CCP Critical Limit and Corrective Action - Plastic Brush Parts

P

patriot19472001

#1
Dear Food Professionals,

We have a Frozen French Fries production line. In line the 3rd step is Brush Peeler which removes the skin of Potatos with the help of small plastic brushes. During Hazard Identification stage in HACCP we declared it a CCP. But now I'm confused with following questions:

1-In Hazard Analysis this Step has a very Low Severity(1) and also no past occurance History. So is it correct to declare it a CCP?

Moreover If we Declare it a CCP then:

2- What will be the critical limit for a Plastic Food Grade Brush?
3- If we defined a descriptive critical limit(like physical inspection) then it be acceptable or not?
4- And finally if we found that some plastic brush pieces aren't with the brush then what can we do with the product as its not possible to inspect the whole product and we also don't have any X-Ray(example) type or any other scanner to scan the product.(We only have metal detector)

Attached file will clear the situation more.

A huge thanks for an early (and obviously for the late) response.

Regards,

Ghulam Mustafa
 

Attachments

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P

patriot19472001

#3
Dear All,

Hope that you will be in good health and spirits. I have replied by my Boss on the aforesaid issue. Can anyone/auditor confirm it!

1- We have cooking guidlines on our label that there's a need to cook the Frozen French Fries at Temperature of atleast 150 C for 5 mins. My boss claims that our plastic brushes are food grade and if these include in product(even with non occuring history) then these small pieces will melt during cooking hense no hazard for the consumer(because brush is food grade).

Is this logic applicable?

Thanks in advance.

Ghulam Mustafa
 
K

K-dix

#4
Dear All,

Hope that you will be in good health and spirits. I have replied by my Boss on the aforesaid issue. Can anyone/auditor confirm it!

1- We have cooking guidlines on our label that there's a need to cook the Frozen French Fries at Temperature of atleast 150 C for 5 mins. My boss claims that our plastic brushes are food grade and if these include in product(even with non occuring history) then these small pieces will melt during cooking hense no hazard for the consumer(because brush is food grade).

Is this logic applicable?

Thanks in advance.

Ghulam Mustafa
OK, the question is, is the next step -which is even out of your control (cooking by the customer) supposed to be done to control the physical contamination by plastic bristles on the product? and worst, what if the customer notice any bristle on the product the moment is about to cook them? are you going to tell them is food grade and they can eat them anyway? or are brush bristles in the list of ingredients on the product label? (!)
 
P

patriot19472001

#5
Dear K-Dex,

First of all thank you so much for your response. I'm agreed with you but i have some other questions also!

We have a Frozen French Fries production line. In line the 3rd step is Brush Peeler which removes the skin of Potatos with the help of small plastic brushes. During Hazard Identification stage in HACCP we declared it a CCP. But now I'm confused with following questions:

1-In Hazard Analysis this Step has a very Low Severity(1) and also no past occurance History. So is it correct to declare it a CCP?

Moreover If we Declare it a CCP then:

2- What will be the critical limit for a Plastic Food Grade Brush?
3- If we defined a descriptive critical limit(like physical inspection) then it be acceptable or not?
4- And finally if we found that some plastic brush pieces aren't with the brush then what can we do with the product as its not possible to inspect the whole product and we also don't have any X-Ray(example) type or any other scanner to scan the product.(We only have metal detector)

Thanks in advance:)

Regards,

Ghulam Mustafa
 
J

jmann

#6
Dear K-Dex,

First of all thank you so much for your response. I'm agreed with you but i have some other questions also!

We have a Frozen French Fries production line. In line the 3rd step is Brush Peeler which removes the skin of Potatos with the help of small plastic brushes. During Hazard Identification stage in HACCP we declared it a CCP. But now I'm confused with following questions:

1-In Hazard Analysis this Step has a very Low Severity(1) and also no past occurance History. So is it correct to declare it a CCP?

Moreover If we Declare it a CCP then:

2- What will be the critical limit for a Plastic Food Grade Brush?
3- If we defined a descriptive critical limit(like physical inspection) then it be acceptable or not?
4- And finally if we found that some plastic brush pieces aren't with the brush then what can we do with the product as its not possible to inspect the whole product and we also don't have any X-Ray(example) type or any other scanner to scan the product.(We only have metal detector)

Thanks in advance:)

Regards,

Ghulam Mustafa
I would first ask yourself what hazard are you trying to control at this step? What physical/chemical/biological hazard will be either eliminated or reduced to an acceptable limit at this step? Your hazard analysis indicates this as low severity so it would appear it might not designate itself as a CCP but moreso a Control Point or Operational PRP.
 
#7
If I am reading you right, the hazard is physical contamination from parts of the brush getting in with the product. The questions relate to that risk.
What would be the risk/effect of having brush bristles (or fingers, or whatever you call them) mix into your fries? You claim it has a low severity, meaning that it will not do much damage. You also state there is no record of this occuring, which would indicate that it is not expected to occur. Those two items typically would mean that it would not be a high risk item.

But, just because ther is no record of it happen, do we know it has not happened? You can still control the risk. But you need to determine what the thresholds (or limits) would be, and how you measure it.
 
P

patriot19472001

#8
If I am reading you right, the hazard is physical contamination from parts of the brush getting in with the product. The questions relate to that risk.
What would be the risk/effect of having brush bristles (or fingers, or whatever you call them) mix into your fries? You claim it has a low severity, meaning that it will not do much damage. You also state there is no record of this occuring, which would indicate that it is not expected to occur. Those two items typically would mean that it would not be a high risk item.

But, just because ther is no record of it happen, do we know it has not happened? You can still control the risk. But you need to determine what the thresholds (or limits) would be, and how you measure it.
Dear Jmann and Dave B,

Thank you so much for your questions and guidance. Please consider the below points:

1- These brushes are at 3rd and final step of manufacturing.
2- This is a physical hazard and we don't have any subsequent step to remove these pieces so i Declare it CCP even the severity was low with NO PAST OCCURANCE HISTORY.
3- Can you guide me please that how can it be an OPRP or how any modification/operation can control it?
4-What will be the critical limits for pieces of a plastic food grade brush?
5- We have only visual checking method once/week earlier (now its more frequent checked). Can we put another checks on it?

Thanks again for your comments and guidance and Obviously waiting for guidance on above points.

Regards,

Ghulam Mustafa
 
J

jmann

#9
Dear Jmann and Dave B,

Thank you so much for your questions and guidance. Please consider the below points:

1- These brushes are at 3rd and final step of manufacturing.
2- This is a physical hazard and we don't have any subsequent step to remove these pieces so i Declare it CCP even the severity was low with NO PAST OCCURANCE HISTORY.
3- Can you guide me please that how can it be an OPRP or how any modification/operation can control it?
4-What will be the critical limits for pieces of a plastic food grade brush?
5- We have only visual checking method once/week earlier (now its more frequent checked). Can we put another checks on it?

Thanks again for your comments and guidance and Obviously waiting for guidance on above points.

Regards,

Ghulam Mustafa
Regarding point 2, if this is declared as a Physical Hazard, what severity rankings are used to establish its impact to the consumer. It appears that you may have combined occurrence rate into that severity ranking. If that's the case, you should treat them separately. If you find that the severity is high due the hazard impact to the consumer, then you'll have to understand how best to control this step.

I would argue it is a CCP if you do not have any further downstream process steps that would monitor for any foreign material introduced at this step. If that is how your process is set-up, then you should consider improving your monitoring activities. Look to make this decision based on known risk, capability, and production needs.

Regarding point 4, this is a sensitive area in which you may look to regulatory guidelines but ultimately, you should look to your customers as understanding their expectations.

As another forum member pointed out, can you further eliminate this hazard by modifying this process?

Hope these questions help.
 
P

patriot19472001

#10
Dear Jmann,

Heartiest thanks for your reply. Please consider the following points

1- For determining severity rankings please see the below table we use

Severity if controls fail
Severity of affect if Hazard Occurs

Multiplier
Little Damage

Mild disappointment to the consumer. May lead to a complaint, no business interruption. Minor consequences.
1
Damage
Very minor medical treatment, (for example a broken tooth). Consumer disappointed and likely to lead to a complaint to the Company.
2
Serious Damage
Illness at home. Medical treatment not necessary. A disappointed consumer very likely to lead to a complaint to a regulatory authority.
3
Very Serious Damage
Illness at home with medical treatment necessary. A very disappointed consumer. A significant risk of proscecution.
4
Disaster Serious Illness
Hospitalization required. Significant risk of proscecution. Media coverage. Intervention by ?Crisis management team?. Damage to ?branded ? image.
5
Catast-rophic
Death. Top level ?crisis management? Certain risk of proscecution. Destruction of ?brand?
6



2- Hazard to consumer is very low so severity is low

3- We also don't have any past occurance about this HAZARD. But there is a chance of occurance.

I think now it is more clear. I'm still confused that may i declare a frequency for change of brushes after studying the condition of brushes(rupturdness) but what about the particles passed in the product(if any)?

One form is attached for more clarification.

Regards,

Ghulam Mustafa
 

Attachments

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