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Dump Tank Wash CCP - Chlorine Monitoring


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#1 MarianaN

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Posted 11 May 2017 - 06:43 PM

Dear All,

 

I'm fairly new at this Food Safety, so I was hoping for some help. :smile:

 

We currently have our dump wash as a CCP

 

But I've had so much confusion with the chlorine monitoring. At the moment we monitor ph level, free chlorine and the ORP.

 

If someone could please explain to me the difference between total chlorine, free chlorine and available chlorine. I would really much appreciate it.

 

I have bought so many test strips.... :unsure:

 

 

 

 



#2 FurFarmandFork

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Posted 11 May 2017 - 07:15 PM

Who sold you the chlorine solution for your wash? I assume they provided validation data for what levels of chlorine would be effective for your process. Make sure you're using the same units as their validation data and you're good to go!

 

Use a unit that meets a standard, if it's FDA check what units they use, if it's your supplier use the units they use, etc. Only use pH if you've also got data to show it correlates with the amount of chlorine you want in the solution.


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#3 mambo

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Posted 11 May 2017 - 07:17 PM

Dear MarianaN,

I have previously worked in a fresh-cut produce processing facility. We were SQF Level 3 & Organic. WE had 2 CCPs viz: Dump tank and Metal detectors. Much as the dump tank is a CCP, it's the Oxidation Reduction Potential (ORP) which is the Critical Limit. The ranges were:  ORP: 700 - 850 meq, Free Chlorine: 0.4 - 08,  PH: 5.5 - 6.5 and Temp: 32 - 40 F. We used to measure water turbidity too. This would guide us in regulating the amount of fresh water to be dumped & added to the tanks. Our Chlorine mix was from Sodium hypochlorite and Citric Acid.

 

Total Chlorine refers to the sum of all Chlorine molecules in the tank. Some of the Chlorine may be bound to soil / foreign matter in the wash water hence unavailable. Free Chlorine refers to the amount of chlorine available to 'rupture/ destroy / kill' microbiological organisms associated with the produce. Free chlorine = available chlorine.

 

UC Davis, Post Harvest Technology centere has insightful publications about fresh-cut produce processing. I would highly recommend checking out their free publication.

 

I hope i have been of help. 



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#4 Charles.C

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Posted 12 May 2017 - 03:30 AM

Dear All,

 

I'm fairly new at this Food Safety, so I was hoping for some help. :smile:

 

We currently have our dump wash as a CCP

 

But I've had so much confusion with the chlorine monitoring. At the moment we monitor ph level, free chlorine and the ORP.

 

If someone could please explain to me the difference between total chlorine, free chlorine and available chlorine. I would really much appreciate it.

 

I have bought so many test strips.... :unsure:

 

Hi Mariana,

 

The supplier's info should tell you what the test strip is measuring. Hopefully free chlorine.( = free available chlorine) for the reason given in Post2.

 

Assuming you understand basic chemistry, the distinctions/measurement are simply explained here -

 

Attached File  chlorineresidual.pdf   226.29KB   32 downloads

(note there is a typo on Pg1, completing should > completely)

 

Personally i prefer DPD tablets / colorimeter.

 

If yr company is rich, you can install a cl2 (hypochlorite) injector with a continuous free chlorine read out/feedback control. > No need to worry. :smile:

 

PS - "Available Chlorine" can also have a specific quantitative meaning in respect to certain chemical compounds, eg bleaching powder.


Kind Regards,

 

Charles.C


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#5 tmfoley68

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Posted 09 July 2018 - 08:50 PM

MarianaN

 

I  don't know what you are processing but For fresh cut produce you are okay at anywhere from 50-200ppm on Chlorine (we use Calcium Hypochlorite) with a pH of 6.0-7.5, there is documentation to back that up all day long even from the FDA. the equilibrium between hypcholorous acid (HOCI or free chlorine) and the hypchlorite ion is pH dependent so checking chlorine alone does little good, you also have to monitor pH.

 

Temp, organic matter, light, air and heavy metals all effect HOCI concentration in process water.   If you can filter your process water to remove as much organic material as possible you help out HOCI. I have done NUMEROUS tests and confirmed HOCI with UHC monitoring with a photo chlorometer, can't use the PC when you run carrots or beets, anything that discolors the water though, and those items EAT up HOCI thankfully ALL of those items we run are further processed and not run for RTE as I have no choice but rely on test strips. Its astonishing how much filtering the process water helps. As far as temp once upon a time it was thought flume/process water should be 33-35 F NOW however we know it needs to be warmer than the commodity being processed because of temperature generated pressure differential. I run mine at 45 F everything we process has been kept in a 35F cooler. but in the FDA "Methods to Reduce/Eliminate Pathogens from Fresh Cut Produce" they suggest its okay to be even warmer.

 

I have got the best APC/TPC sampling results when pH is closer to 6.0 and HOCI is closer to 200ppm, but its difficult to keep it exact, I personally cease the RTE line if HOCI is below 100ppm our CCP is written as Chlorine 100-200ppm and pH 6.0-7.5.  For the line we run that everything is further processed by other processors I have no CCP but use the same ranges. 


Edited by tmfoley68, 09 July 2018 - 08:53 PM.


#6 Charles.C

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Posted 09 July 2018 - 11:46 PM

Hi tmfoley,

 

It's a 1-year old thread but thanks anyway.

TBH I would suggest the absence of zero-tolerant pathogens is more critical than APC count.

Interesting that you "got away" with no CCP where "further processing" ( hopefully involves a thermal step).


Kind Regards,

 

Charles.C


#7 tmfoley68

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Posted 10 July 2018 - 03:14 PM

Its not "getting away" with anything. Produce is tricky, every training class I have gone to they are like "produce distributor/processor, poor you"

 

Under the Food Safety Modernization act, if I do not control the ultimate hazard to the consumer, which I do not on any item further processed by another processor, there is no requirement I eliminate any possible hazard. The requirement is that I notify my customer on each BOL the product has received no kill step AND I get documented verification from my customer that THEY control the hazard to the consumer.

 

I had a 4 day FSMA Supply Chain Audit in March, that was quite enlightening, its when I learned I didn't have to have a CCPs on what was being further processed nor did I have to conduct product testing if it was being further processed. It is the final processor who is responsible for controlling the hazard in their finished product that goes the consumer.

 

Even under PREVIOUS FDA legislation before FSMA Lets say I had 5,000# of diced onions we processed RTE and product testing shows it exceeds the APC count set in our product testing limits I was allowed to divert it to a product being heat treated by myself or another processor and that renders the out of range APC test moot.



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#8 Charles.C

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Posted 10 July 2018 - 05:39 PM

Hi tmfoley,

 

Thks for response.

 

Actually iso22000 included an equivalent "passing on" option when launched in 2005. One wonders as to a potential hazard (eg Salmonella / E.coli O157) of cross-contamination "en route".

 

Out of curiosity, how did the next user control the hazard ?.


Kind Regards,

 

Charles.C


#9 tmfoley68

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Posted 10 July 2018 - 10:00 PM

Well I have several large further processors we supply, heat treatment to  an internal temp above 160 degrees F satisfies the FDA, E Coli, Salmonella and L. Monocytogenes are the most likely hazards in produce products and that should handle them all. However every heat treatment letter I have is for at LEAST 185F, the bakery I supply its 350F. I have one customer that freeze dries and before I ever started selling to them they had to validate their process as a Kill step with the FDA, it basically removes all moisture so bad bugs can't survive. That is the only customer verification I have that is NOT traditional heat treatment.



#10 Charles.C

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Posted 11 July 2018 - 02:10 AM

Well I have several large further processors we supply, heat treatment to  an internal temp above 160 degrees F satisfies the FDA, E Coli, Salmonella and L. Monocytogenes are the most likely hazards in produce products and that should handle them all. However every heat treatment letter I have is for at LEAST 185F, the bakery I supply its 350F. I have one customer that freeze dries and before I ever started selling to them they had to validate their process as a Kill step with the FDA, it basically removes all moisture so bad bugs can't survive. That is the only customer verification I have that is NOT traditional heat treatment.

 

Hi tmfoley,

 

Interesting, thanks.

 

IIRC the USFDA's cook expectations are usually based on achieving a reduction of ca. 6 log for Salmonella (or sometimes E.coli O157) while the UK focuses solely on L.mono. in curent context. An instantaneous core temp. of 185degF should certainly well exceed both Regulatory Bodies'  requirements for all 3 pathogens assuming applied to slowest heating piece/portion handled.

 

I deduce for the zero CCP-process, the scope of your HACCP plan is described as delivering (intermediate) RTC rather than RTE.

 

For not-to-be-heat treated product  i assume your hazard analysis joins the never-ending debate over what the applied hypochlorite is actually "controlling" at a washing stage CCP (ie the critical limit achieves "?"). IIRC FDA have always maintained a hazard "minimisation" logic for such RTE fresh produce and thereby avoided the 2-decade discussion. (I noticed FSMA appear to have reactivated a long-obsolete interpretation of a CCP so as to handle such scenarios).


Kind Regards,

 

Charles.C


#11 tmfoley68

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Posted 11 July 2018 - 02:21 PM

Actually we have to have FIVE separate hazard analysis/preventative control segments which are basically separate plans in the overall HACCP plan.

One for Foods processed in the non-RTE processing area where EVERYTHING produced is further processed,

One for items produced in the RTE area where there are multiple different process flows, ( some produce receives pre and post process wash and some only one or the other depending on commodity)

One for RTE Products manufactured by others we distribute, 

One for whole case produce we distribute, and

One for shell eggs.  She eggs are subject to inspection all on there own, and have separate regulations that govern them.

 

The scope of the HACCP plan for non-RTE is the product is not fit for human consumption without further processing and it is labeled as such,

You have to understand this is BULK product in insulated bins, cooperage barrels etc that hold up to 1000# of product. 

 

The largest pack size we do RTE is 5# very different process even on same commodity for say diced onions in bulk they are processed on a production line with multiple conveyors flumes water sanitation and PRPs are the CPs . Then they are dried across a conveyor screen and packed in bulk.

 

RTE Diced onions once peeled receive a pre process antimicrobial wash are diced directly into a dryer tub that goes into a dunk tank and receives a 3 minute post process antimicrobial wash while being agitated every 30 seconds before being spun dried and hand packed, Both washes on onions are CCPs. Now take diced cucumbers or diced tomatoes they cannot receive a post process wash, they would disintegrate, so they have a different type of pre-wash that is the CCP.  Trust me I WISH we did no RTE and manufactured only ONE product, my life would be much easier!



#12 Charles.C

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Posted 12 July 2018 - 11:59 PM

Actually we have to have FIVE separate hazard analysis/preventative control segments which are basically separate plans in the overall HACCP plan.

One for Foods processed in the non-RTE processing area where EVERYTHING produced is further processed,

One for items produced in the RTE area where there are multiple different process flows, ( some produce receives pre and post process wash and some only one or the other depending on commodity)

One for RTE Products manufactured by others we distribute, 

One for whole case produce we distribute, and

One for shell eggs.  She eggs are subject to inspection all on there own, and have separate regulations that govern them.

 

The scope of the HACCP plan for non-RTE is the product is not fit for human consumption without further processing and it is labeled as such,

You have to understand this is BULK product in insulated bins, cooperage barrels etc that hold up to 1000# of product. 

 

The largest pack size we do RTE is 5# very different process even on same commodity for say diced onions in bulk they are processed on a production line with multiple conveyors flumes water sanitation and PRPs are the CPs . Then they are dried across a conveyor screen and packed in bulk.

 

RTE Diced onions once peeled receive a pre process antimicrobial wash are diced directly into a dryer tub that goes into a dunk tank and receives a 3 minute post process antimicrobial wash while being agitated every 30 seconds before being spun dried and hand packed, Both washes on onions are CCPs. Now take diced cucumbers or diced tomatoes they cannot receive a post process wash, they would disintegrate, so they have a different type of pre-wash that is the CCP.  Trust me I WISH we did no RTE and manufactured only ONE product, my life would be much easier!

 

Hi tmfoley,

 

Thks for detail. I will forgo asking as to the individual differences :smile:.

 

I totally agree that this is a complicated/contentious area from a haccp POV.

 

It is particularly unlucky that -

 

(a) suppliers seem unable to consistently supply fresh produce which is pathogenic E.coli /Salmonella free/very low level.

(b) pathogenic E.coli and certain Salmonella species are so potent aggressors at low levels of concentration..


Kind Regards,

 

Charles.C


#13 Scampi

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Posted 13 July 2018 - 01:18 PM

You may want to look at the possibility of switching from Hypochlorite to PAA it is more stable, easier to maintain the levels, are some may argue, provides a better level of microbial death. It has the added benefits of 

 

 

1) not corrosive on metal

2) oxidizes into vinegar and water which leaves a much smaller environmental foot print

 

https://cvp.cce.corn...sion.php?id=298

 

https://ag.umass.edu...rs-chlorine-paa

 

https://www.fda.gov/...h/ucm091363.htm

 

https://www.hort.vt...._Sanitizers.pdf


Edited by Scampi, 13 July 2018 - 01:22 PM.





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