International Food Safety & Quality Network Newsletter Edition 261, September 26, 2016 Our Newsletter Sponsors     Last Fridays Webinar Root Ca

FOOD SAFETY NEWS LETTER

International Food Safety & Quality Network Newsletter

Edition 261, September 26, 2016

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Our Newsletter Sponsors

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Last Fridays Webinar

Root Cause Analysis, how science can help us with the investigations

Presentation slides and video recording from last Fridays webinar.
It is commonly known that root-cause analysis can be done with tools like the 5 Whys or Cause-and-Effect Analysis. The advantage of using these tools is that we can organize the information found in the investigation more efficiently. But just identifying potential causes is not a guarantee of effective problem solving, because improper selection of preventions for the causes may result in re-occurrence. The objective of this webinar is to review the application of scientific methods to effectively investigate and identify the causes of food safety problems as well as using science to properly select and manage control methods.

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george

George Howlett, CEO, Safefood 360°

Next Free Live Webinar

Risk Assessment under BRC

Taking place:
Friday, October 14, 2016 - 03:00 PM - 04:00 PM UK Time (10.00 AM Eastern US Start)

Presenter:
George Howlett, CEO, Safefood 360°

Webinar Overview:

Did you know that the BRC Food Standard refers to risk assessment nearly 100 times, but offers almost no advice on how these risk assessments should be carried out? This presentation offers an extensive analysis of risk assessment under BRC, and it provides you with a full breakdown of all areas where the BRC standard requires you to carry out a risk assessment. Up until now, there has been little guidance available on how to risk assess non-HACCP elements of your food safety management system; elements such as cleaning and auditing programs. To improve the situation, this presentation gives solid, easy-to-follow advice on how to carry out the risk assessment of these items in a systematic way.

Register for Free >>

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hello

New IFSQN Members

Hello
Hi everyone, I'm working in a beverage company and currently in-charge for the certification programs. Hope to share and learn from everyone. God bless

Introduction
Hi, I'm Aldo. I'm working on a commissary (bakery and pastry), which is a partner of an international coffee brand as their IMS Head (Integrated Management System). Currently were working on FSSC 22000 and hopefully we get certified before the year ends. I'm also pursuing my post graduate studies, taking up MS Food Safety Management.

Glad to join!
Glad to join! I am in Academia in a Food Technology Department. I work in cereal chemistry and technology. Looking forward to exchanging our views

New in BRC
Hello everybody. Recently, I started working as a Technical manager for a distributor company that is based in the Netherlands and is focused on the supply of flowers, herbs and vegetables from Africa to various retailers in Europe. As a recent graduate from my master in food quality management my experience in designing quality management systems is limited to 2 projects (one for ISO22000 and one for HACCP). Hence, I am not exactly a beginner but I have still a lot to learn and ask :P
Any tips or feedback is more than welcome.

Kind Regards
Pad

Introduce Yourself >>

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Topic of the Week

Roof Leak on Sealed and Packaged Raw Material

Thank God it's Friday. We recently had a major roof leak in our refrigerated warehouse onto several racks of packaged and vacuum sealed bulk cheese products. I placed all products on hold and performed sampling of all the products in order to ascertain any widespread contamination issues. My concern is the following:

• Management did not want/allow cleaning immediately after the leak stopped (product has been sitting in potentially contaminated packaging for more than a day at this point...)

• The leak was severe enough that the exterior corrugate packaging was soaked all the way through on multiple skids.

Based on history and case study, even though testing was performed, this cannot 100% exclude the risk of pathogen contamination on bulk product. There is talk of deboxing and repackaging suspect product into fresh packaging but my concern is that the plastic direct packaging could still be contaminated and our process involves bringing this directly into our RTE processing area where it comes into contact with direct product contact processing utensils and buckets. In addition, we have not performed a validation study on the use of approved chemicals on vacuum sealed material.

Am I crazy for pursuing that this product be disposed of or is this something that is verifiable as safe?

Thanks in advance for any comments!

Read More >>

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Latest Topics from the Forums

Questionnaire for supplier of drums for pineapple juice concentrate
Hi, Anyone able to assist please? I am looking for a questionnaire I can send to our empty drum suppliers to complete instead of me going to do a supplier audit. We produce pineapple juice concentrate which we fill aseptically into 210 Litre drums. I am wanting to send them a questionnaire they can complete which will satisfy BRC version 7 audit.

Regards,
Sharon

How to validate a final product sampling program?
Good morning everyone, could you please inform me how can I validate a sampling program in our final products.

We are producing dry mixtures from powdered raw materials. Our product categories are 1) dairy blends. (rm are milk powder, whey powders, milk proteins powder) 2) instant sauces-bechamels (rm are modified starches, stabilizers like xanthan sodium alginate etc. milk proteins and flavours) 3) additive blends (phosphates, nitrates etc.).

The acceptance of raw materials is being made only with Certif. of Analysis and from our procedure for the Suppliers acceptance (according to BRCv7). Twice a year we send to external lab 1 sample from each category for micro and chemical analysis.

In the ISO 22000 audit the auditor told us that the only NC is that the sampling program is not validated and insist to read the Regulation (EC) No 882/2004 (and implement a validated program...

Please help me if you have some previous experience

What are the CCP's and OPRP's in catering?
What are the oprp's & ccp’s according to ISO 22000 in catering industry??

Alternative to chain mail gloves for meat cutting?
Hi, I am working in a catering company as QHSE. We had a practice of using chain mill gloves while using meat cutting machine. Recently I came to know that it is not recommended to use. If anyone have idea related to it, please feel free to share the best alternative solution for replacement of chain mill gloves.

Regards,
Sawmya

What steps should every food plant have to keep their product safe?
When starting any new food manufacturing plant, what are the most needed/necessary steps to protecting your product from an and all contaminates? In other words, what should every plant have to insure they are making clean product?

Listeria monocytogenes in vacuum packaged cheese
Hello everyone. I'm currently QA/QC Director in the retail sector. Recently, local Public Health Department Deputies took samples of vacuum packaged cheese as part of their food inspection and surveillance programme. Those samples were sent to microbiological analysis at a local certified lab. I was surprised as I started reading... Suddenly I read Listeria monocytogenes - Positive Test in 1 out of 6 samples...

This is my first time dealing with this non-conformance and I almost immediately contacted the supplier and requested all traceability records for the lot's raw materials and finished product, HACCP and production log sheets, batch-records, microbiological testing of at least 3 subsequent lots at external independent lab (which I chose), cause-analysis and action plan.

The supplier's lot quality certificate declares no presence of the pathogen according to their sampling procedure and plan (was also submitted from external lab).

It would be great to listen to some comments and get some advice from you. I'm aware that prevalence of pathogens in food may be a bit confusing since they can be found in just a few units of the same batch i.e., we cannot say that the whole batch has been compromised.

No recall plan has been activated to date as we are expecting the microbiological verification tests.

Best regards!

When was your unannounced SQF audit?
Getting ready for our audit window and anxious to hear when others had their auditor show up on the doorstep.

Hand wash station garbage container-covered or uncovered?
During a recent inspection it was pointed out that hands could become recontaminated by disposing of hand towels through a lidded receptacle. I have replaced with an uncovered, wire framed, trash liner holders. These stations are located before entry into production areas. I was asked to check the FDA guidelines for a requirement stating they must be covered. I have found conflicting information.

SQF code only states "A means of containing used paper towels" is to be provided.

I feel that the open container at this location does not pose a risk to our product and reduces the potential for recontaminating washed hands.

Please give your thoughts.

Food Packaging Testing Limits for Mold
Hello, I work for a small food packaging company and we make a pad product that is used in direct contact with food materials inside of other packaging. We conduct annual microbiological testing on the product and wanted to seek advice and reference guidance on what is acceptable levels of detection for Mold specifically.

The testing that we have conducted is able to detect no lower than levels of <10 CFU/g. So the premise of my inquiry is at what level is Mold considered a hazard? Is there a regulatory standard or guideline available stating what level is or is not acceptable? What type of levels do others view as hazardous when taking Mold into consideration?

Appreciate any and all assistance!

Next best accreditation body to BRC or SQF?
Hi, I work for an importing dry feed ingredient brokerage, e.g. corn gluten meal, dry milk powder, soy protein, etc. I looked over the BRC requirements and some of them, my company wouldn't be able to fulfil. (Imagine how hard finding a GFSI feed ingredient supplier is at market value) We also wouldn't be able to conduct audits all over world due to costs. So my question is: What accreditation body should my company go for besides BRC or SQF? Maybe HACCP?

Stupid question of the day...... FSMA Expectations
Hello, I have gone to FDA website, googled and searched on IFSQN but cannot find what I am looking for, Is there a document available with FSMA expectations similar to the documents available for other standards? Maybe I am just confused or looking in the wrong places...all I find are "final rules" perhaps I am supposed to figure out what to do from these?

Any help would be appreciated.

Thank you!

Camellia oil formally considered food safe in the US?
Quick question, I handle the FSQA role for a very large catering company. One of our clients wants to incorporate camellia oil (tea seed oil) into dishes served at their event. The question has been raised as to whether this is considered food safe. I've long ago found that different levels of government (FDA vs state vs local health departments) have different opinions of the safety of different food additives, ingredients, etc., so I don't expect a definitive answer, but I was wondering if anyone has any experience with camellia oil in food?

I know it has many uses in the cosmetics industries and as a substitute for mineral oil in other countries. In the US the alternative health crowd suggests its use in cooking and frying. A search through the FDA's GRAS database doesn't come up with anything.

Any thoughts would be appreciated.

Bacteria limits (TPC/TVC) of poultry receiving crates once washed
Good day, I was hoping that someone would be able to give me guidance as to bacteria limits (TPC/TVC) of poultry receiving crates once washed. Can anyone provide me with what the TPC/TVC limits should be for such crates?
Tx

How to Validate Reverse Osmosis Filtration as a CCP for Packaged Water
Hi, I work in a manufacturing plant that produces bottled (packaged) water for retail sale. We've identified a few CCPs whilst conducting our risk assessments, and reverse osmosis (RO). Membrane filtration was identified as a CCP. What is the best way to validate or monitor this as a CCP? It's quite difficult to open up and inspect (unlike other filters) hence my dilemma here. I can't seem to find literature anywhere else give guidance on this.

Liquid Ingredient Transfer Ideas
Hello all, I am looking for some ideas on how other companies solve the issue of transferring liquid ingredients received in 4-5 gallon containers, to smaller, RTU portions. We have >10 different liquid ingredients (from flavors to juice concentrates) which arrive in 4-5 gallon containers. They are square, round, pails, twist lids, pull lids, tear lids...you name it. We transfer the liquids from their original containers too smaller, daily, single use portions (1/2 to 1 gallons) for multiple operators to use. Of course, we experience splashing and lots of grunts from man-handling the containers.

I would like to find some options to reduce the amount of man-handling and splashing by gathering information on how other companies handle these same types of ingredients. Options which have been discussed so far are slim: a.) purchase in larger quantities and use an electric pump; b.) find a small electric pump c.) find a cradle the container can rest in and tilt to pour.

All ideas along with their pros/cons are much appreciated!

TYIA!!!!

Sensitive Ingredients
Hello, we have identified certain ingredients (Chocolate, Cocoa, gums, sweetened condensed milk, tree nuts etc.) as sensitive ingredients and have it as one of our CCPs. The reason for categorizing them as sensitive is because all these ingredients will be used in our process as icing or decoration on the cakes which will not undergo any cooking to kill some of the microbes.

Now, when we receive ingredients that contain one or more of the ingredients that we have listed as sensitive, would that make this ingredient sensitive or not? In my opinion I think it depends, the reason is if those sensitive ingredients have undergone kill step to make this final ingredient then we need not consider it as sensitive.

Example, we have listed cocoa and sweetened condensed milk as sensitive because we do not cook these ingredients and are used in making RTE toppings. However, if we do receive Chocolate icing as one of our ingredients and it contains both ingredients such as cocoa and sweetened condensed milk, now would the chocolate icing become a sensitive ingredient or not? Please share your experiences and help me understand better.

Thank You.
RTP

Motivating to follow Approved Supplier Program
Hello All, Looking for suggestions to motivate a Senior Management team who says that they want to do the right thing when it comes to following the policies & procedures necessary to produce safe products. However, at the end of the day when it comes down to following through the commitment is not there.

One area is in the Supplier Approval Process. I have several scenarios where the President of the company refuses to buy from approved suppliers and uses the raw materials in our products without having received any or all of the required documentation. Although there are other members of the senior management team they refuse to hold him or anyone else in the organization accountable for their actions or lack thereof. I should also mention that we are a small company but have a huge profit margin so the bottom line is not being affected nor has anyone determined what our bottom line truly is.

Another area for motivation is in the development of product specifications - weight measurements of raw materials. As the FSQA Manager I have no idea if products are being made correctly because the President refuses to allow the creation of any specifications for products. There have even been times where production was stopped due to the fact he did not provide the day's recipe for our products.

You might be able to tell that I can go on and on with the things in my facility that are causing big headaches but I'll spare the rest of the details, unless you ask for them. I am looking for suggestions on how to motivate the senior management team so we can move the organization in the right direction for Food Safety & Quality. I also need to learn and gain experience as a young FSQA Manager but in my opinion I haven't gained the information I expected when I first took this job 18 months ago. I was hired under the premises that I would be preparing the facility to be compliant to a GFSI scheme but as you can see from above we are a long way away from that. What advice would you give on continuing to stay motivated myself during this challenging time?

Is food grade epoxy coatings in BRC Scope?
I have just received this question from company dedicated to food grade epoxy coatings production. Could it include on BRC/IOP scope or BRC consumer products? Actually, it is used by food industry to paint warehouses, tanks... but after reading both scopes, I'm not sure if we could use any of them.

Thank you in advance.

Microbiological Limits for Compressed Air Testing
Good Morning, Are there specific microbial limits for compressed air testing?

Thanks,
Jessica

What is meant by external origin of a document?
What it means by the external origin of document? Is the standard we refer??

Effect of sterilization on color of dried chilli powder?
Hey!!! I want to understand the effect of steam sterilization on color or LAB value of red chilli powder. Please help me out in understanding the same.

Microbiological acceptable levels for fresh juice
Hello, I am making cold pressed, fresh juices. No additives to extend the shelf life. All juices except one have a low pH below 4.2 and have been tested by a lab. Though I do not know safe levels of the bacteria, yeast etc. tested by the lab. Only that they were safe.

I have another customer that just wants beetroot juice. They have asked for a product specification which I am struggling with. I have not had this juice tested at the lab and the pH is higher than 4.2.

Is anyone able to help with safe levels of microbiological content? They have asked for this. So if they were to test the juice, what levels would be safe. I have asked the lab for this info but I need to the spec to the company asap and am running out of time.

Is anyone free to give feedback on how to improve the product spec. I have researched lots but most of the content of other threads and online things have gone over my head and I ended up deleting bits I did not understand and probably need to add it back in.

I am in the UK.

Thank you

Check-weigher settings
Hi, I need to understand in depth setting up tolerances, lower and upper limits on checkweighers and how it applies to average, minimum and custom settings. I have mixed messages from different people within the business. Any expertise will be appreciated. Thanks

Two Sets of Label for One Product, is it allowed?
Hi All! I'm just wondering if our company can use a two sets of label for a single product? First is the one with allergen declaration and the other one does not?

Glass/Plastic Audits
Hello, I am new to this forum and am just wanting a little advice. We are a small frozen food packer in the UK that is working towards gaining BRC accreditation. I am wondering how in depth the glass/plastic audits need to be. I think we are going over board by auditing everything within the open product area on a daily basis. This includes air gauges on the side of machines, calculators etc. I think instead we should only be checking items that are a direct risk i.e. anything directly above the line. Everything else should be on a monthly basis. Please correct me if I am wrong.

Anyway my main question is this - do we need to go so far as checking items in my office which is out of the open product area and then a couple of metres down a corridor. In this area PPE is not worn however it is obviously required in the packing hall which should prevent personal clothing from contaminating the product.

Many thanks in advance.

SQF 11.3.2.3 - Hands free sink
What are everyone’s thoughts on wrist blades for sinks. Would these fulfil the hands free section for SQF 11.3.2.3? And as always, Thanks for your input!

Effectiveness of Defect Eliminators
I feel like I'm going crazy in a new work environment, and it's really making me feel defeated in my position for the first time in my career. I've been dealing with this for over two months now, and I'm at my wit's end. Perhaps I'm being the so-called crazed "quality nazi" (not a bad thing, eh?) and need to be reined in. So, I've decided to turn to you guys for help.

We're a grinding process. That's all we do. Receive in trim. Grind. Ship. We've been struggling with Foreign material opportunities for a while now. Soft plastic from raw material, soft plastic from rework, hard plastic from who knows where, hard plastic from PPE, but not much metal (of course, because we have detection systems in place for metal, so why would the stars align for me on that?).

Here's the thing - We do have a defect eliminator (Weiler) that pulls out most dense foreign bodies. With my history with this brand, I do not feel confident these pieces of equipment remove 100% of denser foreign objects, depending on size, and I also do not feel confident in its ability to remove all soft plastic contamination. That is not to say I don't think they are very effective, I absolutely do, I just don't put 100% of my faith in them. I prefer to look at product coming out of the defect eliminator as an indicator of potential contamination.

Having said that, I've been really confused lately. Any time plastic is observed in the defect eliminator, there is literally a shrug of the shoulders from operations and "The equipment is doing what it's supposed to." There is no breaking down of the equipment, no observing product from the blender, the finishing grinders, or on belts, no real investigation expected to determine the source.

When I am miraculously notified that plastic is exiting the defect eliminator, I ask them to stop the process until we can complete an investigation into the source, determine the potential for finished product or WIP contamination, and inspect equipment prior to the step where the foreign object was identified. I kind of feel like this is normal stuff.

Everyone here disagrees. Not only do they disagree, they just keep running! I'm throwing away more product from "We just didn't think we'd find anymore and kept running" than I am from what I actually think is the most affected product, and absolutely more than we would have if we would have STOPPED, come together, and come to an agreement as a team. I'm working on a foreign material procedure, updated from the one my predecessor created, and, I'll be honest, I'm being kind of a hard you-know-what in it, because I know they are going to argue with how strict it is and this will give me a little wiggle room, kind of like when buying a car. I'm over-selling to win negotiations.

For those with experience with defect eliminators/bone eliminators/beehive grinders, am I going overboard?

Glass Standard for plants in USA
Just confirming that the British Glass Standard is the reference standard for Glass and Brittle Plastics for operations in the US.

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About the IFSQN

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The forums are a place where members can network, share knowledge and ideas to make food safer around the world - why not join us today!

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