3 replies to this topic

[scoot915]

This may be a little long winded, but I am having some difficulty with the physical & microbiological part of product specifications, sort of thinking out loud as I write.

 

We are a small manufacturer of frozen bread dough, frozen par-baked breads and fresh breads. Our frozen products are shipped to wholesale customers who distribute to their retail level stores, our fresh products are shipped to retail customers.

Our products are not considered RTE.

 

Our finished product specs are complete except for physical and microbiological standards, which we never established.

Our customers do not set specifications for products, so we have never had to document meeting customer specs and no one has ever asked about them.

 

We just passed out first HACCP and GMP certification. I was dinged 5 points for not having all the specifications for raw materials, ingredients and packing material (due to time restraints, I did not have time to get them all but am working on that)

Nothing was mentioned about physical or microbiological standards missing on finished product specs.

 

We have HACCP plan, GMP’s, Pre-requisite programs, use approved suppliers, COA (for bulk flour only at this time) perform ATP and allergen specific swab tests, etc. which in combination should eliminate contamination's but I believe the product specs should still have the standards. If we go for higher certification it will be necessary and it is only a matter of time before our larger customers request more QA documentation so I want to have my ducks in row.

 

My questions (finally)……

 

To establish the physical standards I would send samples to a lab for analysis. The results will go onto the finished product specs.  Correct or is there another way?

 

To establish micro standards do I also send samples to a lab or just use industry standard limits?

 

Would we need to test finished product to prove they meet the physical and/or micro standards and if so how often?

It would not be feasible for us to hold product for several days to a week waiting for test results. Unless there is some type of rapid test we could do in house without a lab, or the testing would only be necessary yearly, I do not know how we would accomplish the testing.

 

Again.. I hope this makes sense and thanks in advance for any help.

[Charles.C]

Hi scoot,

 

Yr post makes excellent sense and IMEX is a typical situation when faced with obtaining certification for Standards such as those recognized by GFSI. The scope of the post is quite wide though so i have had to generalise here and there.

 

Our products are not considered RTE.

 

I’m guessing you meant the frozen dough ?

 

Not quite sure how one "Approves"  Suppliers in the absence of specifications.

 

I assume yr current HACCP/GMP certification is not for a GFSI recognized Standard.

 

Theoretically "Specification" includes both Safety and non-Safety features. In a haccp context  only Safety-related parameters would be relevant.

 

A general comment for many "refined"  ingredients/ inputs is that they should have a specification which conforms to "Food Grade" status.

 

 

To establish the physical standards I would send samples to a lab for analysis. The results will go onto the finished product specs.  Correct or is there another way?

To establish micro standards do I also send samples to a lab or just use industry standard limits?

 

 

IMEX, for sellers of finished products, 2 options are possible regarding specifications (in general) –

 

(1a) the BPC specs are defined by the buyer and required to be mutually agreed/signed for by the seller. This is the norm IMEX. It involves the seller having their finished product lab. tested so as to confirm the product  will meet the to-be-agreed buyer specs. If otherwise further discussion / change of product  will likely follow.

(1b) If the seller of finished goods is obliged to create the spec. for agreement with the buyer, the procedure would be similar but initially require seller to determine from appropriate sources the typical required BPC parameters / limits for the  finished product so as to be able to send samples to a testing lab and instruct what analyses required. The subsequent lab results will then determine if the spec. is suitable for the  product or not. If not, the action will depend on which parameter (s) have unsatisfactory results and by how much.

 

IMEX for Purchasers of raw materials, inputs, etc, the options are similar to above, eg -

 

(2a) the specs are defined by the seller and mutually agreed/signed for by the buyer.  This  involves the buyer having a sample of raw material lab. tested so as to confirm the product  will meet the to-be-agreed specs. If otherwise further discussion / change of product  will likely follow

(2b) If the buyer of raw material is obliged to create the spec. for agreement with the seller, the procedure would be similar but initially require buyer to determine from appropriate sources the typical required BPC parameters / limits for the raw material so as to be able to send samples to a testing lab and instruct what analyses required. The subsequent lab results will then determine if the spec. is suitable for the  product or not. If not, the action will depend on which parameter (s) have unsatisfactory results and by how much.

 

Would we need to test finished product to prove they meet the physical and/or micro standards and if so how often?

The quantity/frequency will likely depend on the product quantity/results/compliance and how much data variation occurs. And cost ofcourse.

From a HACCP POV this activity is related to Validation and/or Verification (depending on the particular interpretation of the respective terms)

 

It would not be feasible for us to hold product for several days to a week waiting for test results.

This may be a problem for certain micro. results.

 

PS - I forgot to mention that some requirements may obviously depend on yr current process set-up, eg metal detection.

 

PPS - slightly OT, for inputs, from a FS Standard POV, the amount of routine testing involved may depend on a Risk Assessment of the Supplier /Ingredient. This is linked to the criteria for designating an Approved Supplier and the subsequent handling of the Supplier's inputs.

[scoot915]

Thanks Charles you cleared up a lot for me.

[Anish]

Dear Scoot,

 

There is GCC specificaiton for Frozen Dough - GSO 1370/2013 and when I referred the reference of the GSO - I foudn the reference as Egyptian Standard -2471/2005. Pls find the specifications mentioned in the GSO standard as below:

Micro parameter: Salmonella - Nil, Staph.aureus_100

Physical: Moisture - NMT 50%, Acid Insoluble Ash- NMT0.15%, Fat -NLT8%, Protein-NLT12.5%, Insect Fragment-Nil

Chemical: Heavy metals - Cd-NMT0.1ppm, Hg-NMT0.03, Pb-NMT0.2ppm, As-NMT 1.0ppm, Radioactivity-NMT75bq/kg

Flavours - as per GSO707, Coloring matter- As per Codex 192, Preservative- As per GSO 356 and Antioxidant - As per GSO 357.

 

Most of the contaminant limits of GSO are derived from Codex standards.

Hope this helps.

Rgds,

Anish