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Handling of Potentially unsafe products Clause 7.10.3.2

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Ayuse

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Posted 20 July 2018 - 09:50 AM

Hello brilliant minds,

 

Please provide me clarity on this clause;

 

Evaluation for release
Each lot of product affected by the nonconformity shall only be released as safe when any of the following
conditions apply:
a) evidence other than the monitoring system demonstrates that the control measures have been effective;
 
b) evidence shows that the combined effect of the control measures for that particular product complies with
the performance intended (i.e. identified acceptable levels as identified in accordance with 7.4.2);
 
c) the results of sampling, analysis and/or other verification activities demonstrate that the affected lot of
product complies with the identified acceptable levels for the food safety hazard(s) concerned.
 
I work for a seasonings/flavor blending company that  utilises salt as a major ingredient, MSG, herbs & spices in descending order.
Our expiry dates are 1 year old and many times, slow moving products expire while at dry, ambient storage.
 
Is it possible to release a dry seasoning blend (past expiry date) back into production and rework into a larger batch say (5kg in 1000kg) without sending a product for micro evaluation to an external lab?
 
We will of course do an organoleptic report to verify quality of the product, review C.O.A's (to ensure ingedients used for the blend are still within expiry date) and add the production record to show control during blending. Will this suffice?   :uhm:
 
 
 
 


Scampi

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Posted 20 July 2018 - 01:58 PM

ok, that clause basically means that you cannot rely solely on the monitoring records when the product was produced.

 

So you couldn't say, well the CCP was within limits so even though its xxxx, we will release it

 

 

If product has expired, it should NOT go back into rework.......that should have happened while there was still viable shelf life...............that may constitute "adulterated product"

You get to determine shelf life, so maybe focus on shelf life extension and production volumes instead of an after the fact work around

 

I am not saying micro is an issue, but rather how potent the flavour profile is and customer satisfaction levels as a result of blending expired product back in


Edited by Scampi, 20 July 2018 - 01:59 PM.

Please stop referring to me as Sir/sirs


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SQFconsultant

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Posted 20 July 2018 - 05:01 PM

"Is it possible to release a dry seasoning blend (past expiry date) back into production and rework into... "

 

Answer: NO!


All the Best,

 

All Rights Reserved,

Without Prejudice,

Glenn Oster.

Glenn Oster Consulting, LLC -

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http://www.GlennOster.com

 

774.563.7048


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