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Environment & Pathogen Control in a small grain facility

environment & pathogen positive release food defense program

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#1 Left the Building...

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Posted 27 September 2013 - 04:03 PM

I am new to the world of having to write policies and procedures. In our small grain facility, I have received numerous questionnaires from customers regarding Environmental & Pathogen Programs, Positive Release Programs, and Food Defense Programs. I have a few questions and hope to find answers here :)

 

#1  Seeing as we are not considered "food grade for human consumption", would a generic, broad basic plan for Environment & Pathogen Program work? (traffic control, dust control, separation of raw & finished product, and effective cleaning & sanitation)

 

#2 Positive release program....all outgoing loads are sampled, loads sealed w/a clean trailer form accompanying it, samples retained for 24 months, then all info entered on an accountability form...would these procedures constitute a positive release program?

 

and #3 Can someone explain how a food defense program differs from a GMP program and other policies and procedures?

 

There is so much information out there, I'm having difficulty sifting through it all. I'm sure I'm not alone on that....but for a "Newbie"....wowsa

 

So, in advance...thank you very much!!

krl54409


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#2 Charles.C

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Posted 28 September 2013 - 12:20 AM

Dear krl,

 

I'm having some difficulty understanding the context of yr post.

 

You mention yr product not related to human food safety. Do you mean the intended user / usage will have no  ultimate impact to the human food chain ?  So what is it actually for ?  Petfood  ? (added later - apparently Yes, see the PS below)

 

i also noticed you made no mention of haccp in yr post. Assuming yr query does primarily  relate to FS for human / animals, this would have probably been in the first line of most posts of this type. Including non-humans.

 

Meaningful answers to  posts often requires some knowledge of the context.  :smile:

 

Rgds / Charles.C

 

PS (added later) - just noticed you have posted 2 other interlinked threads (see below), one of which appears abandoned. Seems to me you are urgently in need of a professional consultant as recommended in second link below.

 

I don't yet see any info. on the standard (if any) for which you intend to be certified to ? It relates.

 

http://www.ifsqn.com...ike/#entry63454

 

http://www.ifsqn.com...ill/#entry63379

 

I daresay you know this already but some FS systems for petfood are equally as rigorous as for humans, eg FEDIAF. After all, i presume petfood is supposed to be (dog) food grade, Yes ?

 

Quick answers to yr above questions - 

(1) basically this is a query on whether Risk Assessment is required. It probably will be.

 

(2) "positive release typically means data to show that no existing  "red flags" resulted from the implemented FS / haccp plan within the process chain leading to finished product. So, as you have written above, probably No.

 

(3) GMP activities are typically regarded as prerequisite functions related to manufacturing. Food defense is  another prerequisite program related to, for example, protection from potential acts of " sabotage, vandalism, terrorism" (at least in the  PAS220 viewpoint anyway).


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Kind Regards,

 

Charles.C


#3 Left the Building...

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Posted 30 September 2013 - 09:56 PM

Perhaps I was getting a little ahead of myself earlier. We deal strictly with pet food, dog and bird, sorry for that omission. 

 

You had mentioned about my earlier posts, or threads being abandon, I don't know how to mark them as NOT..again I apologize.

Since those posts, I have written and we have begun to implement several policies, including HACCP, GMP, a non conforming program, and a food allergen program among a few more. 

 

We did have an audit earlier this month, which we passed with flying colors. As earlier stated, I still had a few questions. And to be honest, I'm still a little cloudy as to why the policies we have in place already would not suffice for a positive release program.  If any "red flags" had come up during the production process, the product wouldn't even make it to the shipment stage, therefore I don't see why the policies we have wouldn't work. Or is this going to come down to an issue of  potaTO vs poTATo? 

 

Although it seems I don't know what the h*#% I'm talking about (please don't misunderstand me...I don't have a clue lol) but all of my questions I had have all been answered, other than my hazy understanding of the positive release. 

 

Thank you again!! 

:smile: krl


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#4 Charles.C

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Posted 01 October 2013 - 10:00 AM

Dear krl,

 

I am happy you passed the audit.  :thumbup:

 

May I ask what standard the audit was for ?

 

Regarding positive release -  As i understood from yr original post, your only "evaluative" interaction is carrying out sampling and retaining the  samples. I have no idea what an "accountability" form is ?  This activity(s) implies (to me) that yr FS/haccp system apparently has no requirements for monitoring / measuring to generate data. If this is in fact so, "positive release" probably has no real meaning as applied to yr process. But perhaps I have misunderstood what you are actually doing, eg what yr haccp plan (??) requires.?

 

Suggest you have a look at the link below (and the sub-links inside) and see how yr current procedure fits in. :smile: 

Of course, yr own particular standard may have a different interpretation / requirement.

 

http://www.ifsqn.com...uct/#entry61611

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C


#5 Tony-C

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Posted 04 October 2013 - 06:26 AM

I think Charles has covered most of your questions.

 

Broad basic plan for Environment & Pathogen sampling - this will depend on specification you are working to, customer requirements and the various risks in each area (filling vs. storage for example)

 

Positive Release - normally you set criteria for positive release rather than state sample taken e.g. Salmonella absent in 25g

 

Regards,

 

Tony


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