a result, a food safety hazard can be prevented, eliminated, or reduced to acceptable levels.
Sensitive raw materials/ingredients – Materials forming part of a product, e.g. primary produce, additives, processing aids as well as packaging and similar materials that could result in an unacceptable food safety risk to consumers and need to be controlled.
Issue #1.
In key discussions and literature review, users are worried about assessment of risks and leading to identification of additional CCPs and lot of additional monitoring as well as effective control measures. As such, with so many attempts to recognised allergens caused by Big 8 including eggs, milks and nuts as its own hazard #4 was widely discussed – and should be categorised under physical or chemical matters. No one can safely estimate what is the critical limits to a consumer as the tolerance level of individuals differ. The best is zero raw materials that are sensitive to every consumers in terms of food safe for consumption.
Issue #2.
Clause 5.2.4.3 provides the use of Figure 2a, which shall be used as guidance when determining CCPs. However, in Figure 2a logic reasoning path do not provide assertions to identifying and confirming a CCP.
In the case of a raw material e.g. cocoa powder and dairies which can cross-contaminate an entire facility or to other products will not be controlled, then CCP is required to monitor the activity. However the likelihood of users to answer – “no” there is no chance of cross-contamination due to control measures taken has eliminated the item as sensitive raw materials to cross contaminate does not eliminate the product being sensitive itself.
My conclusion,
Clause 5.2.4.3 is defective due to its circumstantial provision of logic reasoning. Raw ingredients, raw materials or packaging materials should only limit itself to identification as being sensitive or not. It should not tantamount to having determine that there is a Critical Control Point. The recognition of a CCP should remain in process steps of a facility rather of the materials.
Erasmus Koay,
FSSC Lead Auditor.
MIENS