10 replies to this topic

[Alex]

I'm just beginning to implement an SQF system into a candy distribution center and thus I'm trying to create a HACCP plan. In my plant we recieve candy from suppliers in bulk, repackage it, and distribute it. When I am documenting my finished product specs I am including packaging info, strorage, distribution, shelf life, and allergy info. However, I also keep hearing from various sources that microbiological and chemical information (i.e. acidic level) should be included. It would require a lot of work for us to access this information from suppliers. The suppliers we buy from all have some form of accredidation in food safety from various third party auditing bodies. I am going to also include a section in the SQF and HACCP plan on supplier approval protocol.

My quesiton is if we do not create any product in house and simply store and package it, do I need to include microbiological and chemical information for the product or does our suppliers accredidation and our supplier aproval protocol as well as our strorage, tracking and cleaning practices serve as good enough prerequisits to eliminate the need for us to have on record such information?

[Charles.C]

Dear Alex,

In my plant we recieve candy from suppliers in bulk, repackage it, and distribute it.

Hv no direct experience with SQF or repacking-only procedures but i can offer an opinion based solely on manufacturing experience.

You don't describe the process in detail but if I understand correctly, the above requires you to open bulk packaging thereby "exposing" the contents to the environment, transfer the contents into a hopper (?) or manual system and then carry out a repacking / subpacking.

If so, IMO, from a QA / HACCP point of view there is an obvious potential for BCP contamination. How much depends on quantities / how you are doing it / where you are doing it/ etc. Similarly for micro.growth although I expect yr product is of low susceptibility to this hazard.

If the above is the actual situation I am frankly rather amazed that -

(a) you do not require a micro.spec from yr suppliers.
(b) yr customers do not require the same from you.

A HACCP analysis (required by SQF ??)would surely also demand BCP specifications.??
Other people here may hv some experience with SQF in such situations so can offer a direct answer ?

Rgds / Charles.C

BTW, Welcome to the forum !

[Alex]

Thanks for your help and I definately see what your saying. The reason I'm a little uncertain about it is that we buy all of our food from companies with certified safety plans in place and we have a supplier aproval plan in place. Therefore, it is reasonable to expect the food coming into us to pay safe from any contaminants. We have necessary pre-requisits in place to control contaminants upon the candy being placed on the machine (such as proper cleaning, maintanence, allergen control, and GMP's) as well as a tracability protocol if there were to be a problem with the candy. HACCP deals with risks that are both dangerous and realistic. Therefore, I do not believe there is a realistic risk of a previously clean piece of candy picking up biological contaminants simply by being placed on a certifiably clean piece of equpment (as long as the machinery is indeed clean).

That is my biggest hold up right now, both SQF and HACCP seem to be more written for food manufacturing plants and I'm having trouble diferentiating what risks are reasonable to expect at a distribution center of such a low risk food as candy. Any additional advice with anyone who has experience with low risk foods particuarly at the distribution level would be much apreciated.

[Cathy]

I think you might be trying too hard. Your process has minimal risk - we can surmise this but you must document it. Yes - you need to address all 3 types of hazards in your hazard analysis and determine if they are likely to occur. Most likley the key factor for you is a very low water activity for all products - this prevents baterial growth. HACCP requires you to fully describe and evaluate the finishd product and the ingredients and the steps. The level of detail - should be commensurate to risk and include both science and common sense.

For example - each ingredient - the candy - can be described in terms of low water activity, ready to eat, not likely to contain B,C or P hazards due to other information you have provided for us. Document this...then for each step evaluate if there are any new risks...from exposure to the (clean)environment or the (metal) equipment.

I have worked with companies that repack (candy, frozen desserts, and vegetables) and it is not uncommon to have zero CCPs.

[Charles.C]

Dear Alex,

Thks yr info, it’s an interesting scenario. Normally a complete flow chart is required to avoid asking non-relevant questions however can add few more thoughts.

I daresay Cathy won't agree with some of the next comments but it's all good learning experience (for me).

I know nothing about the candy industry so after my previous post I realised I should have asked if the items in the bulk packaging are already individually wrapped ? I presume not. If not, do you individually ( manually / automatically?) wrap them ? The contamination aspect is obviously related plus the degree of handling involved.

I have never encountered a food supplier approval program which did not involve (agreed) microbiological specifications. ! I hv to predict that SQF will find this very unusual.

Another favorite, potential HACCP / CCP where machines are involved (especially for auditors) is metal contamination ?

If you look around this forum a little you will see another very recent thread regarding SQF expectations for another processor. The posters main query concerned clarification of the SQF requirements regarding scope of “specifications” and the outcome of the thread suggested that considerable confusion exists apparently due to ambiguous wording in the standard. I am wondering in the present case if your product specifications are automatically included or not ?

I predict that in present case, SQF will require at least 2 responses from yourself –

(a) evidence that yr FS program complies to any appropriate Federal / local regulatory requirement
(b) further evidence that it complies to the SQF standard regarding any additional clauses

I daresay that SQF will place substantial interest in (a) which I assume you have long ago ensured compliance with. Does (a) in fact exist ?? (It may be that repackers in USA somewhat fall into a legislatory “black hole”.)

[I’m not in USA and I know every country (state) may be different, eg I noticed that in Texas you would be specifically defined as a Food Manufacturer ( http://www.dshs.stat...foodmangen.shtm ), whatever that subsequently demands.

And in Mississippi you might very possibly not need a HACCP plan by definition ( http://msdh.ms.gov/m...ources/1767.pdf , pgs 7,8 but depending on Federal law and perhaps on the local interpretation of “minimal food preparation” in category 2)]

Generally I deduce yr product is classified as a non-potentially hazardous food (eg as per http://cpa.utk.edu/pdffiles/cpa138.pdf )

However the end - product is classified as Ready-to-eat and perhaps (?) targetted for a (considered) vulnerable customer range (eg children). IMEX, from a HACCP viewpoint, this may often result in the area responsible for any “handling” process being classified as “High Care” (aka, sometimes, High Risk). IMO, and I would hv thought also of SQF, this strongly relates to the risk analysis aspect and pre-requisites etc. Not necessarily disagreeing yr own conclusions, just speculating.

Repeating myself slightly, I find it difficult to understand how you validate / verify yr product is “food safe” (for both input/output situations) without getting involved in micro.specifications. And the same comment for pre-requisites (I presume this checking is currently carried out ?).

(Based on recent threads, I am beginning to have a few qualms about the depth of the SQF standard as compared to, say, BRC )

Rgds / Charles.C

[tsmith7858]

Alex,

Interesting topic and one that hits close to home for me. We do both manufacturing and distribution of candy and snacks so I can relate to some of what you are saying but since we package both manufactured and purchased bulk candies on the same machines, our risks are different. We are registered to ISO 22000 and just completed FSSC 22000 but neither require product specs. I am unfamiliar with SQF requirements so I cannot speak to it.

Going back to Charles' responses, I would also question whether you are packaging wrapped or unwrapped candies (we do both at our facility). If it is all wrapped, I would agree that your risks are minimal to non existent and micro would be unnecessary. If it is not wrapped than it would depend on your products. Anything unwrapped with chocolate or nuts (particularly peanut butter) would present a higher risk (check this site for the "Salmonella in Low Moisture Foods" guidance from GMA).

We do not provide any product specification for our distributed products and if asked we would give what comes from our supplier. We get COA's on any product that is "sensitive" but we also distribute some that would present no real risks.

The most difficult thing that we have encountered on distributed items (not only what we repack but also that we sell "off the shelf") is keeping track of all ingredients for re-calls. As mentioned along with candies we also sell snacks and over the last year we have had to review products for various recalls including peanut/peanut butter, pistachios, spices (like pepper) and even Hydrolyzed Vegetable Protein (HVP).

We did not have any of it but if we did have something from those recalls and it was unwrapped product that was packaged from bulk, we would have been at risk. We do have all the proper procedures in place but we would have needed to review them and verify they were working.

Not sure that any of this helps you but I will leave you with one final thing (slightly off topic). All of the companies that have had recent recalls have had "food safety" systems in place. Most were even recently audited by third parties and even government auditors. Stating that you have "approved suppliers" does not mean you are free of risk. You may want to include some random micro checks of your own just to have that comfort level. In the end it is your choice but the auditors we have had recently have all suggested it.

[Alex]

Thank you all for your advice.

To answer the question that you all had for me, some of our candy is wrapped while other ones are not.


I just finished doing my final product specs using a form suggested to me in the sqf training courseit took. It includes information on proper storage temperature control, packaging, standard size and shape, and allergen info. I may end up adding in some information on microbial and chemical properties later, the major drawback is once again getting this information from the companies that manufacture the candy. I am still thinking it over and sifting through our records to see if we have any relevant info on the subject.

Once again thank you all for your advice.

[Charles.C]

Dear Tsmith,

We are registered to ISO 22000 and just completed FSSC 22000 but neither require product specs.

I just couldn't resist following this up

Seemed to me that this kind of information (at least where relevant to food safety) is required by, for example, 7.331 or 7.332 or 7.42 in the context of hazard analysis / acceptable levels ??

By way of illustration only, these 2 items are 2nd and 3rd prerequisites in the FDA's reproduction of the original NACMCF, HACCP Presentation (1997). ( have to admit that they don't appear to occur in the Codex HACCP )

Supplier Control.
Each facility should assure that its suppliers have in place effective GMP and food safety programs. These may be the subject of continuing supplier guarantee and supplier HACCP system verification.


Specifications.
There should be written specifications for all ingredients, products, and packaging materials.

Rgds / Charles.C

[tsmith7858]

Dear Tsmith,



I just couldn't resist following this up

Seemed to me that this kind of information (at least where relevant to food safety) is required by, for example, 7.331 or 7.332 or 7.42 in the context of hazard analysis / acceptable levels ??

By way of illustration only, these 2 items are 2nd and 3rd prerequisites in the FDA's reproduction of the original NACMCF, HACCP Presentation (1997). ( have to admit that they don't appear to occur in the Codex HACCP )



Rgds / Charles.C

I think that leads to another topic and conversation:

Is there a difference between Product Characteristic/Description and Finished Product Specifications?

My definitions:

Product Characteristic/Description - General product information for a product or group of products describing the intended use, general storage and potential hazards related to the product or group.
Example: Product characterized as having low water activity
Finished Product Specification - Detailed information for a specific product that gives full characteristics and expections of the product
Example: Product has a Water Activity level of .86 - .90

I consider 7.3.3.1 and 7.3.3.2 to be part of Product Characteristics/Descriptions and have it in my HACCP plans but I would require a supplier to give me a Finished Product Specification to be covered in 7.4.2 (due diligence for each ingredient) to ensure I knew what I was processing.

As a distributor I would not create my own finished product specifications. I would pass on the finished product specifications that were provided to me by the supplier. I may have a general specification that describes my processes. It would state my obligations for packaging, labeling and distribution but not include any characteristics of the candy (micro, chemical, etc) but it would be my responsibility to ensure that none of the charateristic are adulterated by my process.

I attached my "Product Description" page for my distribution HACCP Plans (minus some details).

Just my opinion, I certainly welcome views of others.

Attached Files

•  Product Description.pdf   40.51KB   167 downloads

[Cathy]

I have seen a similar form accepted many places. The product description focuses on essential food safety characterisitics and the finished product specification typically has a lot more detail including dimensions, weight etc.

Raw material specifications could be important to HACCP when doing an ingredient hazard analysis - but again - it's important to focus on kep food safety characteristics.

[Charles.C]

Dear All,

Sorry Alex, I forgot to add the “OT” label when I deviated to ISO 22000. I hope you don’t mind the extra information. At least it gives a perspective to SQF .

I guess it’s important to remember that all this thread (so far anyway) is focused on food safety systems and related standards (and their content).

Personally, I would not solely classify Alex as a distributor as per my original example but it’s obviously important if SQF does otherwise and specifically limits their expectations accordingly. I hope Alex knows this already but it appears that the standard is “blurred”.

@ Tsmith. Many thks yr attachment and yr detailed contributions. Seems you do not regard packaging operations as a production process, I guess it’s a matter of opinion. I also presume that where reception of wrapped product is involved you have no microbiological CCPs and hence no HACCP plan ?

I noted yr earlier comment referring to non-usage of product specifications –

We did not have any of it but if we did have something from those recalls and it was unwrapped product that was packaged from bulk, we would have been at risk. We do have all the proper procedures in place but we would have needed to review them and verify they were working.

I’m surprised that you take the risk.

Is there a difference between Product Characteristic/Description and Finished Product Specifications?

A lot of it is just semantics of course, tailored for the specific application.

However, in the FS sense, in the segments I previously referred, ISO 22000 states for example that “all raw materials, ingredients, end products and product-contact material shall be described in documents to the extent needed to conduct the hazard analysis (7.4) including …….” Seems to me that this defines their interpretation of the captioned “Product Characteristics” . I certainly agree that items like tsmith’s attachment exist and I hv even seen them described as “Product Specifications” and be accepted as such (the ‘buyer beware” syndrome). But am rather surprised if ok in an auditable sense for a food safety standard. However I am always prepared to be astounded .
IMEX most manufacturers issue what they call “Product Specifications” which are intentionally designed to give BCP details only to the extent that some (perceived / calculated) basic requirements are fulfilled, eg the ubiquitous “Salmonella not detected in 25g”, and I can appreciate that the general trade may be very happy to see alternatives like “Salmonella free” or even the intriguing “free of pathogens” (particularly as some official standards are no different !). A rose by any other name.

@Cathy - Raw material specifications could be important to HACCP when doing an ingredient hazard analysis - but again - it's important to focus on kep food safety characteristics.

I don’t’t believe you can have a meaningful material specification which does not include safety characteristics unless it categorically excludes such. This is regardless of HACCP aspects, in the latter case, the importance simply becomes “critical” IMO.

Rgds / Charles.C