10 replies to this topic

[trubertq]

Good Morning everyone,
What a great resource, and thanks to everyone who's docs I have used as guidelines.
I am helping my old Company prepare for BRC, and am writing up the manual for them from home.
We need to do procedure for diluting chemicals, however, the cleaning chemicals are run through a power washer. There is a gauge which can be set to determine the concentration of the chemical, but, there is no way of finding out if this gauge is correct.The QM says it is nigh on impossible to get a sample from the business end of the power washer because of the force of the water. I am stumped on how to deal with this in either a procedure or record.

We also have an issue with positive release.....well there is none. basically the product is sous vide shellfish, and is working on a JIT system which means that the Micro results are not back by the time the product is released. The product is going to Europe mainly and has a 3 day transit time, therefore is able to be recalled should anything arise. This always gave me the heebie jeebies when I worked there as Microbiologist, but how do I deal with it wrt BRC? I can't see how they can change their procedure because of the shelf life restrictions on theproduct and their remoteness from their market. Any bright ideas?

Having said all that, they have very few problems considering the tonnage of product they supply.

[Charles.C]

Dear trubertq,

Yes, I once had to routinely take manual samples from a total factory waste water discharge pipe, not the most co-worker friendly of occupations. I called it circumferential sampling. The only way to judge the sampling accuracy was to do several repeat samples/measurements and do a routine stat.evaluation. Depends on what level of accuracy is required of course. I hv no idea what a power washer is unfortunately. The usual first approximation is presumably based on known input flow rates (like used for chlorine injectors into metered factory water supplies) but I suppose the situation is different here. A permanent installation wud presumably have a tee-in at the outlet to enable an in-flow sample to be taken, something like the pitot tube systems. Sounds like a standard chem.engg. problem.

Regarding positive release, it depends on specific mic. item involved but I hv previously seen a related situation where a (compromise?) procedural minimum delay time of (from memory) one day was used which enabled a mic. technique for a particular (indicator) characteristic to be (+/-) evaluated with the other parameters like your own case being obtained during a (stoppable) transit. A risk analysis using extensive historical data underpinnned this procedure. I also found the methodology questionable however it was BRC auditorily acceptable (bit like the ISO philosophy maybe, as long as you do what you define as “quality” acceptable, with a [personal] validation supplied).

Rgds / Charles.C

PS, just noticed yr 2nd whelk post, fascinating info. indeed, I often wondered if the song "we are the champions" had the same connotations.

[GMO]

I don't think positive release has to be based on microbiological results; it's a bit anti HACCP in fact. IMO, you can base a positive release system on your CCP and quality checks, if all are in spec the micro should look after itself (or your HACCP is wrong!) Micro should only be verification.

[Tony-C]

Good Morning everyone,

We need to do procedure for diluting chemicals, however, the cleaning chemicals are run through a power washer. There is a gauge which can be set to determine the concentration of the chemical, but, there is no way of finding out if this gauge is correct.The QM says it is nigh on impossible to get a sample from the business end of the power washer because of the force of the water. I am stumped on how to deal with this in either a procedure or record.

One way around this is if you put a water meter on the line to the power washer and monitor the water and chemical usage you will be able to calculate the dosage - providing you don't have a load of leaks.

Regards,

Tony

[Charles.C]

Dear GMO,

I initially used a system (no documented HACCP problem > authority to ship) very similar to yr logic and the auditors classified it as negative release. Maybe some auditors are more flexible than others.

Rgds / Charles.C

[ads78]

We have a pressure washer with auto dosing sanitisers. This is fed through a valve that will dose only at the correct level and is checked by the chemical company. In your case, I imagine that you may be able to remove the power lance on the hose pipe end which may help things from a sampling point of view?

[SUJIT_KGPIAN]

We have a pressure washer with auto dosing sanitisers. This is fed through a valve that will dose only at the correct level and is checked by the chemical company. In your case, I imagine that you may be able to remove the power lance on the hose pipe end which may help things from a sampling point of view?

Even we follow similar method. Auto dosing systems are good but have to be periodically monitored. & evaluated

[Simon]

What do you think Trubertq?

[trubertq]

Thanks everyone...sorry I went walkabout for a bit...

I think there will have to be sampling done at some point it's just a case of convincing someone to do it lol

[GMO]

Dear GMO,

I initially used a system (no documented HACCP problem > authority to ship) very similar to yr logic and the auditors classified it as negative release. Maybe some auditors are more flexible than others.

Rgds / Charles.C

I agree, that is negative release, that isn't what I meant. I meant that before the product is released, all paperwork with CCP checks on should be checked that these checks have passed and this should be signed off by a responsible person (in our case a QA technician). If you are just relying on the absence of a problem, then yes, that is negative release, positive release must check for presence of results within specification. Personally I think waiting for micro results is worse as micro can be patchy.

[trubertq]

I agree, that is negative release, that isn't what I meant. I meant that before the product is released, all paperwork with CCP checks on should be checked that these checks have passed and this should be signed off by a responsible person (in our case a QA technician). If you are just relying on the absence of a problem, then yes, that is negative release, positive release must check for presence of results within specification. Personally I think waiting for micro results is worse as micro can be patchy.

How very dare you!! LOL Micro is the most inexact science there is !!!