10 replies to this topic

[Madam A. D-tor]

Dear all,

A company who is producing fruit salads (cut fresh fruits without additives) determined the finished product temperature as CCP.
Legal and customer requirements are < 7 C.
The temperature of the product is monitored before loading (transport to customer). The company is only monitoring the temperature 3 times a day.
The company produces several different recipes and several differen package sizes. The traceability is per day (date code), meaning that a day production is considered as one batch. Therefore the company management say that one temperature monitoring is enough.
I now this is not a good justification. What will be a good frequency for monitoring finished product temperature as a CCP?

Actually, I think the CCP should not be the finished product temperature, but should be the cooling process (time/temp).

[cazyncymru]

Dear all,


Actually, I think the CCP should not be the finished product temperature, but should be the cooling process (time/temp).

i agree.

i cant think that there is a perceived food safety risk if fruit was despatched above temp, more likely to be food spoilage.

cooling time/ temp would be more logical as a ccp

just my thoughts

[Madam A. D-tor]

Are there any more suggestions on this forum about frequencies for finished product temperature checks?

[FSSM]

Would it be useful to redefine batch as each time interval of temperature check?

Maybe frecuency should be defined by the time that a fruit could start showing microbiological growth because it is stored out of the safe temperature range.

Regards,

FSSM

[Charles.C]

Dear Madame A.D-tor,

Lack of info.on process and type of packaging.

This is surely all about validation and verification.

The usual type of cooling process requirement in meat industry is to reach XdegC within Yhrs. I presume the X is 7 degC for some, hopefully validated, reason. Perhaps analogous to the 4degC > 8degC for refrigerators. There is a codex for the generalised fruit transport issue, cac/rcp 44/1995. Precooling recommended for quality reasons but no specifics given.

The appropriate number of samplings is surely related to the observed variation of target temperature and its typical absolute level. Data required, and perhaps also related to type of packaging. eg, best case scenario, if level is always 5+/- 0.5 degC, 1 sample is sufficient. If otherwise, statistics may enter in. Corrective action ?

Rgds / Charles.C

[Madam A. D-tor]

Hello FSSM and Charles,

Thanks for your comments.

Would it be useful to redefine batch as each time interval of temperature check?
FSSM

Yes, ofcourse. Actually I think (I know) that the manager's answer that the frequency is low because they see one day production as one batch is totally nonsense. I was quite astonished with her answer and couldn't even formulate a proper answer at the time.

Lack of info.on process and type of packaging.

Ok, I am sorry. I think it does not really matter for the case, but here is some more information:
The organisation receives whole fresh fruits (apples, melons, grapes, oranges, pineapples, berries). The fruit is washed (if necessarry), peeled, cut, mixed (if required) and packed in consumer cups (80 gr - 150 gr with spoon) and in 1 kg - 3 kg containers for restaurants/catering/bakeries/etc. Packagings are sealed. No MAP. The processes are mostly manual. Some small equipment is in place, like apple cutting machine, pineapple peeling machine and assembling and sealing line for cups.
The organisation is supplying to a global restaurant chain.
Pathogenic growth is IMO not really possible. The products have a shelf life of 7 days and the pH of the used fresh fruits is < 4,5.

The usual type of cooling process requirement in meat industry is to reach XdegC within Yhrs. I presume the X is 7 degC for some, hopefully validated, reason. Perhaps analogous to the 4degC > 8degC for refrigerators.
There is a codex for the generalised fruit transport issue, cac/rcp 44/1995. Precooling recommended for quality reasons but no specifics given.

I am familair with the cooling processes in meat industry and ready to eat (meals, meal salads, sandwiches, meat products, etc)
The codex is new to me, but is really interesting. Although it is ment for fresh fruits and vegetables, I can surely use this for other customers.

The appropriate number of samplings is surely related to the observed variation of target temperature and its typical absolute level. Data required, and perhaps also related to type of packaging. eg, best case scenario, if level is always 5+/- 0.5 degC, 1 sample is sufficient. If otherwise, statistics may enter in. Corrective action ?

Corrective action = do not load and inform quality supervisor and plant manager.
I like your statement about statistics and observed variation in relation to frequency. It seems quite logic to me and I am wondering why I have never thought like this. On the other hand, I have never seen applied these kind of information/statistics to establish frequencies for CCPs or CPs. E.g. A company which always have negative metal detector tests, can, according your statement, lower the frequency to weekly. I, as an auditor, the retailer, as customer and I hope the company itself will not accept this.
Well, thinking of it, it is used for setting frequency of glass inspections. These are mostly annual or quarterly. (accept when they are supplying to UK --> then the frequency of glass inspection is daily. ) I would say that the frequency for the metal detector checks AND the glass inspections are established based on hazard analyses/risk asessment.

This is surely all about validation and verification.

I absolutely agree! The discussion actually started with a question about CCP-validation. The company got a major on validation anyway. (a lot of things were not demonstrable validated)

[FSSM]

Corrective action = do not load and inform quality supervisor and plant manager.
I like your statement about statistics and observed variation in relation to frequency. It seems quite logic to me and I am wondering why I have never thought like this. On the other hand, I have never seen applied these kind of information/statistics to establish frequencies for CCPs or CPs. E.g. A company which always have negative metal detector tests, can, according your statement, lower the frequency to weekly. I, as an auditor, the retailer, as customer and I hope the company itself will not accept this.
Well, thinking of it, it is used for setting frequency of glass inspections. These are mostly annual or quarterly. (accept when they are supplying to UK --> then the frequency of glass inspection is daily. ) I would say that the frequency for the metal detector checks AND the glass inspections are established based on hazard analyses/risk asessment.

I think it would be statistically correct to reduce frecuency. Also, at least in ISO 22000 (I suppose other standars require it too), you should consider if your control measure has a low probability of failure. But how much product would you like to recall, reprocess, etc. if you find the critical limit has been exceeded?

Regards,

FSSM

[Charles.C]

Dear Madame A.D-tor,

Thks yr info. The MAP aspect was indeed part of my interest.

I did a little searching on this topic. It’s not my area so I’m not competent to evaluate the opinions but the situation is maybe not quite so simple as the “ph < 4.5” might indicate (especially for melons, apples maybe?). I enclose some comments from microorgs in foods vol6. Perhaps you know all this already.

 fruit_1.png   55.87KB   30 downloads
 fruit_2.png   58.95KB   28 downloads
 fruit_3.png   62.71KB   22 downloads

Slightly OT but a partially related generic haccp link (not sure about age) is –

http://www.angelfire...haccpmodel.html

My statistical comments were sort of inspired from this link –

http://www.thefreeli......-a0133515930

As you say, don’t see many examples of application of this approach. People don’t like the work I guess.

One usual problem of infrequent sampling is of course the magnitude of defective product in the event of failure of a CCP. It’s ok where you can re-run through a metal detector but for a temperature CCP, not quite so easy I think. (sorry FSSM, didn't see yr post )

Rgds / Charles.C

added - as an example of current (july 2009) US/FDA thinking about processing safe melons -

 microbilal_food_safety_melons.pdf   301.42KB   66 downloads

Perhaps this is a possible justification for a temperature CCP

(apologies in advance to Madame A.D-tor)

It seems strange to me that USA relies on GAP/GMP type mechanisms for vegetables / fruit rather than HACCP (some debatable similarities to the EC "process hygiene" thinking in a parallel thread

http://www.ifsqn.com...showtopic=13947 .

There is another thread on this forum (somewhere) which analyses the relative UK lack of microbial disasters for vegetables to the recent US experiences. This concludes that, due to existing practices, UK is on one (strict) end of a farm produce control "spectrum" as far as parameters like E.coli are concerned. I wonder what the FDA thinks of an acceptable target for E.coli of <100/g with a few samples allowed to be < 1000/g. Is there really no correlation to O157 ??

[Sorry Tony, I added this last bit before seeing yr next post. I also find the E.coli limits highly debatable, I simply hv a suspicion that the EC is being pragmatic. It would indeed be very interesting to see detailed examples / frequencies of some of the high-end data which are being accommodated by this guideline.]

[Tony-C]

Dear Madame A.D-tor,

added - as an example of current (july 2009) US/FDA thinking about processing safe melons -

 microbilal_food_safety_melons.pdf   301.42KB   66 downloads

Perhaps this is a possible justification for a temperature CCP

It seems strange that USA relies on GAP/GMP type mechanisms for vegetables / fruit rather than HACCP

Another useful link - Thanks Charles

Human pathogens may proliferate rapidly on fresh-cut melon products held under temperature abuse conditions

I know I rattle on about this but another case for my thoughts on E.coli levels

So CCP for cooling and storage. Sampling rates seem to be a grey area. I would use maximum of hourly as a batch. Others might consider a days production as a batch. I always consider this - What is the maximum amount of product you would routinely want to quarantine when you have an out of spec. result?

Madam A. D-tor - Are these your customers you are referring to?

Kind regards,

Tony

[Madam A. D-tor]

Hello all,

I always consider this - What is the maximum amount of product you would routinely want to quarantine when you have an out of spec. result?

This is also my approach.

Madam A. D-tor - Are these your customers you are referring to?

Yes this is a real case study, based on one of my customers.

I enclose some comments from microorgs in foods vol6. Perhaps you know all this already.
Slightly OT but a partially related generic haccp link (not sure about age)
added - as an example of current (july 2009) US/FDA thinking about processing safe melons -

Charles, Thanks for all the great resources. Juice production is indeed off topic, but I find it very usefull anyway. This week I was with a company, which were also doing some fresh juice production.
The melon guidelines are great. I did not know there was so much handling in the total melon-chain. I wonder about the decontamination steps. These are not allowed here, but since melons are always imported, I wonder if these steps are done at the country of origin.

It seems strange to me that USA relies on GAP/GMP type mechanisms for vegetables / fruit rather than HACCP
(some debatable similarities to the EC "process hygiene" thinking in a parallel thread
http://www.ifsqn.com...showtopic=13947 .

I think it is not strange. vegetables/fruit growing is primary process. GAP/GMP is the beginning. Also the guidelines can have a HACCP-apporach as a basic.

I will start reading the mentioned thread. I know that there are some big attachements in.

There is another thread on this forum (somewhere) which analyses the relative UK lack of microbial disasters for vegetables to the recent US experiences. This concludes that, due to existing practices, UK is on one (strict) end of a farm produce control "spectrum" as far as parameters like E.coli are concerned. I wonder what the FDA thinks of an acceptable target for E.coli of <100/g with a few samples allowed to be < 1000/g. Is there really no correlation to O157 ??

I think this thread is the same as the one you mentioned before. I found there data regarding organic cut produce in UK. I searched for Dutch data. I have attached some. They are unfortunately not available in English. The data is from 2007. 1932 samples fresh cut RTE vegetables(factory and retailer) were analysed for Campylobacter spp., L. monocytogenes, Samonella spp. en E. coli O157. In only one sample a pathogen was found. This was Salmonella. Also 697 samples of RTE cut fruit products (salads and pineapples pieces) were sampled. 8 samples were positive for pathogens (1,3%) The pathogens found were: Salmonella S. Aureus and E.Coli. Only 0,1% off the samples were out of limits.
Conclusion: also in the Netherlands not much pathogens in RTE cut fresh vegetables. It would be nice to have some USA figures.
This week I was auditing at another vegetable cutting plant and the QA manager and I were discussing about shelf lifes. He told me something, which we maybe must consider in this thread. Packaging (and shelf lifes) of cut fresh produce is really different in USA then in Western Europe. In the Netherlands (also Belgium, France, Germany and I Think also UK) fresh cut produce is packed in bags of crispy foil , sometimes with MAP, sometimes not. The shelf life is very short. Up to 7-8 days. I was told that the RTE fresh cut produce in USA are packed in a stronger foil under a pseudo-vacuum, with a shelf life of 12-13 days. Shelflife is here based on spoilage. Produces are spoiled before pathogens start to grown to relevant numbers. Leavy salats get week and wet and start to smell. Even if temperature is abused, spoilage will occur before pathogenic growth.

For E. Coli I have learned in school that sickness occurs > 10^6 CFU. This does not refers to E. Coli 0157. I actually can not find back if there was a differentation between the different E.Coli types.

[zein1]

Frequency of temperature measurement depends on some factors - frequency of door opening, and environmetal temperature. In case both are under control - I can assume three times per shift (8 hrs) woul be enough. Otherwise, that woul ddemand increase in frequency.