17 replies to this topic

[Danny]

Hi all,

Been lurking around on these forums for years now, and always found them most helpful. However, I've now got a question I haven't seen answered before.

I've recently been asked to review the HACCP plan for our factory. Now, the ONLY process that takes place at our factory is spray drying, of various different flavours and colours. Currently, the two CCPs in the plan are for the actual spray drying (to remove microbiological contamination) and the sieving of the finished product (to remove foreign body contamination).

Now, the CCL is currently for the inlet temperature, but I've been told by an auditor that the CCL should be either the outlet temperature or the moisture content, preferably both. Ideally I'd like to keep it to just one CCL for simplicity, but I'm having trouble establishing what the CCL should be for temperature.

I tried talking to Campden food research, but had no joy there.

Is there anyone there who can help me? I hope my post is clear enough. All suggestions are welcome!

Cheers! Danny

[Charles.C]

Dear Danny,

Nice to hear from you after several years

Yr query is obviously quite specialised, must admit I got lost regarding the connection between "spray drying" and "microbiological contamination" ! Hopefully there are people here who know more about spray drying processes than me but you may be shortly asked for a more detailed flow chart ??

Rgds - Charles.C

[cazyncymru]

Hi all,

Been lurking around on these forums for years now, and always found them most helpful. However, I've now got a question I haven't seen answered before.

I've recently been asked to review the HACCP plan for our factory. Now, the ONLY process that takes place at our factory is spray drying, of various different flavours and colours. Currently, the two CCPs in the plan are for the actual spray drying (to remove microbiological contamination) and the sieving of the finished product (to remove foreign body contamination).

Now, the CCL is currently for the inlet temperature, but I've been told by an auditor that the CCL should be either the outlet temperature or the moisture content, preferably both. Ideally I'd like to keep it to just one CCL for simplicity, but I'm having trouble establishing what the CCL should be for temperature.

I tried talking to Campden food research, but had no joy there.

Is there anyone there who can help me? I hope my post is clear enough. All suggestions are welcome!

Cheers! Danny

Hello Danny

i have a little bit of experience of Milk powder drying (about 13 years worth!)
but its been a few years. if you pm me what they say etc and i'll dig out what i have

c x

[AS NUR]

Hi all,

Been lurking around on these forums for years now, and always found them most helpful. However, I've now got a question I haven't seen answered before.

I've recently been asked to review the HACCP plan for our factory. Now, the ONLY process that takes place at our factory is spray drying, of various different flavours and colours. Currently, the two CCPs in the plan are for the actual spray drying (to remove microbiological contamination) and the sieving of the finished product (to remove foreign body contamination).

Now, the CCL is currently for the inlet temperature, but I've been told by an auditor that the CCL should be either the outlet temperature or the moisture content, preferably both. Ideally I'd like to keep it to just one CCL for simplicity, but I'm having trouble establishing what the CCL should be for temperature.

I tried talking to Campden food research, but had no joy there.

Is there anyone there who can help me? I hope my post is clear enough. All suggestions are welcome!

Cheers! Danny

Dear Danny..

at our company use Spray drying process too.. But for Non Dairy creamer.. IMEX.. Inlet temperature at the process more than 200oC and the outlet ± 93oC.. and product resident time ± 1 minutes in the chamber.. so with this data we not state spary drying is CCP.. we just put PRP and OPRP for the process before spray dry, because the source of micro contamination came from that process, Both of operators and environment...
and i'm sure that inlet temperature can't below 150oC...

and my reason to auditor during iso22K audit last 2 years ago is the spray drying process can't run with the low temp. (bellow 150oC) and if the process run at inlet temp bellow 150oC, Moisture content product must be greater then 5% and we should be reject the product.. so.. automatically the process must be run at high temp. (> 200oC) and i am sure with that temp. pathogen micro can't leave..

So... my suggestion is better you observe more the deatil of your process.. and IMO the spray drying is not CCP...

Thats my opinion


Rgds

AS Nur

NOTE : Caz.. do you have any doc. for Milk Powder Process.. can you share with me ?

[Biss]

Hi,

I also agree with AS Nur. we are also doing the spray drying activity. In our experiece beacause of law contact time of product with temperature, microbial reduction / elimination cant happen in spray drying activity.

I think it is better to consider sieving activity as OPRP not a CCP if you are implementing ISO 22K

[Danny]

Thanks for the feedback all! BTW, the factory doesn't work to any ISO standard, rather it's currently at BRC issue 5, Grade A.

Generally, the inlet temperature is around 195 C, the outlet temperature is around 95 C and the moisture content is < 5%. However, looking through previous records, I've seen rare circumstances where the inlet temp has had to drop as low as 125 C, outlet to 59 C and moisture to < 6%. Having spoke to the production manager, he's explained how the nature of some products requires a lower than normal temperature to properly spray dry.

So, as I see it, I have three issues:

1) Is the spray drying process a CCP?

A few years back, it wasn't. However, the BRC auditor came along and said that it should be a CCP as it's our way of reducing the threat of microbiological contamination. However, I remain unconvinced that the spray drying is an effective method for this.

2) If not, what CCPs could I use to prevent microbiological contamination?

In my mind, the prerequisites covering purchasing of raw materials and plant /operator hygiene are our most effective, consistent methods.

3) If so, how can I set the correct limits and justify them?


I hope this all makes sense. Thanks again for your help, and let me know if you need any more information. Cheers!

[Biss]

Hi Danny,

1) I dont think spray drying is a CCP
2) Do you have any issues of microbial contamination in your products ? if there is a possibility of harmful mico organism in the Raw material, then you have to do the sterilization of raw materil / final product like ETO / steam sterilization

[Charles.C]

Dear Danny,

One suggestion – Post yr process, just a (horizontal) straight line version showing process steps is probably enough.

After all this discussion, you may hv a process with no CCPs, the auditor will love that.

Strictly any CCP is based on the risk analysis of your system of course. Where the decision is not automatic the pragmatic (ie acceptable to the auditor) choice often revolves around 2 criteria - (a) can you validate yr decision (published model plans, etc) and (b) (which should be a corollary of [a]) – what do most other people do for an analogous process?. May not be so easy if you hv a rare process but this looks unlikely in present case. ??

No experience yr (partially specified) process (I deduce no pasteurisation steps are involved) however I did a little googling and the links below appeared relevant to yr situation however I may still be totally incorrect, if so, apologies in advance. Other links obviously existed but required money.

The conclusions regarding the spray-dry / CCP step appeared to me in agreement with AS NUR. As far as any other CCP possibilities, it comes back to the risk analysis and (a), (b) above. For example, environmental contamination is obviously a key factor with serious potential implications but how likely is it in your opinion ?, ie are the hygiene controls (= PRP) adequate. Or is some equivalent functional step but not an actual PRP involved, this could be a CCP (or maybe an oprp in the (undesired) ISO 22000 lingo).

Links -

1. http://www.codexalim...26/cxp_066e.pdf
(eg pgs 10-14, eg 5.2.2.3)(I realise this product may be for a more sensitive consumer)

2. Google “salmonella in dried milk " (no inverted commas)
look for "microbiological testing in food safety management" ( detail microorganisms in food 7 in text) which appeared near top / 1st page for myself
Go to pgs 279 – 282, (one middle page is missing, for probably obvious reasons )

Rgds / Charles.C

added - of course, if the auditor was quite happy with the sieving as a CCP, no need to change that! yr auditor considered spray-dry step to be a CCP, do you hv a validation for that ??
Did you consult Caz yet ?, she certainly knows more than me.

[AS NUR]

1) Is the spray drying process a CCP?

No.. AS i said before.. minimum resident time of the product ± 1 minutes at 65 - 95 oC.. and as I know the sterilize process at ± 75oC need 15 Second.. And your process have min. temp is 95oC.. I think thats enough to kill Pathogenic Micro...And if your temp. process bellow then 95oC I am sure you can't run your process.. that is the reason why we don't put Spray drying process as CCP..


2) If not, what CCPs could I use to prevent microbiological contamination?


IMEX.. In spray drying process contaminated micro came from Compressed air that use to cool the product the temp. ± 40oC.. in our process we use filter in compressed air equipment as CCP. and we monitor that filter more frequent by visual and verify the micro using air contact plate method every week...


3) If so, how can I set the correct limits and justify them?

I think you don't need to set the temp. limit of spray drying process





thats my opinion hope can help you

[Suzuki]

Danny -

A few years back, it wasn't. However, the BRC auditor came along and said that it should be a CCP as it's our way of reducing the threat of microbiological contamination

I have to agree with the BRC AUditor as this is your final "kill step" for potential microbial presence. I can understand the final spray dry temperature varies according to your product types (internal content) hence the differences in end product tolerable range of moisture content.

Au Nur -

IMEX.. In spray drying process contaminated micro came from Compressed air that use to cool the product the temp. ± 40oC.. in our process we use filter in compressed air equipment as CCP. and we monitor that filter more frequent by visual and verify the micro using air contact plate method every week...

Agree with you that this is a potential source of recontamination after spray drying. Can it not be placed under PRP monitored by your OPRP maintenance verification and supported by internal / external validation using air contact plate etc. Because if this is a critical souce of recontamination, verification frequency may needto be intensified as weekly may or may not be adequate.

Biss

I think it is better to consider sieving activity as OPRP not a CCP if you are implementing ISO 22K

Why!

[Charles.C]

Dear AS NUR,

Item1. Maybe I misunderstand but it seems to me that you are claiming that in the typical spray-dry process considered here (no pasteurisation), the operation of the spray drier will eliminate any microbiological contamination prior to the spray-drying step. This property IMO could suppport the step as a CCP if validation requirements are available (eg external references, actual operational data). However it appeared to me from previous posts that in Danny’s case, his process is currently not in general set up to achieve this target (eg his comment about having occasional much lower temperatures than you think possible [my knowledge insufficient to comment on that]).
This aspect of “not intended” seemed to be equivalent to info in the links I mentioned hence my opinion of non-CCP. However eventually it all comes back to the existing process design capabilities and intentions.

Another viewpoint is that appropriate GMP control procedures may simply be sufficient / validatable (eg with respect to the final product specification) to show that there is no reason to look for a CCP capability in the spray-dry step as used here ? It is always nice to reduce the CCPs if possible, unless Danny’s auditor has a minimum requirement of 2.


item 2. Have to say that this looks like a pragmatic CCP to me. Auditor problems also ??

item 3. IMO, based on yr operational comments, looks like Danny has to clarify his process details and requirements. And find some validations ?

I suspect these kind of arguments (for metal detectors) led to the inclusion in the Codex D-tree of the “specifically included in the process” route as one convenient definition of a CCP.

Rgds / Charles.C

added - Sorry Suzuki, I didn't see yr post before clicking. We seem to hv some agreement in the absence of data to the contrary !

[Biss]

Hi Danny,

please see the link below which discuss whether sieveing is CCP / OPRP

http://www.ifsqn.com...t...&hl=SIEVING

[AS NUR]

Dear Charles

Item1.

yes your right Charle.. that is typical process for spray dryer.. spray dryer using high temp, because the objective process is to reduce moisture content from ± 35% (equal Total solid ± 65%) to < 5 %, range 2 - 4 %, in short time , < 1 minutes contact time... so if the process using low temp for example < 95oC (outlet temp) in danny's case.. the can't dr... IMEX.. we can get lumpy products and the system must be stop to clean it...

And for pasteurizer process.. IMEX.. in NDC we use similar (we call HIPEX) process only for increase the Total Solid content and reduce the viscosity.. and we can't validate the micro content before and after HIPEX because this is the closed system..

the source of micro is from hygienic practices (in my company we use that as PRP) and during cooling process (static fluid bed dryer and vibration dryer), we use compressed air to reduce temp. of product from ± 70oC to ± 40oC as i mention in last post..


item 2.

no comment about this..

item 3.

IMO for the other CCP .. according to danny's process after spray dryer process.. if using metal detector at filling line as same as with us.. yes.. the MD is CCP

[Simon]

Any more comments on this Danny / other members?

[Danny]

Thanks for all the replies, you've all been a huge help. Unfortunately I've been having to deal with several other issues at present and haven't been able to focus on this, but I'm going to read through the replies again later and let you know the results. Thanks again!

[Tony-C]

Hi Danny

I worked with spray drying milk in the past (4 tonne per hour Niro).

Our products were pasteurised prior to spray drying so the temperature wasn't a CCP. If spray drying your products reduces bacteria levels to safe levels or kills pathogens that are present then the inlet temperature or the outlet temperature should be regarded as a CCP.

There are other hazards that have been mentioned in the forum such as air quality.

The only other thing I would like to add is that there have historically been problems (Food Poisoning Incidents) caused by cracks in the spray drier. The cracks allowed pathogens to seep into the spray drier and contaminate the powder. Therefore regular dye inspections are recommended.

Hope this helps,

Tony

[Abdul Qudoos]

Hi all,

Been lurking around on these forums for years now, and always found them most helpful. However, I've now got a question I haven't seen answered before.

I've recently been asked to review the HACCP plan for our factory. Now, the ONLY process that takes place at our factory is spray drying, of various different flavours and colours. Currently, the two CCPs in the plan are for the actual spray drying (to remove microbiological contamination) and the sieving of the finished product (to remove foreign body contamination).

Now, the CCL is currently for the inlet temperature, but I've been told by an auditor that the CCL should be either the outlet temperature or the moisture content, preferably both. Ideally I'd like to keep it to just one CCL for simplicity, but I'm having trouble establishing what the CCL should be for temperature.

I tried talking to Campden food research, but had no joy there.

Is there anyone there who can help me? I hope my post is clear enough. All suggestions are welcome!

Cheers! Danny

Greetings to the readers,

Sieving may be the CCP, if there is physical hazard involves imagine while loading a batch, paper-peice, plastic-packaging material peice, thread comes from packaging material stiching, flies (which revolve around the head sometimes) any other foreign matter can easily pass in the mixing tank then we need to re-work or discreminate the whole watch, so we need to keep seiving may be maximum 4 mm in diameter size by this we can control any foreign matter which comes contact with product, the customer requires 'zero' physical contaminant product to make sure CCP is our seiving. So 2 CCPs are fine.

CCL is currently for the inlet temperature is fine, you are confident about the process and manufacturer manual explains about the process, and your CIP is in place, the records of CIP also proves the same. You may take help from spray drier manufacturer for the same. Surely they will help.

Although my english is little pitiable i tried to explain the situation. Hope you understand, for more queries please feel free to reply me.

[Charles.C]

Dear Abdul,

Yr English is just fine and many thks for all yr multi-thread contributions.

Rgds / Charles.C