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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.
Seafood HACCP Alliance Training Course 6-2
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.
Seafood HACCP Alliance Training Course 6-3
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.
Seafood HACCP Alliance Training Course 6-4
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.
Seafood HACCP Alliance Training Course 6-5
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.
Seafood HACCP Alliance Training Course 6-6
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.
Seafood HACCP Alliance Training Course 6-7
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.
Seafood HACCP Alliance Training Course 6-8
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.
Seafood HACCP Alliance Training Course 6-9
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.
Seafood HACCP Alliance Training Course 6-10
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:
Seafood HACCP Alliance Training Course 6-11
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.
Seafood HACCP Alliance Training Course 6-12
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!
Seafood HACCP Alliance Training Course 6-13
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!