Inspection position in 22000

Hi everyone

I have a question about control measures in 22000. I work in a flour Mill.

Could I consider raw material and end product inspection as control measures in hazard analysis?

I think as they can not prevent, eliminate or decrease the hazards they should be included in verification plan.

thank you everybody
A. Mirzabeigi

Amir

You need to be more specific about the hazards you have in mind but you can consider raw material / supplier selection selection as a prerequisite.

End product inspection is not a control measure but could be a verification activity for a specific hazard.

Hope this helps.

Ken

Amir

You need to be more specific about the hazards you have in mind but you can consider raw material / supplier selection selection as a prerequisite.

End product inspection is not a control measure but could be a verification activity for a specific hazard.

Hope this helps.

Ken

Thank you ken

Our regulations make us to do tests for incoming wheat regarding moisture, Gluten, Impurities and Hectolitre. We shall not discharge loads with below our standards specifications. Also we have some standards about flour like Ash, Moisture, particle sizes and gluten. (I know some of them are quality issues)
after 22000 implementation I want to use our QC forms to prevent the records to increase unnecessarily. I think incoming tests could be used for raw material verification and our machineries parameters like sifter, magnets, aspirators and etc are control measures to decrease or eliminate the hazards which should be monitored and final tests are the same verification activities to make sure hazards are really eliminated.

am I right??

Best regards

Amir

The tests you quote (other than impurities) are all about quality - nothing to do with food safety and therefore not relevant as far as ISO 22000 is concerned.

Obviously your Haccp plan will identify physical hazards, chemical hazards such as pesticide residues and any microbiological hazards associated with the raw material. The controls and monitoring activities associated with the raw materials will come from this and some of the controls will be in the process such as magnets which are controls measure for specific physical hazards.

What is the final test which you do?

Regards

Ken

dear ken

The test for final product is Ash, Moisture, particle sizes, gluten, PH and Acidity. (I know some of them are quality issues).

best regards

dear ken

The test for final product is Ash, Moisture, particle sizes, gluten, PH and Acidity. (I know some of them are quality issues).

best regards

Amir

The tests you describe are all quality checks and therefore not relevant to verification of Haccp.

I can't see how any of these tests can be a verification activity for a specific food safety hazard under Haccp.

You really need to forget about all these quality checks on raw materials and the finished product and just think about the identification of food safety hazards and the development of the haccp plan.

You should find lots of help on this in other parts of the forum.

Regards

Ken

Dear amirhosein,

There are also 2-3 detailed haccp plans for flour on this forum if you try a little searching, eg "+flour +haccp"

Why do you test for gluten?, I thought all flour had it ? Just curious, not my area . I presume this will be ultimately related to labelling (safety?) requirements.

Rgds / Charles.C

thanks friends,

not all tests are for 9001. Wheat has aflatoxin which we can not recognize it by laboratory tests. Just our wheat suppliers ought to send wheat free of mycotoxins like
aflatoxin. But we test it visually. If it has mould or yeast it may have mycotoxins. Also
moisture is a safety paramtere and wheat with high moisture have definitely safety problems. In order to determine that the flour produced is free from them we do microbial test for final product so it could be a verification activity (target sampling).

Also insoluble Ash in acid of flour is an index of sand and stone in flour which could be hazard as it results in kidney disorders.

I think all cleaning machines which take stone and sand must be monitored and Ash test of final flour is a verification because it shows that our control measure have been able to remove the hazard.

thank you

Amir

The following topic had a useful discussion on the choice of CCP's in flour:

http://www.ifsqn.com...showtopic=13415

Regards

Ken

Amir

The following topic had a useful discussion on the choice of CCP's in flour:

http://www.ifsqn.com...showtopic=13415

Regards

Ken

Thanks a lot Ken

You are very kind to me. I have visited this link before but CCPs are not proper in my view of point.
I really wanted to contact you directly but I couldn't. It seems that you are so active and have much skill about food safety.
All in all I appreciate your patience.

BR
Amirhosein

Amir

What are your CCP's?

Obviously your Haccp plan will identify physical hazards, chemical hazards such as pesticide residues and any microbiological hazards associated with the raw material.

You must also ensure that you address allergens in your HACCP (ie Gluten)

thanks friends,

Our wheat suppliers ought to send wheat free of mycotoxins like
aflatoxin. But we test it visually. If it has mould or yeast it may have mycotoxins.

Testing for aflatoxins should be part of your pre-requisites or a parameter on your specification for which you get a COA for incoming products. When you say you test visually, do you mean plates? Yeats may not always be evident in products.

Hi

I don't know whether my friends here know flour production process or not. I attach our HACCP Plan and I would be grateful If anyone adds comments about it. I think it is good but not perfect. Unfortunately flour production process is experience intensive and many controls are based on experience not exact measurements.

Best regards

Amirhosein

Dear Amirhosein:

How about:-
- Deoxynivalenol (DON , Vomitoxin) that occurs in grains such as wheat, barley etc
- Zearalenone which does not seem to occur in significant amounts prior to harvest, but under proper environmental conditions, it is readily produced
- Heavy metals from the soil
- Pesticide residues, residue of fumigant (during fumigation of silo)
- Some pathogenic micro-organisms
- Physical hazards e.g. metal fragments, wood splinters etc.
- Presence of weevils etc.
- Allergen e.g. mixture of other grains e.g. corn etc. during shipping of wheat kernel.


Yong

Amir

I had a look at your list of CCP's.

I think you need to define the hazards more clearly. e.g. For intake you have a hazard listed as 'Biological' - this is a generic term for a group of hazards and is not a specific hazard.

You need to identify and define the actual hazard which is sometimes a lot harder than it sounds. Many people will 'know' the hazard but find it difficult to come up with the right words so that it is meaningful to another person who is reading the plan.

You should consider something along the lines 'The presence / growth of X due to Y'.

'Y' refers to the circumstances

A microbiological hazard could be 'The growth of moulds and production of mycotoxins due to storage at a high humidity'.

You could be more specific on the type of moulds / mycotoxins although these would probably be detailed in the introduction to the Haccp plan where you would detail the type / groups of hazards under consideration by the Haccp team.

Dear amirhosein,

Agree with Ken. Regarding the typical initial HACCP stages, yr attachment looks more like a general overview, needs more specifics.

Some of the queries in Ken's post should hv been answered in yr starting hazard / risk analysis for ccps and in the associated validation data ??.

FAO / Codex hv issued several detailed downloadable documents giving global examples of haccp / hazards for agricultural products, including assessments of the pre-harvest contaminants. Linked somewhere on this forum.

Rgds / Charles.C

Dear friends,

the points you mentioned were excellent. But the problem is that it is too hard to detect each type of mycotoxins. if anyone knows simple ways let me know.
We test final flour. I know this is not a good solution but we load about 20 wheat trucks each day and there is apperantly no fast way of detecting the biological hazards you mentioned. Our wheat suppliers are also traditional and have no laboratory to issue Quality certificate for trucks But about foreign wheat suppliers like AWB, CWB, BUNGE, CARGILL and like them we have no problem we only check their documents.

Another problem we have is about monitoring biological related machinery (control measures) to check if they are working as per plan and also in process verification of such machines is very hard.
for example the machine scourer takes a thin layer of the bran and in fact decreases the microbial load. So we don't know good ways of setting limits for this machine.

I ask anyone who has a good solution to mention it here.

best regards

Dear friends,

the points you mentioned were excellent. But the problem is that it is too hard to detect each type of mycotoxins. if anyone knows simple ways let me know.
We test final flour. I know this is not a good solution but we load about 20 wheat trucks each day and there is apperantly no fast way of detecting the biological hazards you mentioned. Our wheat suppliers are also traditional and have no laboratory to issue Quality certificate for trucks But about foreign wheat suppliers like AWB, CWB, BUNGE, CARGILL and like them we have no problem we only check their documents.

Another problem we have is about monitoring biological related machinery (control measures) to check if they are working as per plan and also in process verification of such machines is very hard.
for example the machine scourer takes a thin layer of the bran and in fact decreases the microbial load. So we don't know good ways of setting limits for this machine.

I ask anyone who has a good solution to mention it here.

best regards

Anyone have further comments or ideas on this?

Dear Amir,
You have too many CCPs in your HACCP Plan when most of mentioned "concerns" can be controlled by OPRPs such as intake of wheat which is controlled against agreed batch specifications (usually done after confirmation of samples and before contract is signed with subsequent delivery sample reconfirmation when shipment is received).

The obvious CCPs are your last stage Magnet and Sieving Processes for physical hazards. I believe the homogeneity of your vitamin / preservative additives needs consideration as control of chemicals. The control of Mycotoxins (various i.e. Penicillin and Aspergillus Type) can only be minimized through process system cleaning given the numerous bucket elevators, gravity pipes including screw conveyors involved. Of course there is no generic answer to your predicament. I believe you would know what to do as you know your system better than all of us.

I can only offer you this advice. For a process step to be classified as a CCP, it needs to be a "KILL STEP" capable of eliminating, preventing or reducing potential hazards to an acceptable level as per your FSO.

Cheers
Charles Chew

Hello Charles C,
Yes gluten is there in all wheat flours but the level varies with different types of wheat like hard and soft wheat.
The flour is used in making bread, cake, biscuits which requires gluten in process.
For bread you need higher percentage of gluten to get the volume of bread. For biscuits you need low percentage of gluten.
Best regards
Sujit

Dear Sujit,

Thks for that info. So in this respect, I presume all wheat products are equally unsafe.
(After visiting wiki, i guess it is more accurate to say that wheat flour contains the proteins gliadin and glutenin which transform into gluten.)

Found this food table which seemed interesting.
gluten_free.png   32.78KB   51 downloads

Rgds / Charles.C

Dear Charles,

Yes, there are allergic reactions in some people.
Refined flour & its products has no nutrients value.
Best regards
Sujit

Dear Amir:

The CCP's in flour mill can be Destoner, Separator, Scourer and Magnet.
Some time back, a similiar query was answered in the forum.

Best regards
Sujit

Dear Amirhosein:

How about:-
- Deoxynivalenol (DON , Vomitoxin) that occurs in grains such as wheat, barley etc
- Zearalenone which does not seem to occur in significant amounts prior to harvest, but under proper environmental conditions, it is readily produced
- Heavy metals from the soil
- Pesticide residues, residue of fumigant (during fumigation of silo)
- Some pathogenic micro-organisms
- Physical hazards e.g. metal fragments, wood splinters etc.
- Presence of weevils etc.
- Allergen e.g. mixture of other grains e.g. corn etc. during shipping of wheat kernel.


Yong

Our HACCP system was evaluated by Nestle two weeks ago. I agree with Yong.

You should evaluate DON (PRP Supplier Control), Mycotoxin (Biological), Chemical contamination caused by residues of fumigant (DETIA), also Plansifter screens condition (physical) and final Metal detector (physical), if you are using any "gray area" chemicals like Potassium Bromate, check concentration too (many countries forbid it's use)



Regards

Excel