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FSMA Preventive Controls

FSMA Preventive Controls

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#1 jportz

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Posted 22 June 2017 - 06:39 PM

We add spices to our brined vegetables and relish's and our product is pasteurized before the addition of spices.  Salmonella and mytoxins are known hazards in spices.  If we use a Supply Chain preventive control and obtain a COA with a Salmonella testing and mytoxin statement from our supplier would this be a sufficient preventive control?  We do obtain their 3rd party audit and Letter of Guaranty but, we don't have resources to conduct audits on our suppliers. 

 

Also we receive raw vegetables from growers and obtain letter of guarantee's, C of A, and spray records and sprayers license that they are certified to spray.  Is this a sufficient supply chain preventive control or do we need to do more.  I attended training and I'm still having trouble understanding the new requirements for preventive controls. 


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#2 Peter C.

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Posted 29 June 2017 - 12:36 AM

The FSMA preventive control rule states “The hazard analysis must consider hazards that may be present in the food because they occur naturally, are unintentionally introduced, or are intentionally introduced for purposes of economic gain."

 

So based on what you listed above I would think you need to also include a hazard analysis for hazards introduced for purposes of economic gain.


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#3 Charles.C

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Posted 29 June 2017 - 02:01 AM

The FSMA preventive control rule states “The hazard analysis must consider hazards that may be present in the food because they occur naturally, are unintentionally introduced, or are intentionally introduced for purposes of economic gain."

 

So based on what you listed above I would think you need to also include a hazard analysis for hazards introduced for purposes of economic gain.

 

Hi Peter.C

 

Slightly, but maybe importantly,  truncated ?
 

 

Hazard analysis: The first step is hazard identification, which must consider known or reasonably foreseeable biological, chemical, and physical hazards. These hazards could be present because they occur naturally, are unintentionally introduced, or are intentionally introduced for economic gain (if they affect the safety of the food).

 

https://www.fda.gov/...a/ucm334115.htm


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Charles.C


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#4 pablo coronel

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Posted 29 June 2017 - 01:14 PM

If you get supplier's CoA with every batch it should suffice.  

 

However, you need to ask yourself, is this sufficient guarantee?

If you believe it is, then are confident enough to feed this to your child?

If both are yes, then you have  agood SC-PC

 

 

We add spices to our brined vegetables and relish's and our product is pasteurized before the addition of spices.  Salmonella and mytoxins are known hazards in spices.  If we use a Supply Chain preventive control and obtain a COA with a Salmonella testing and mytoxin statement from our supplier would this be a sufficient preventive control?  We do obtain their 3rd party audit and Letter of Guaranty but, we don't have resources to conduct audits on our suppliers. 

 

Also we receive raw vegetables from growers and obtain letter of guarantee's, C of A, and spray records and sprayers license that they are certified to spray.  Is this a sufficient supply chain preventive control or do we need to do more.  I attended training and I'm still having trouble understanding the new requirements for preventive controls. 


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#5 Charles.C

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Posted 30 June 2017 - 02:44 AM

We add spices to our brined vegetables and relish's and our product is pasteurized before the addition of spices.  Salmonella and mytoxins are known hazards in spices.  If we use a Supply Chain preventive control and obtain a COA with a Salmonella testing and mytoxin statement from our supplier would this be a sufficient preventive control?  We do obtain their 3rd party audit and Letter of Guaranty but, we don't have resources to conduct audits on our suppliers. 

 

Also we receive raw vegetables from growers and obtain letter of guarantee's, C of A, and spray records and sprayers license that they are certified to spray.  Is this a sufficient supply chain preventive control or do we need to do more.  I attended training and I'm still having trouble understanding the new requirements for preventive controls. 

 

i would have thought that there needs to be some reference as to whether compliance to any (relevant) maximum chemical spray residue is achieved  ?


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Kind Regards,

 

Charles.C


#6 GMO

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Posted 30 June 2017 - 06:10 AM

We add spices to our brined vegetables and relish's and our product is pasteurized before the addition of spices.  Salmonella and mytoxins are known hazards in spices.  If we use a Supply Chain preventive control and obtain a COA with a Salmonella testing and mytoxin statement from our supplier would this be a sufficient preventive control?  We do obtain their 3rd party audit and Letter of Guaranty but, we don't have resources to conduct audits on our suppliers. 

 

Also we receive raw vegetables from growers and obtain letter of guarantee's, C of A, and spray records and sprayers license that they are certified to spray.  Is this a sufficient supply chain preventive control or do we need to do more.  I attended training and I'm still having trouble understanding the new requirements for preventive controls. 

 

I don't agree that a CoA is good enough as people have put on here.  What I'd be looking for is that the spices are heat treated before you use them.  If they're not, I would look at two options; buying heat treated spices (they are available) or adding your spices before pasteurisation if that's possible.  One of the key concepts of HACCP (long before FSMA got involved with HARPC) is that you can't normally microbiologically test something safe; you design a process that delivers safe food, validate it, then your testing is verification.  So your question should be "what process is there in place to ensure Salmonella and mycotoxin producing moulds are not present in these spices?" 

I would also look at the brine, would the pH and salinity be sufficient to not support growth anyway?  (Personally I would not rely on this as in many markets even presence of pathogens is enough to recall so I would still try to reduce the spice risk if I could.)


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#7 RMAV

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Posted 30 June 2017 - 03:45 PM

If you have identified a supply chain preventive control, you need more than a COA.  You need to verify your supplier's control is adequate *and* verify your supplier is actually doing it.  According to my training, this can be accomplished by auditing your supplier yourself, or by verifying their *qualified* 3rd party auditor verified the supplier's preventive control is in place, in practice, and effective.


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#8 jportz

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Posted 17 July 2017 - 03:42 PM

I have done a lot of research on spices and we do get a C of A with each load stating the salmonella testing is conducted by the supplier and the results.  We get the following spices:

 

Untreated:

Granulated Garlic

Dehydrated Garlic

Minced Garlic

Garlic Powder

Granulated Onion

Minced Onion

Parsley Flakes

Whole Mustard Seed

 

Heat Treated:

Whole Oregano

 

Irradiated

Whole Celery Seed

 

The only testing for mycotoxins is conducted on the Whole Mustard Seed biannually by the supplier but is not listed on the COA.

 

I have asked the supplier if they plan on testing for mycotoxins on spices due to the new preventative controls but haven't received an answer.  We put the spices in after the fermentation process and pasteurization step has been conducted.  I don't know how to control the hazard for mycotoxins without our supplier controlling them.  Testing each lot before use at our facility is not feasible to us.  What else can I do?

 

As for the Salmonella testing it is now listed on the COA at receipt for all ingredients we receive and we have a copy of the third party audit on file but, not the entire audit.  Will this be sufficient enough for a preventive control?


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#9 Peter C.

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Posted 19 July 2017 - 12:53 PM

Hi Jportz, 

 

I go back to what FSMA states what is required for their hazard analysis listed below. 

 

Hazard analysis: The first step is hazard identification, which must consider known or reasonably foreseeable biological, chemical, and physical hazards. These hazards could be present because they occur naturally, are unintentionally introduced, or are intentionally introduced for economic gain (if they affect the safety of the food).

 

"We continue to believe that hazards that may be intentionally introduced for economic gain will need preventive controls in rare circumstances, usually in cases where there has been a pattern of economically motivated adulteration in the past."

 

Hazard analysis: The first step is hazard identification, which must consider known or reasonably foreseeable biological, chemical, and physical hazards. These hazards could be present because they occur naturally, are unintentionally introduced, or are intentionally introduced for economic gain (if they affect the safety of the food).


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