12 replies to this topic

[adobrosielska]

Hello everyone
Last week I had two audits and one was really surprising for me. I work in mill, we made good flour from bad wheat Our production is really specific: we have no clean or dirty zone, our workers have no contact with product because all lines are close. The wheat come into the mill and, in the end, we have finished product paked into sacks. Samples are taken by special equipment, that's how we get flour for all laboratory test.
The most important thing are kilometers of pneumatic transportation.
Ok, that's how generally everything look like. What is my problem? Well, one of the auditors wanted from us making microbiological smear test of production surfaces. My question is how? Our production is on 4 floors and this unfortunate pneumatic transport. We have all microbiological test of flours made once a mont or two. We make test for mycotoxins, pesticides and heavy metals. Our clients don't want us to make them at all, but it's better for us to have all these results. Polish law also doesn't mention about any microbiological test for flours. The auditor came with check list made for all types of production, especially meat production, and didn't want to listen our explanations.Is there any possibility to convince her to change her mind? Or maybe we will have to make those tests? But which moment of production will be most proper for this kind of tests?
Maybe anyone had similar problem? I 'll be very thankful for every help
Best regards for all

[MartLgn]

I think there is a strong possibility of you convincing your auditor that she is wrong to require production surface swabs, I am unaware of this practice being commonly requested by auditors visiting UK mills and it certainly does not happen in any of our groups mills.

Any microbiological load in flour is most likely to come from the wheat, once milled it is pretty difficult to contaminate flour microbiologically, it is low in protein, has low moisture and the only aspect of the process that would promote microbiological growth is the warm temperatures generated in the transfer pipeways and purifiers.

The fact that it is not industry practice should be an indicator that it is of no benefit, if there was a safety benefit to be had then in the UK NABIM would recomend that we took swabs , but they don't and neither does the UK milling industry.

This paper gives an insight into microbiological issues assocated with flour.Micro of flour

[adobrosielska]

Thank you very much for your answer. It made me really calm, there was a moment I was afraid I missed something in my HACCP plan
The paper you showed is really interesting and I will take some parts of it to prove our statement. I hope you don't mind it?
Thanks once again.

[YongYM]

I think you have done your part already.

Besides, flour is not commonly consumed in raw form but needs further processing by food manufacturers. They are the one who need to be more stringent than you, correct?


Any comment from others?


Yong

[Charles.C]

Dear All,

I am ignorant about flour manufacture or analogous processes but I am bit confused over this thread. I understand the point that a long, closed system is involved but does this really guarantee no hygienic issues which was I suppose the point of the auditor’s request ? (I can see the conceptual difficulty over sampling but I presume the ubiquitous audit checklist is involved here ) How about microbiological xcontamination issues from an “unlucky” batch. ? Cleaning validation ? Maybe I am missing something.

Martin’s link is indeed a fascinating and beautifully presented document (especially if desired to avoid pathogen testing). I have tried similar arguments for other raw, non – agricultural products however, legally, entities like Salmonella are often simply not acceptable in raw items despite all eloquent explanations and customers demand to protect their “backs” (bye-bye HACCP ). How about flour ?

Sorry to inject a negative flavour, just seeking enlightenment.

Rgds / Charles.C

[Charles Chew]

he auditor came with check list made for all types of production, especially meat production, and didn't want to listen our explanations

Another mechanical audit using an audit checklist.........Bravo!

We make test for mycotoxins, pesticides and heavy metals.

Pretty well covered from my point of view. Does your myco test cover "Ochratoxin"?

[adobrosielska]

Dear Charles C.
Your negative flavour is really important. I posted on the forum because I knew there will different points of view, which have significanr meaning for solving the problem
Ok, we want avoids making swabs because next auditor will ask us why here? Why not in the machine on the left, why not 10 meters on the right? In our products (flours, brans and also in grains) we check: bacterias form coli group, Staphylococcus aureus, Bacillus cereus, E. coli, Salmonella, mould and yeast and total amount of microbes. We never had positive salmonella tests. I know "never had" doesn't mean "we wil never have". That's why we make those test regulary. So we can see also if there are any changes in amounts of other microbes. If something is going in not too good direction we clean all the parts of equipment. I didn't mentiond about cleaning validation because it was obvious for me. We have schedule of cleaning all the machines and, of course, we do it. And when something needs to be repaired it is also cleaned another time, besides the schedule.
Another thing is taht all sources I found don't mention abou Salmonella in wheat grain or in flours. The most common are Pseudomonas sp., Erwinia herbicola, moulds from Alternaria, Cladosporium, trichoderma, Geotrichum and yeasts. When we store the grain we can also have moulds from Aspergillus and Penicillium, bacteria from coli group, Streptococcus and Staphylococcus, milk fermentation bacteria and two others which I can't translate into English, sorry

"Does your myco test cover "Ochratoxin""
Well, we check Ochratoxin, Aflatoxins B1, B2, G1, G2, Zearalenon and DON. We test it in all types of products, like microbiology. Mycotoxins are really interesting for all millers in Poland beacuse two years ago one of polish mills made flour from rest of the grain they had in store. In few weeks later we could heard in tv about killing flours. The case was really big because contents of mycotoxins in their products was few times hiher than all rules and laws allow.

I wrote a lot I and I hope I didn't lose point of what I wanted to say.

Edited by adobrosielska, 21 August 2008 - 07:32 AM.

[Charles.C]

Dear Adobrosielska,

Ok, we want avoids making swabs because next auditor will ask us why here? Why not in the machine on the left, why not 10 meters on the right?

Actually, this is quite easy, simply invoves making a list of items and taking a “random” selection for each routine evaluation, eg monthly. If you prefer to be more analytical can separate say 4 items into each of a few categories,eg A,B,C and take one from each. I have never had an auditor dispute such a procedure (it looks authoritative and he probably doesn’t care that much about the details anyway, [time = money]).

Although I agree with CharlesChew regarding the limitations of checklists I am afraid they are not going to disappear this millenium. I once enjoyed long arguments with auditors over such matters but sometimes pragmatism is the easiest way out to avoid suffering frequent mental indigestion.

It’s an interesting, and probably controversial, topic. I regret my lack of detailed knowledge of yr industry.
I presume your current validation is (visually clean + following yr SOP). I think many auditors (CharlesChew will disagree perhaps) will simply expect to see some swab checks as part of the initially proposed cleaning validation procedure. I am unclear as to the frequency of people using swab tests to validate for dry proceses ?? If in fact the use is not rare it will maybe depend on yr willingness to convince an auditor when his typical experience is the contrary (ie MartLgn is a brave [and determined] exception ). If the opposite is true and you can present such (auditable) evidence then MartLgn’s minimalist route is surely the way to go. Requirements for validation are discussed in several threads on this forum including one for a non-enclosed, dry process. These well illustrate the difficulties of selecting microbial swab limits if used (but equally the flexibility of interpretation to the user). Subsequent production data is primarily considered as verification material IMEX. Good luck.

Sadly, if yr flour is anything like the MartLgn linked reference document, normal sampling procedures will be ineffective for pathogens like Salmonella. Nonetheless and equally sadly, my guess is the vast majority of manufacturers are still obliged to do it for business / legality reasons; the repeat follow-up to any rare positive result is virtually always a negative of course (the very few times ++ did happen IMEX genuinely resulted from massive contamination in the raw material from a new supplier so I suppose the concept is not totally worthless under certain constraints).

Rgds / Charles.C

[Charles Chew]

Well, we check Ochratoxin, Aflatoxins B1, B2, G1, G2, Zearalenon and DON. We test it in all types of products, like microbiology.

These validations are fantastic. Personally, from mycotoxin angle, you had substantially covered most of it. I take it that you had also covered fusarium.

On microbiological concerns, the article inserted by MartLgn summed it all up. Yes, it is an extremely interesting industry. IMO, there is probably more concern about mycotoxin cross contamination from old grains retained in the process system than swabs on equipment surfaces.

[MartLgn]

I am ignorant about flour manufacture or analogous processes but I am bit confused over this thread. I understand the point that a long, closed system is involved but does this really guarantee no hygienic issues which was I suppose the point of the auditor’s request ? (I can see the conceptual difficulty over sampling but I presume the ubiquitous audit checklist is involved here ) How about microbiological xcontamination issues from an “unlucky” batch. ? Cleaning validation ? Maybe I am missing something.

Nobody is seriously claiming that there are no hygiene issues in flour milling and you are correct Charles that a closed sysytem does not eliminate them, the point I was trying to make was that swabbing of equipment surfaces in a flour mill would be a terribly inneficient way of detecting microbilogiocal contamination as such surfaces tend not to promote nor harbour micro-organisms. With regard to cleaning validation most cleaning of milling equipment is 'dry' as flour, water and moving parts are not a good combination.

I think many auditors (CharlesChew will disagree perhaps) will simply expect to see some swab checks as part of the initially proposed cleaning validation procedure. I am unclear as to the frequency of people using swab tests to validate for dry proceses ?? If in fact the use is not rare it will maybe depend on yr willingness to convince an auditor when his typical experience is the contrary

It's certainly rare in the UK and Eire flour milling industry.

(ie MartLgn is a brave [and determined] exception thumbup.gif ). If the opposite is true and you can present such (auditable) evidence then MartLgn’s minimalist route is surely the way to go.

If only! It's the position of the UK's largest flour miller and operator of the largest mill in Western Europe, the HACCP plan for this mill addresses the microbiological risks using scientific advice along the lines of that touched on in the paper I linked to. To hopefully illustrate the faith we have in this approach the majority of flour produced in this mill goes into bakeries owned by the group which produce many major brands.

[adobrosielska]

If you prefer to be more analytical can separate say 4 items into each of a few categories,eg A,B,C and take one from each. I have never had an auditor dispute such a procedure (it looks authoritative and he probably doesn’t care that much about the details anyway,

Well, I really like this way of making swabs I even started thinking about 4 places to do the tests But I posted because I agree with MartLgn: it's not the best way of checking microbiological conatmination in mills.


Sadly, if yr flour is anything like the MartLgn linked reference document, normal sampling procedures will be ineffective for pathogens like Salmonella.

That's what worries me. So how to make samples for microbiological tests? I don't want find any Salmonella, I just want to make sure that my products are safe we want make all test we don't not because we have to (the truth is we still don't have to) but because we care.

One thing more: some days ago when I was reading other diffrent kind of topics I found one document about wheat flour. It can bring closer some requirements for flours.

Best regards for all and thank you very much for your really interesting points of view.

Attached Files

•  CXS_152e.pdf   19.73KB   114 downloads

[Charles.C]

Dear Adobrosielska,

That's what worries me. So how to make samples for microbiological tests? I don't want find any Salmonella, I just want to make sure that my products are safe we want make all test we don't not because we have to (the truth is we still don't have to) but because we care.

Without using enormous sample sizes as defined in the ICMSF food sampling standard, the usual recommended approach is the one given in MartLgn’s / Sperber ref (SR), ie to be confident of the reliability of yr HACCP system and its associated procedures. IMEX for other products this kind of logic in the absence of any other data will unfortunately generate some audit queries. I hv no idea for flour and if the UK well accepts SR I presume this smooths the audit. Any alternative option like the usual ncMm method obviously requires appropriate specs., for example I noticed what appeared to be an opposite situation to UK in Australia (ca 2003) –

http://www.foodscien.../flourmills.htm


Some of the comments in the SR regarding Salmonella did seem a little over-convenient to me. Having worked with raw products exported to the USA, all scheduled to be cooked, I can assure you that the detection of any Salmonella was cause for immediate rejection. Example of a double standard required by economic necessity maybe.

CharlesChew’s comment on mycotoxin residues also offers another route to cleaning validation analogous to options invoving risks from allergenic situations. I don’t know if there are any (reasonably) quick and inexpensive methods for checking for such parameters though. A quick look on IT suggested not. ??

Thks for the interesting attachment. I noted a typical Codex moment here –

When tested by appropriate methods of sampling and examination, the product:
- shall be free from microorganisms in amounts which may represent a hazard to health;

Very useful !

Rgds / Charles.C

[adobrosielska]

Dear Charles.C,
all your replays were very useful for me. I found few interesting things on ICMSF websites, information about sampling and about flour industry.
Another thing: australian millers and flours. In Poland millers don't have to put microbiology test in their HACCP plans and we don't have official specifications for products with microbiological limits. The mill, where I work, made such a specifications because we have some big clients who demand such a document. We talked to them and these specifications are our common opinion. I must admit that the biggest problem we have with moulds. The limit is 1000 moulds per gram of the product. Sometimes there's more and we clean the equipment in the production area besides the schedule.
To solve the swabs problem I used all the information I had and I get thanks to your replays. I'll get you know when this everything finishes
One more thing: I also asked my friends in Poland to help me solve swabs problem. And their answers were really surprising for me. Most of them decided to do what the auditor said, they just gave up without any fight! It's amazing for me because they admitted that such an auditor's recommendation is rather unusal in this kind of production. I hope that they will be more assertive when they have this kind of situation in their own industrial works
Best regards
adobrosielska