What is a CCP?
The second principle of HACCP is to determine whether a critical control point (CCP) is required to a control significant hazard identified in the hazard analysis. Codex guidance defines a CCP as a ‘step at which a control measure or control measures, essential to control a significant hazard, is/ are applied in a HACCP system’1. Control applied at a CCP may control more than one hazard (e.g. cooking) or more than one CCP is required address the same hazard (cooking and cooling for a spore-forming pathogen1.
CCP Decision Tree
The HACCP team can use a decision to identify a CCP1. Although, this useful tool should not be a substitute for expertise required to determine a CCP because inaccurate conclusions could be made. The two most common CCP decision trees used are published by Campden BRI and Codex (page 47).
The Codex decision tree has been updated with new and revised questions to determine a CCP at a specific step in the process. These questions are examined in detail below.
Question 1
‘Can the significant hazard be controlled to an acceptable level at this step by prerequisite programmes (e.g. GHPs)?’
This question is only for a significant hazard identified by the hazard analysis in the previous HACCP principle/step. It is important to understand that PRPs are applied generally and may not be sufficient to ensure food safety due to the complexity of the operation or specific hazards associated with the product or process1.
If the answer is ‘yes’, this step is not considered a CCP. This outcome must be backed up by sound technical and scientific evidence to prove the hazard is controlled at an acceptable level by PRPs in relation to its intended use downstream. PRPs that control a specific hazard (e.g. cleaning, temperature control, etc.) must be validated and determination of an acceptable could be benchmarked against a regulatory or scientific limit. If the answer is no, then progress to the second question.
Question 2
Do specific control measures for identified significant hazard exist at this step?
This second question is an adaptation of the first question in the previous version of the Codex CCP decision. The addition of the word ‘specific’ confirms a control measure used at this step is specific to this hazard and not a prerequisite programme2. The word significant is also included to stress again the application of the CCP decision tree is only used for significant hazards2.
If the answer is yes, progress to the next question. If the answer is no, then this step is not a CCP and subsequent steps should be evaluated for a CCP1. A footnote for this outcome also states the process or product should be modified to implement a control measure if no CCP is identified questions two and four1.
Question 3
‘Will a subsequent step prevent or eliminate the identified significant hazard or reduce it to an acceptable level?’
Question three was originally question four in the previous version of the Codex CCP decision tree. The word ‘prevent’ has been added to the question ‘because’ it aligns better with the definition of a control measure2.
If the answer to this question is yes, then a subsequent step in the process should be a CCP. This permits the presence of a hazard at one step if it is likely to be controlled further on in the process. If the answer is no, then progress forward to the final question.
Question 4
‘Can this step specifically prevent or eliminate the identified significant hazard or reduce it to an acceptable level?’
This question is a modified adaptation of the second question in the previous CCP decision tree. The new version is more to the point as the word ‘is’ has been replaced with ‘can’ at the beginning of the sentence and the removal of the ambiguous term ‘designed’.
If the answer to this question is ‘yes’, then this step should be considered a CCP. This conclusion follows a singular route to determine a CCP compared to the previous version in which two paths were available. If the answer to this question is ‘no’, then modify the step, process or product to implement a control measure, and return to the start of the CCP decision tree after completing a new hazard analysis1.
A footnote for the question also considers whether a control measure at a process step is used in combination with a control measure at another step to control the same hazard. If the answer is yes, then both steps in the process should be considered as CCPs. For example, cooking is a CCP to destroy vegetative cells of a pathogenic spore-former and cooling is a CCP to prevent germination and outgrowth of the spore1.
Document CCPs
Decisions for determination of a CCP at a specific process step must be documented. This record must show justifications for outcomes of questions to prove decisions were based on sound evidence. Evaluations of CCPs can be recorded in a table and any identified CCPs are clearly shown on a process flow diagram. Documented decisions for CCPs support due diligence, provide an auditable record and assist in the review of the HACCP plan.
What if No CCP is Identified?
There are occasions when no CCPs are identified. This can occur when a hazard is controlled by prerequisite programmes or if the rationale behind the application of HACCP is misunderstood3. If no CCP’s are identified, then justifications for answers should be rechecked to make sure nothing has been missed and conclusions are based on sound evidence. The absence of CCPs means the HACCP team can miss principles 3 to 5, and progress directly to principle 6 (validation and verification)3.
Some significant hazards are also unable to be controlled by CCPs even if the product or process is redesigned, for example presence of a chemical hazard3. This may require sourcing of raw materials being elevated to a CCP level3.
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