Are hydrocooling and fruit washing critical control points (CCPs)?
Determining whether or not hydrocooling and fruit washing constitute a critical control point starts with your hazard analysis and risk assessment. Within that analysis and assessment, and according to PrimusGFS 3.2, 6.02.01 interpretation guidelines: one should “Consider pre-requisite programs (PRPs) in place which provide basic environmental and operating conditions necessary for the production of safe, wholesome food and support decisions in the hazard analysis.” And in 6.02.02: “The CCPs should be created from the documented hazard analysis i.e. there should be a logical documented approach (such as utilizing a CCP decision tree that justifies whether or not there is a step(s) in the process determined to be a CCP(s).”
In CODEX General Principles of Food Hygiene CXC 1-1969, Revised 2022, you will find “Figure 1: Example of a CCP decision tree,” and this question:
A recent CONTACT webinar on washwater included an excellent discussion of this topic led by Faith Critzer, Ph.D. from the University of Georgia. (A recording of that particular webinar should be posted by mid-May, but there are plenty of others on that site worth your time. Unfortunately, the future of this webinar series is in jeopardy as it depends on grant funds from the USDA Specialty Crop Research Initiative.)
In a recent, personal communication, Dr. Critzer said:
“If your current program is being properly implemented and you have records to show this (water quality parameters, sanitizer concentration) and microbiological evidence through on-site analysis to show that produce exiting the water system has on average lower or similar populations of indicators or aerobic plate counts than on entry, you would have sufficient evidence and justification that your water management prerequisite program is properly operating to manage the hazard, thereby reducing its likelihood of occurrence. On the other hand, if your records show that you’re regularly not meeting your operational limits for various parameters or if the program isn’t being properly monitored, this will increase the likelihood of cross-contamination, and it should be elevated to a CCP.”
There is sufficient evidence in the research literature to guide decisions on the water quality parameters and sanitizer concentration necessary to manage hazards during hydrocooling and fruit washing to an acceptable level within the context of your prerequisite programs and thereby justify the decision that they are not CCPs as long as all other elements described by Dr. Critzer above are in place.
Many of those references can be found on this site under “Resources > Hydrocool & Wash Water.”
Please don’t hesitate to contact me if you have any questions on this topic.