16 replies to this topic

[Evelynn]

Hi,

 

So I was looking back at our Dec. 2017 SQF audit. At the time I had only been an SQFP for 4 months, and was working with an audit plan from our CB that had been completed prior to my employment at this facility.

 

We had a pretty harsh audit, and I was trying to figure out why our NC's had jumped from 3-4 per audit, to 12 in 2017. 

I had a look at the audit plan, and noticed that our facility was listed as HIGH risk, and wondered if that could have been a small factor in this spike of NC's.

(I tackled the issues with several of the others, which were legitimate but I do feel that some were a little much. Regardless, we dealt with them).

 

We produce mushrooms here. We do not mix our own compost (we get it from an approved supplier), and we do not slice mushrooms at this facility.

I know of no other mushroom producer in our region who is listed as a high risk facility, so I believe that the SQFP before me had mis-categorized us as high risk. 

We do fall under category 3, 4 & 14 but we aren't RTE, so I don't see how we could have been categorized as high risk.

 

Can I simply contact our CB to have this changed? Or do I need to provide any sort of documentation for this?

 

P.s: Can the auditor add a module to your FSC after the plan has already been confirmed? I read an email from our CB that specified that "The scope of the certification will be defined by the certification body and the supplier prior to the start of the certification audit. Once the certification audit has begun, the scope of the certification shall not be altered.".... Yet we got an NC for not having a module covered, and it was never in the plan, so I had nothing prepared for it.

 

I apologize for the novel, I'm still a semi-newbie. I've been in the food industry for 7 months. At the time of the audit I was nowhere near confident enough to challenge anything, although I did bring up the fact that the module wasn't listed in the scope of our audit.

[Scampi]

I'm guessing you object to 14.....i don't see how that applies either. I think you are RTE, mushrooms can and are consumed without cooking

Can you clarify on the word "module"?  you should have had module 2 and 11 covered regardless....is this what you mean?

[Evelynn]

I'm guessing you object to 14.....i don't see how that applies either. I think you are RTE, mushrooms can and are consumed without cooking

Can you clarify on the word "module"?  you should have had module 2 and 11 covered regardless....is this what you mean?

 

-Actually, I didn't even think to object to 14, because we used to slice, but no longer do, and I hadn't thought about removing 14 because I don't know if weighing and packing counts as processing (Still new, bear with me).

 

-I had thought that we were RTE, but the owner said we weren't, and the auditor agreed with him. Also, I had a chance to sit in on another mushroom company's audit, and their auditor also said they weren't RTE, so I just assumed we weren't. Maybe because you definitely have to wash mushrooms before you eat them, and they're usually prepared further, either by cutting or cooking or both? I don't know.

 

-The SQF food sector categories listed on our Audit plan included: 3, 25, 4 & 14. I argued 25 because we repackage, label and weigh incoming mushrooms from our suppliers. The modules we include are 2, 7 & 11 (according to old 7.2 code modules), which I did have covered... Our auditor said we needed to also cover module 12 (now known as Food Safety Code for Storage & Distribution), because we receive mushrooms, and then inspect, weigh, repackage and ship them. But that's not the same as having product shipped to a warehouse and just shipping it out. I had included that process as receiving raw materials from a supplier and processing them along with our own mushrooms. 

 

Does this make sense? And thank you for your speedy response!

[Scampi]

I would argue the same. those suppliers are just that, suppliers and you are warehousing your ingredients for processing, no different than any other ingredient for a process. UNLESS you are putting your suppliers name on them then you might be in a grey area. Repacking is considered a processing step..............argue this one with you CB

 

You can email your certifying body as well and ask them for guidance. They should be able to get you a definitive answer quickly one way or the other.

 

Are they packed in the plastic container with stretch wrap on top?   

As fresh mushrooms are produce like lettuce or grapes, i still thinks its odd that no one considers them RTE, sigh, that's my something new for today

[Evelynn]

I would argue the same. those suppliers are just that, suppliers and you are warehousing your ingredients for processing, no different than any other ingredient for a process. UNLESS you are putting your suppliers name on them then you might be in a grey area. Repacking is considered a processing step..............argue this one with you CB

 

You can email your certifying body as well and ask them for guidance. They should be able to get you a definitive answer quickly one way or the other.

 

Are they packed in the plastic container with stretch wrap on top?   

As fresh mushrooms are produce like lettuce or grapes, i still thinks its odd that no one considers them RTE, sigh, that's my something new for today

 

Yeah, we're just putting our customer's labels on, with our standard info on there as well. I knew that was the wrong call on the auditor's part.

 

I will definitely be emailing my CB to discuss. Thank you!

 

And yes, we package with the plastic-stretch wrap on top as well as bulk 5lb cardboard boxes. I agree it's odd, but maybe it has something to do with the fact that mushrooms always have a bit of dirt left on them when they get to the final consumer. Grapes and lettuce wouldn't have as much dirt as mushrooms, as they can't be pre-washed before shipping. I don't know... I'm not planning to argue that one lol.

[jcieslowski]

If you package mushrooms with the plastic-stretch wrap, that seems to imply to me that they are ready to eat.  Mushrooms.ca, a Canadian mushroom group says:

 

Q: Is that true you should not eat raw mushrooms?

A: All fresh Canadian mushrooms, that you have purchased at your grocery store or local market are safe to eat raw or cooked

 

Are you not selling to stores?  

 

I'm also confused by your argument to food sector category 25.  Those under food sector category 25 fall under module 11.  You'll be subject to module 11 anyway. 

[Evelynn]

If you package mushrooms with the plastic-stretch wrap, that seems to imply to me that they are ready to eat.  Mushrooms.ca, a Canadian mushroom group says:

 

Q: Is that true you should not eat raw mushrooms?

A: All fresh Canadian mushrooms, that you have purchased at your grocery store or local market are safe to eat raw or cooked

 

Are you not selling to stores?  

 

I'm also confused by your argument to food sector category 25.  Those under food sector category 25 fall under module 11.  You'll be subject to module 11 anyway. 

 

I agree with you and have reviewed the info on CMGA's site about mushrooms being RTE, but I have never come across a mushroom farm that is audited as an RTE facility. I've only been here for 7 months though, so there's a whole lot I haven't come across :) 

 

We do sell to stores. I know we do already fall under module 11, but I don't understand why we would be category 25 if we're not a distribution warehouse, etc. I wasn't as worried about that category 25 thing as much as I was worried about the module 12 N/C, because, as you mentioned, we were already module 11 compliant. 

 

I wish I had been confident enough to ask more questions during that first audit.  

[Evelynn]

So, I'm looking at Health Canada's Policy on L. Monocytogenes in ready-to-eat foods, and in the footnotes it covers a few food types that are and aren't included in the policy. When I read that, it seems that unwashed, unsliced mushrooms would be considered Non RTE.

 

See below:

 

RTE fresh-cut fruits and vegetables are subject to the provisions of this policy, i.e., raw fresh fruit and vegetables that have been either washed and peeled, either sliced, chopped or shredded prior to being packaged for sale and are intended to be consumed raw and not for further processing or cooking. Examples include: shredded bagged lettuce, coleslaw, fresh-cut melons or fruit salad.

Return to footnote5Referrer

Footnote 6

Non RTE fresh-cut fruits and vegetables are not subject to the provisions of this policy, i.e., raw fresh fruit and vegetables that have been either washed, peeled, sliced, chopped or shredded prior to being packaged for sale with cooking instructions on the package (e.g., mixed fresh-cut vegetables intended as pizza dressing or intended for use in preparing soup), as well as raw whole fresh fruits and vegetables, i.e., whole fresh fruit and vegetables that have only been trimmed, cleaned, brushed, washed, graded, packaged or otherwise prepared for human consumption (e.g., fresh herbs, whole or trimmed fruit or vegetables, whole leaf vegetables and berries).

[FurFarmandFork]

So, I'm looking at Health Canada's Policy on L. Monocytogenes in ready-to-eat foods, and in the footnotes it covers a few food types that are and aren't included in the policy. When I read that, it seems that unwashed, unsliced mushrooms would be considered Non RTE.

 

Evelynn, you only listed the clarification of what was RTE for the purposes of the listeria control policies. The guidance you linked specifically states:

 

"Ready-to-eat ( RTE) foods are foods not requiring any further preparation before consumption, except perhaps washing/rinsing, thawing or warming. 

However, only the following kinds of RTE foods are subject to the provisions of the Listeria policy: foods which have been subjected to some form of processing in order to render them RTE (most often cooking) and/or which have been subjected to another process to extend their shelf-life, including but not restricted to the use of heat, chemicals, reduction of pH, reduction of water activity, or special packaging. Fresh produce processed and sold as RTE are also included 

Footnote

5. These foods may be shelf stable or may require refrigeration or freezing in order to assure their preservation until the time of consumption."

 

 

 

Canada clearly considers raw mushrooms RTE, but exempts them from the Listeria policy, and even states (above in bold) that those foods you quoted are considered RTE.

[Evelynn]

Evelynn, you only listed the clarification of what was RTE for the purposes of the listeria control policies. The guidance you linked specifically states:

 

 

 

Canada clearly considers raw mushrooms RTE, but exempts them from the Listeria policy, and even states (above in bold) that those foods you quoted are considered RTE.

 

That makes sense. 

To be clear, I assumed that mushrooms were a ready -to-eat food, but I was trying to figure out *why* so many auditors are not considering mushrooms farms a ready-to-eat facility. 

I don't know why we haven't been considered RTE, and I'm a bit worried about emailing my CB over it, and making it harder for everyone else. 

[Scampi]

I think this issue should be raised with the CB.............OR your CFIA inspection office............something very odd is going on here that just doesn't make sense. Don't worry about everyone else, the goal is to produce wholesome safe food for all!!!!

[Evelynn]

That's true. I don't understand what's happening, but I'm sure when I speak to my CB they'll clear it up with me. 

[Scampi]

do you belong to this? Groups can help fight a battle

 

https://www.mushrooms.ca/food-safety/

[Evelynn]

Alright, 

 

So, I decided to settle this whole RTE question with the CFIA. I asked if whole mushrooms were considered RTE.

This is the answer I got:

 

"Ready to eat produce is considered to be raw produce that has been peeled, sliced, chopped or shredded prior to being packaged for sale. With the possible exception of the addition of dressing or croutons by the end-user, the product does not require further preparation before consumption. Fresh raw mushrooms that have not been sliced are not considered ready to eat foods.  It is recommended that consumers wash fresh produce under cool, running, drinkable water, before eating or cooking them."

 

Finally. I can sleep at night... 

[Scampi]

Ok, so YOU can sleep at night, but know i have to wash my lettuce and spinach and cabbage and collard greens, and romaine lettuce and aubergine and apples and pears and bananas and zucchini and turnip and sweet potato and jalapenos and MUSHROOMS!  

 

How can i possibly get anything done now that I have all this NON READY TO EAT PRODUCE in my house

 

CFIA never ceases to amaze me.

 

PS; I'm be sarcastic, but I am very glad you finally got clarification

 

 

As a funny aside, the FDA once told me 'its only an egg if it comes from a chicken" !!!!!!!!!

[Scampi]

You totally scored!  If you cut those mushrooms you have to test for listeria, but for whole ones, ah never mind

Would the following (washed or unwashed) products be included in the Listeriapolicy: sprouted seeds/bean sprouts, micro greens, leafy greens and whole mushrooms?

Any types of sprouts, micro greens, leafy greens or whole mushrooms are considered as whole raw fresh fruit and vegetables, i.e., whole fresh fruit and vegetables that have only been trimmed, cleaned, brushed, washed, graded, packaged or similarly handled. According to the Listeria policy, whole fresh fruit and vegetables are not subject to the provision of this policy.

[Evelynn]

You totally scored!  If you cut those mushrooms you have to test for listeria, but for whole ones, ah never mind

Would the following (washed or unwashed) products be included in the Listeriapolicy: sprouted seeds/bean sprouts, micro greens, leafy greens and whole mushrooms?

Any types of sprouts, micro greens, leafy greens or whole mushrooms are considered as whole raw fresh fruit and vegetables, i.e., whole fresh fruit and vegetables that have only been trimmed, cleaned, brushed, washed, graded, packaged or similarly handled. According to the Listeria policy, whole fresh fruit and vegetables are not subject to the provision of this policy.

 

Yes, we used to slice, and we did all the fun testing, etc. then. We actually still test our whole mushrooms for Listeria. 

 

And yeah, I feel better knowing, but I had always wondered why we weren't RTE. As I said before; I'm not going to argue it.

I've always washed all of my vegetables, including mushrooms, and would never eat any veg without washing. Maybe I'm paranoid.

I do appreciate the humour though Scampi!