Introduction - Cornell Universityseafoodhaccp.cornell.edu/blackboard/module6/pdfmod6/mod6.pdf · Introduction In this module we'll learn about the second principle of HACCP, Critical

Seafood HACCP Alliance Training Course 6-1

Introduction

In this module we'll learn about the second

principle of HACCP, Critical Control Point (CCP)

determination. In module 5 you learned the first

principle of HACCP—hazard analysis—where you

determine what hazards need to be controlled in

your HACCP Plan. Now, for each significant hazard

that was identified during the hazard analysis you

will need to determine where the hazard is

controlled. The CCP's are the points in the process

where HACCP controls are in place. There are 13

pages, 7 CCP interactive worksheet examples, and

4 questions in this Module.


What is a Critical Control Point?

First, let's make sure you understand the

definition of a critical control point.

A Critical Control Point, or what we will

now refer to as a CCP, is:

"a step at which control can be applied and

is essential to prevent, eliminate, or reduce

a food safety hazard to an acceptable level."

A "step" means a place in your Process

Flow Diagram. That means for every

significant hazard that you identified in

your hazard analysis (1st Principle),

there must be one or more specific steps

in your Process Flow Diagram where the

hazard can be controlled. These points in the

process flow are called CCPs.


Critical Control Point Placement

Remember in Module 5 we discussed control measures and said they are "actions

or activities designed to control a hazard." In order for a processing step to be

a CCP for a particular hazard, one or more effective control measures

must exist at that processing step. If there are no adequate control measures

at a particular process step, that step will not be the CCP for that significant

hazard. In some cases control measures could be applied at a particular step, but

that step may not be the best place to control the hazard. In that case, a

processing step that occurs later in the process flow may be the best CCP for that

hazard.

For example, ABC Shrimp company identified bacterial pathogen growth as a

significant hazard at the receiving step. Although time/temperature controls at

receiving could slow down the growth of bacterial pathogens it is not the best

control. As the cook step will eliminate this hazard —it is identified as the CCP.


Examples of Critical Control Points

We now know that in order for a processing step to

be a CCP you must be able to prevent, eliminate

or at least reduce a significant food safety

hazard to an acceptable level. Let's take a look

at some examples:

CCP's where hazards can be prevented.

•Chemical hazards caused by the addition of

too much of a food additive can be prevented

at the step where the ingredient is added

(CCP).

• Pathogen growth in the finished product can be

prevented at the step where a preservative

such as nitrate, salt, or acid is added (CCP) by

controlling the amount that is added to the

product.

• Chemical hazards such as drug residues in

aquaculture products can be prevented at

the receiving step (CCP) by using controls such

as supplier declarations or testing.


Examples (continued)

CCP's where hazards can be eliminated.

• Pathogens can be eliminated (killed) at the

cooking step (CCP) by controlling the time and

temperature used for cooking.

• Metal fragments that may be in the finished

product can be eliminated at a metal detector

step (CCP). Any product containing metal

fragments large enough to be detected by

existing technology would be removed from the

processing line.

• Parasites can be eliminated (killed) at a

freezing step (CCP) by controlling the freezer

temperature and how long the product is held

at that temperature.


Examples (continued)

CCP's where one or more hazards can be

reduced to acceptable levels.

• The possibility that biological hazards, such as

pathogens, and chemical hazards, such as

natural toxins, will be present at unacceptable

levels in shellfish can be reduced to

acceptable levels at the receiving step

(CCP). This is done by ensuring that shellfish

being received are properly tagged and have

been harvested from approved waters or are

from certified dealers.

• The possibility that environmental chemical

hazards such as PCBs will be present in fish at

unacceptable levels can be reduced to

acceptable levels at the receiving step

(CCP). This is done by ensuring that the fish

being received were not harvested from

waters that have been closed by local or state

health authorities.

• The possibility of Pathogen growth caused by

time/temperature abuse can be reduced to

acceptable levels at a storage step (CCP) by

controlling cooler temperatures or using

adequate ice.


Control Point or Critical ControlPoint?

As you work through your Process Flow Diagram

there may be many steps in the process that

will not be identified as CCPs. These points are

called control points. Control points may address

control of quality factors such as color or flavor or

non-HACCP regulatory requirements such as

standard of fill. It's important to note the

difference between what is a control point and

what is a CCP. A HACCP plan can lose focus if

points in the process are unnecessarily

identified as CCPs.

CCPs should be limited to only those

specific steps in the process at which food

safety hazards can best be controlled. For

example, a metal hazard can be controlled in

several ways, by ingredient sourcing, magnets,

screens and a metal detector all in one line.

However, all of these processing steps need not be

considered CCPs if the best control is the use of a

metal detector.

Using our example of ABC Shrimp company, they

list 21 processing steps, but when this module is

completed you will find that there are only two

CCPs.


Multiple CCPs and Multiple Hazards

A CCP can be used to control more than one

hazard. For example, refrigerated storage might

be identified as a CCP to control both pathogen

growth and histamine.

Likewise, more than one CCP may be needed

to control a hazard. For example, receiving,

processing and storage may need to be CCPs for

those processors that are receiving, processing

and storing non-frozen fish that have a histamine

hazard, such as some tuna. This is because

histamine can develop in these fish when they are

exposed to elevated temperature over a certain

period of time. Any step in the process where

there is a potential for significant time/

temperature abuse must be identified as a CCP.


CCPs are Product and Process Specific

CCPs identified for a product on one processing line may be different for

the same product on another processing line. This is because the hazards

and the best process steps at which they would be controlled may change with

differences such as: plant layout, formulation, process flow, equipment, sanitation

and support programs, and other ingredients that may be used.

Your company's HACCP plan must be designed for the specific product

and process that you use. There are several generic HACCP models available

which can be useful in helping you to evaluate your HACCP plan. Keep in mind

that your product or processing line may be different from the model. In order to

develop an adequate HACCP plan you need to evaluate your own unique

operation.

Tools to Help You Identify CCPs

There are several tools available to help you identify CCPs for significant hazards.

The FDA Hazards Guide, discussed in Module 5, provides guidance on likely CCPs

for each of the potential food safety hazards associated with seafood products.

The Hazards Guide is designed to walk you through chapters that cover each of

these hazards. Step number 12 in each of these chapters provides information on

identifying appropriate CCPs.

Another tool that can help you identify appropriate CCPs is a CCP Decision Tree.

Let's take a look at this tool and work through some examples.


CCP Decision Tree

A series of questions has been developed that can help you to identify the CCPs in

your process. These questions are referred to as a CCP Decision Tree. You can

apply these questions at each of the processing steps in your flow diagram where

you have identified a significant hazard in your hazard analysis (HACCP principle

1). Properly used, the CCP Decision Tree can be a helpful tool in identifying CCPs,

but it's not a perfect tool and should not be used as a substitute for expert

knowledge.

The CCP Decision Tree asks a series of four questions that will lead you to decide

if a specific processing step is a CCP. It looks like this:


Let's take a look at the questions in the CCP Decision Tree and then work through

some examples.

At each processing step where you identified a significant hazard, the CCP

Decision Tree prompts you to ask yourself the following questions:

Question 1. Do control measures exist at this step or at subsequent steps

for the identified hazard?

• If your answer is yes, ask Question 2.

• If you can't identify a control measure at this step in the process flow answer

no. Then ask: Is control at this step necessary for safety? If the answer is

again no, the process step is not a CCP for that hazard and you will move to

the next step where you identified a significant food safety hazard. If the

answer is yes than you have identified a significant hazard that is not being

controlled. In this case, the step, process or product must be redesigned to

include a control measure. Sometimes there is no reasonable control measure

available. In such cases, HACCP does not provide assurance that food

products are safe.

Question 2. Does this step eliminate or reduce the likely occurrence of a

significant hazard to an acceptable level?

*To answer this question, consider if this is the best step at which to control the

hazard.

• If the answer is yes, then the step is a CCP and you would move on to the

next process step where you identified a significant food safety hazard.

• If the answer is no, ask Question 3.

Question 3. Could contamination with an identified hazard(s) occur in

excess of acceptable levels, or could these increase to unacceptable

levels?

*This question refers to contamination that exists, occurs or increases at this

step.

• If the answer is no, then the step is not a CCP for that hazard and you would

move on to the next process step where you identified a significant food

safety hazard.

• If the answer is yes, ask Question 4.

Question 4. Will a subsequent step eliminate the identified hazard or

reduce the likely occurrence to an acceptable level?

• If the answer is no, this step is a CCP.

• If the answer is yes, then this step is NOT a CCP for the hazard. In this case,

be sure the hazard is controlled by a subsequent processing step.


Now, it's up to you to try and apply the CCP decision tree to the ABC Shrimp example. The first step is to

outline each process step that was identified as having a significant hazard. In Module 5, we identified

the hazard of bacterial pathogen growth, sulfiting agent, and pathogen survival at several process steps.

If we were to put these process steps and hazards into a table, and then provide a column to answer each

of the CCP Decision Tree questions, it might look like this:

CCP Decision Tree Table for ABC Shrimp Co. Example

We'll use an Interactive CCP Decision Tree to answer the four questions for each process step and

hazard in this table. When you've completed each example using the CCP Decision Tree, you'll return to

this table and the answers to Q1 through Q4 will have been entered into the table. The final column will

have a "Yes" or a "No" to indicate whether or not this step is a CCP for this hazard. Click on the "Yes" or

"No" answer in the CCP column and you will be transported to your Hazard Analysis Worksheet where

your answer will be recorded. After reviewing this worksheet you'll move on to the CCP Decision Tree

exercise for the next processing step.

When the table is complete you will have used the CCP Decision Tree to determine which steps in the

ABC Shrimp Company example are CCPs. You will have also completed the Hazard Analysis Worksheet

that you began in Module 5.

Tips on Using the Interactive CCP Decision Tree

You will need to return to Module 6 (page 6-12) via the Internet to go through the interactive portion of

this Module. You will probably need 25 to 30 minutes to work through this part of the Module.

Have fun!


Check Your Knowledge

Now you need to return to Module 6 via the Internet.

Click through the text pages until you get to the Check Your

Knowledge page (page 6-28). Submit your answers before

moving on to Module 7.

Good Luck!

Documents

Introduction - Cornell Universityseafoodhaccp.cornell.edu/blackboard/module6/pdfmod6/mod6.pdf · Introduction In this module we'll learn about the second principle of HACCP, Critical