Controlling Process Risk
I am seeking a very clear explanation about controlling hazards that affects the process but not directly the final product. There is nearly zero possibility of affecting consumer. For example, we are using food grade sodium alginate as an additive. As per the specification, Sodium alginate is free from pathogenic microorganisms but APC is below 5000 cfu/g. In our process, we sterilize sodium alginate before adding to the process. Otherwise, bacteria will multiply and will cause the loss of the intermediate batch. Now my question is, how shall I define this control? In my understanding this sterilization cannot be termed as CCP. I am bit confused about categorization of this control point. I would highly appreciate the clear explanation.
Hi Mazid,
A little more context will probably be required, eg -
(1) What is the final Product / Process steps ?
(2) How is the sterilization of Na Alginate performed ?
We will sterilize by thermal process.
Note that the gel will be exposed to room temp for certain times.
Hi Charles, final product is a gel that is going to be added to raw meat.
We will sterilize by thermal process.
Note that the gel will be exposed to room temp for certain times.
Hi Mazid,
Thks for info.
So what is the specific safety related hazard that you are trying to control ? (As I understand the alginate is already "guaranteed" pathogen free ?)
Yes it is pathogen free. But there will be growth of spoilage bacteria and destroy the gelation process if we don't steriliza the sodium alginate. It's related to process safety but not the food safety.
I'm not a user of fssc22000 but this sounds more like a quality problem. HACCP afaik is only for safety/health-related risks (to the consumer).
Yes, exactly. It is a quality problem. I am bit cofused about addressing quality hazards in the HACCP plan. They can be categorized as Biological and heavily affect the process. But definitely, food safety risk is minimal here. Now, we need to sterilize them by eithre filtration or by thermal process, eventually needs monitoring the critical limits. How these quality issues are generally addressed in the HACCP Plan?
Yes, exactly. It is a quality problem. I am bit cofused about addressing quality hazards in the HACCP plan. They can be categorized as Biological and heavily affect the process. But definitely, food safety risk is minimal here. Now, we need to sterilize them by eithre filtration or by thermal process, eventually needs monitoring the critical limits. How these quality issues are generally addressed in the HACCP Plan?
Hi Mazid,
The original Scope of HACCP as formalised around 1980's included certain quality risk aspects as well as safety issues however the quality portion was abandoned in the foundation HACCP Systems published by Codex and NACMCF in 1990s.
The haccp portion of fssc22000 is based on iso220000 (= so-called iso-haccp) which expands the control measure philosophy as compared to Codex/NACMCF but retains the Safety-oriented focus.
Afaik, the only current dedicated treatment of Food Quality Risk within a haccp-like structure is the System developed/published by SQF which operates in parallel to their Safety-focused System. BRC's Food Standard also involves (raw material) quality elements in addition to Safety
Nonetheless FSSC 22000 has, by design, a much broader Scope of haccp-application than Codex et al so fssc22000 users here may be able to suggest a way whereby yr Process can be integrated within the former. Hope so.
PS - Just remembered that Woolworths Australia also publish a quite comprehensive Quality-based hazard control sub-System which IIRC is integrated with the Safety-related Section into an overall HACCP Structure.
Both SQF/Quality and Woolworths's HACCP Systems are freely downloadable from IT.
PPS - ISO9001 is of course the classic Generic Quality Assurance/Control System, ISO22000 being its Safety/HACCP-based equivalent.
P3S - I deduce that yr manufacturing process per se is applicable to fssc22000/section K but I am less aware of what kinds of hazards could be relevant.