Design of CCP Monitoring Programs

Contents

1. Introduction
2. Definition of CCP Monitoring
3. Why is Monitoring Needed?
4. Determination of CCP’s
5. Critical Limits
6. Methods of Monitoring
7. Monitoring Frequency
8. Monitoring Records and Documentation
9. Corrective Action and Deviation Management

1. Introduction

One of the few things we can be certain of in our world is uncertainty. Philosophers have been preoccupied by this phenomenon for centuries and the seemingly relentless drive of nature to introduce change and variation into even the most stable of systems. This is not necessarily a bad thing. Many believe that uncertainty or variation is the key driver behind all developments and improvements in nature. Whether this is true or not, one thing we know for sure is that variation in a manufacturing process if not controlled will lead to product failures, waste and overall poor quality. In food manufacturing it can also lead to food safety issues. The eminent statistician, W. Edwards Deming, dedicated much of his career to studying the nature of variation in production processes and came to many conclusions including “If you can’t describe what you are doing as a process, you don’t know what you’re doing”. This tells us a lot about the nature of food safety management. HACCP is the tool we use to describe ‘what we are doing’. Once we know this we can then get on with the business of monitoring and checking and the Critical Control Point (CCP) is the highest expression of this tool.

Describing and Monitoring are two sides of the same coin. One without the other is meaningless. As Deming states, once we can describe what we are doing we can then measure and monitor our performance. The data from monitoring can be fed back into our understanding to improve it and our feedback loop is complete. The scope of this whitepaper does not cover the Describing stage which is the subject of HACCP planning in general. Instead we will focus on the Monitoring aspect of food safety and specifically the CCP. Proper design of CCP monitoring programs is an essential ingredient in any food safety management system capable of producing safe food products. Since variation is an inevitable part of any process we must assume it will happen and when it does our monitoring program will detect it especially when critical limits are exceed. Only then can we take the required corrective action that protects the consumer and the business. In many ways CCP’s are the last line of defence and demand we put sufficient time and resources into their proper design, maintenance, review and improvement.

2. Definition of CCP Monitoring

Before we examine the detail of an effective CCP monitoring program it is important to clearly define what we mean when we speak about CCP’s and Monitoring. Here are some widely used definitions:

Critical Control Point (CCP): Step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level
This standard definition of a CCP refers normally to a specific stage or step in the process. As we know all food manufacturing processes are made of a sequence of steps, activities and stages which ultimately lead to the production of the final food product ready for distribution to the consumer. Depending on the process there will likely be one or more specific steps in the process which if not maintained under control may lead to the consumer becoming ill or being impacted adversely. It is also possible that certain food processes do not have a CCP in the strict context of Codex and global food standards. However, the best practice described in this whitepaper remains valid for general PRP’s, operational PRP’s and quality control points (QCP).

Monitoring: The act of conducting a planned sequence of observations or measurements of control parameters to assess whether a CCP is under control
In this definition, we view monitoring as an activity conducted by the company focused on measuring and collecting data relating to processing parameters. This information allows us to decide whether the CCP is under control and therefore the process is producing safe food – this is why monitoring is such an important activity in your food safety system. It is also important to point out that the above definition mentions parameters and not the specific hazard of concern. It is often the case that direct measurement of the hazard e.g. pathogens is not possible or practical. Monitoring will need to rely on measuring a secondary parameter such as temperature to make your decisions on product safety in real time.

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