30 replies to this topic

[Jomy Abraham]

Customer contractual requirement

No of meals: 10000
Type: Hot Lunch
Service duration and time: 9.00 am to 4.00 pm ( 7 hrs)

In this case, cooked products will be ready at 6.00 am and meal packing will be at 6.30 am to 8.00 am and transportation of food will be in between 8.00 am to 8.45 am

Concerns
1. What temperature we need to pack the food ( if its packed above 60 Deg C, condensation occurs and product can be spoiled)
2. If we reduce the temperature, we cannot consider the customer demand of hot food
3. TO safe guard the product for 10 hours what should be our precautions.

As per the trials and validation studies, packing at 60 Deg C and cooling to 30 Deg C in 1 hour supports the requirement of 10 hour shelf life ( its not a hot food and its not a cold food)

Is this process valid?If yes, how can we define a HACCP Plan or OPRP plan for this process.?
Will it be accpeted by a third party Auditor? Can I use my validation study report?

Regards
Jomy Abraham

[Jomy Abraham]

Do you recommend this process as a food safety expert?

Customer contractual requirement

No of meals: 10000
Type: Hot Lunch
Service duration and time: 9.00 am to 4.00 pm ( 7 hrs)

In this case, cooked products will be ready at 6.00 am and meal packing will be at 6.30 am to 8.00 am and transportation of food will be in between 8.00 am to 8.45 am

Concerns
1. What temperature we need to pack the food ( if its packed above 60 Deg C, condensation occurs and product can be spoiled)
2. If we reduce the temperature, we cannot consider the customer demand of hot food
3. TO safe guard the product for 10 hours what should be our precautions.

As per the trials and validation studies, packing at 60 Deg C and cooling to 30 Deg C in 1 hour supports the requirement of 10 hour shelf life ( its not a hot food and its not a cold food)

Is this process valid?If yes, how can we define a HACCP Plan or OPRP plan for this process.?
Will it be accpeted by a third party Auditor? Can I use my validation study report?

Regards
Jomy Abraham

[Ken]

Jomy

You have a difficult task and one which I am familiar with as I have been involved in remote site catering in quite a few countries around the world including India. If you refer to the World Health Organisation document - '5 keys to food safety' (http://www.who.int/f...s/en/index.html) The guidelines are quite clear, store above 60C or below 5 C. and do not keep the food at room temperature for more than 2 hours

I am surprised that trials and validation studies, packing at 60 Deg C and cooling to 30 Deg C in 1 hour supports the requirement of 10 hour shelf life ( its not a hot food and its not a cold food) - what criteria did you use for this?

To answer your question, 'Is this process valid?' then my answer would be 'No'. as you are creating exactly the right conditions for a potential food poisoning outbreak, particularly for those who will be eating the food at the afternoon. Obviously the right organisms have to be there, particularly spore formers but if they are present, and you then hold the meals at 30C for up to 10 hours then in time you will, in my opinion produce a food poisoning outbreak. You may have some validation but if I were an auditor then my food safety expertise would have to say that whilst you might have a report to validate the process, my experience would tell me that the process is not safe.

You can mitigate this to some extent by ensuring there are no meat dishes or rice in the meals. If you wanted to know what the temperature profile is now from production of the meal to consumption, then I have used simple and inexpensive data loggers which log the temperature every 5 minutes - they have to be returned to you but at least you can see how efficient any hot holding equipment is.

If you are transporting to a canteen where everyone will go to eat, then the only options are to pack hot, transport hot and then hot hold before serving or blast chill, transport and store chilled then re-heat before serving.

If each meal is going into a tiffin and then taken out by each individual person, then it is more difficult to control but you can assess how good the insulation on the tiffin is by using dataloggers as described before - if you can prove that the hot temperature is being maintained then that would be part of your validation. I would still pack as hot as possible say 90C or above.

Hope this helps

Ken

[Jomy Abraham]

Dear Ken

I am just trying to support an organization who really require it. Its really unsafe to provide the food at 30 Deg C.

1. In this case, Packing at 90 Deg C in a disposable aluminum or PE bowls is more unsafe than sending the product at 30 deg C
Reason: Packing at high temperaute results in condensation and hence we can see moisture droplets at the bottom surface of the lids. High temperature packing may not be an issue, if we restrict the service duration to 4 hours. But the product will be spoiled immediately after or whithin 4 hours. Hence packing at above 65 Deg C is difficult due to long service durations.

2. Since 6 month, they are serving the product at + 30 Deg C and the time gap between cooking end time and serving end time is 10 hours ( extra precaution is taken to chill the product from cooking temperatue ( 80- 90 Deg C) to 25-30 Deg C in 1 hour). As the the product is still in danger zone temperature, the consumer immunity may be a supporting factor. TPC, coliform, Ecoli, salmonella are found negative/within the limits after 10 hours( validation study report)

( they are serving it to the most prestigious/ sophisticated army camp in the world)

the main challenge is to incorporate this requirement into the ISO 22000 FSMS. Finding it difficult to prepare the OPRP plan, critical limits, Validation reports etc. Please help us with some supporting documents/suggestions...........

Regards
Jomy Abraham

Jomy

You have a difficult task and one which I am familiar with as I have been involved in remote site catering in quite a few countries around the world including India. If you refer to the World Health Organisation document - '5 keys to food safety' (http://www.who.int/f...s/en/index.html) The guidelines are quite clear, store above 60C or below 5 C. and do not keep the food at room temperature for more than 2 hours

I am surprised that trials and validation studies, packing at 60 Deg C and cooling to 30 Deg C in 1 hour supports the requirement of 10 hour shelf life ( its not a hot food and its not a cold food) - what criteria did you use for this?

To answer your question, 'Is this process valid?' then my answer would be 'No'. as you are creating exactly the right conditions for a potential food poisoning outbreak, particularly for those who will be eating the food at the afternoon. Obviously the right organisms have to be there, particularly spore formers but if they are present, and you then hold the meals at 30C for up to 10 hours then in time you will, in my opinion produce a food poisoning outbreak. You may have some validation but if I were an auditor then my food safety expertise would have to say that whilst you might have a report to validate the process, my experience would tell me that the process is not safe.

You can mitigate this to some extent by ensuring there are no meat dishes or rice in the meals. If you wanted to know what the temperature profile is now from production of the meal to consumption, then I have used simple and inexpensive data loggers which log the temperature every 5 minutes - they have to be returned to you but at least you can see how efficient any hot holding equipment is.

If you are transporting to a canteen where everyone will go to eat, then the only options are to pack hot, transport hot and then hot hold before serving or blast chill, transport and store chilled then re-heat before serving.

If each meal is going into a tiffin and then taken out by each individual person, then it is more difficult to control but you can assess how good the insulation on the tiffin is by using dataloggers as described before - if you can prove that the hot temperature is being maintained then that would be part of your validation. I would still pack as hot as possible say 90C or above.

Hope this helps

Ken

[Madam A. D-tor]

Dear Jomy Abraham,

Can you please tell to what temperature the food is heated before packing? To me it also seems strange that after 10 hours at 30 degrees micro is still within the limits. On the other hand, you did not test spore formers or heat resistent pathogens.

If you pack the products at 90 °C, you indeed get condense at the lid of the packing. On the other hand, the air temperature above the product might be > 85 °C and pasteurise the lid. You should validate this, it is only a theory.

I am very curious for your validation plan. Can you inform us, how you validated your process?
You ask for advice in establishing OPRP/CCP limits. By validating you proof that your process settings and limits are capable of producing safe food. So, you should already have these limits. Do you have monitoring plans?

[Charles.C]

Dear Jomy Abraham,

It's an interesting thread.

I'm not familiar with Quantity Remote Catering but one obvious comment is similar to Ken's that the basic concept / practice being applied here appears substantially not in conformance to standard theory for ensuring safe (cooked) food.

And I presume also opposite to usual practice in India. ? Correct ?

If so, this would imply that the validation study you refer to is going to require some very careful examination.

Rgds / Charles.C

PS Just for general information, here is the document linked via Ken's first post '

 5 keys to safer food manual - manual_keys.pdf   3.84MB   109 downloads

[Jomy Abraham]

Dear Charles.

Its not in India. Its in a middle east country and the project is for the ....... Army Camps ( not for any middle east Army)

regards
Jomy

Dear Jomy Abraham,

It's an interesting thread.

I'm not familiar with Quantity Remote Catering but one obvious comment is similar to Ken's that the basic concept / practice being applied here appears substantially not in conformance to standard theory for ensuring safe (cooked) food.

And I presume also opposite to usual practice in India. ? Correct ?

If so, this would imply that the validation study you refer to is going to require some very careful examination.

Rgds / Charles.C

PS Just for general information, here is the document linked via Ken's first post '

 5 keys to safer food manual - manual_keys.pdf   3.84MB   109 downloads

[Jomy Abraham]

Dear Madam A D-tor

1. Product is cooked to a temperature fo 80 to 90 Dg C. Critical limit is 75 Deg c for 2 minute
2. Most of the cases, the temperature reached 90 Deg C
3. Transfer the cooked product immediately to a room maintained at -18 Deg C ( freezer- not a blast freezer)
4. due to the heat heat transfers, freezer room temperature increases to - 5 Deg C to +5 Deg C gradually.
5. when the product temperature reached 65 Deg C ( In 15 to 20 minute), portioning the meal starts...
6. Packing in Al contianer ( for rices) and PE bowls ( for any other side dishes) at 65 Deg C. This prevents condensation...
7. Keep the packed food inside the same room
8. In one hour, the product temperature crosses 30 Deg C.
9. Once it reached +30 Deg C, transfer the food to a food vehicle ( refrigeration unit starts and maintained + 5 Deg C at the time of loading, Once loading finished, switch off the refrigeration of vehicle.
10. 1 hour transportation
11. Distribution ends in 2 hours
12. Consumption of food ends in 4 hours
13. Total life of food after cookign is 10 hours (max)


Random Spoilage reported when the product is packed directly at 70 to 80 Deg C.

It was a tough challenge to rectify the spoilages and replace the process with a non hot non cold food.................But technically I am finding difficulties to proivde the reference standards, except the analysis report of TPC below 10,000 cfu/gm Most wonder is I recieved special congratulations from their organization to rectify thier long run issues which leads to zero spoilages............. . .But I need to support their FSMS now.

As a food safety expert, only option is to recommend the +30 food to blast chilled food and provide micro wave oven at consumer points!!!


REGARDS
Jomy Abraham

Dear Jomy Abraham,

Can you please tell to what temperature the food is heated before packing? To me it also seems strange that after 10 hours at 30 degrees micro is still within the limits. On the other hand, you did not test spore formers or heat resistent pathogens.

If you pack the products at 90 °C, you indeed get condense at the lid of the packing. On the other hand, the air temperature above the product might be > 85 °C and pasteurise the lid. You should validate this, it is only a theory.

I am very curious for your validation plan. Can you inform us, how you validated your process?
You ask for advice in establishing OPRP/CCP limits. By validating you proof that your process settings and limits are capable of producing safe food. So, you should already have these limits. Do you have monitoring plans?

[Ken]

Jomy

I would also have thought that packing at 90C would effective pasteurise the container lid and therefore spoilage would not be an issue. The comment has already been made but your organisms of concern are not the ones of your previous validation study - it is the spore formers such as Clostridium perfringens for any meat / veg dishes and Bacillus cereus for the rice. If you have not checked for this, then this should be next logical test - ensure you check samples of the food at point of production and after 10 hours 'in the field'. (Also check the temperature after 10 hours but preferably use a temperature data logger as described in my last message - the final temperature will be dependent on the type of storage containers used and the external temperature)

The conditions you operate under, are text book conditions for food poisoning outbreak for either of these organism. I have first hand experience of this type of operation in remote site catering in places like the middle east, India & Pakistan. (In industry but essentially the same thing as you describe) I was initially surprised by how few hours is needed at the wrong temperature for an incident to occur.

Remember that a food poisoning incident is as a result of a sequence of events i.e the spore formers have to be present in the original food before cooking and IF they are present and IF the temperature is right for germination, growth and toxin production and IF there is sufficient time then an incident can occur.

Given that part of a Haccp risk assessment is about the predicting significance of a hazard by evaluating the likelihood and severity of a particular hazard then you would have to would have to conclude that there is no control in place and the only option is to change the process to ensure there is a control in place.

in your case, the hazard is food poisoning from spore formers due to transport and storage at say 30C. I would conclude that the likelihood of this event occurring is high (i.e very likely to occur) and the severity would be high (food poisoning) so the hazard is significant. If you then use a codex decision tree, the first question would be "Are control measure in place for this hazard' and the answer would be 'No'. Next question would be "Is control necessary' and my answer would be 'Yes' - the guidance is to then 'modify the step, process or product to obtain control'.

You are right in that time is a critical factor and can be a control so the shorter the period then the safer a product will be at point of eating. I initially had the impression that food was consumed 10 hours after cooking and if that is the case, in my opinion it would be impossible to validate this under the process conditions you have described but might be validated under different time / temperature conditions.

To conclude, check the temperature profile and complete some micro testing for spore formers and take it from there.

Ken

[Jomy Abraham]

Dear Charles/Ken

Is there any loop hole to link the customer requirement to ISO 22000? Here there is no reference std. Only we have some validation studies and zero spoilage complaints since 6 month? Spores can be a risk factor..If there is any loop hole, please advice to tackle the FSMS...

Rgds
Jomy Abraham

Dear Jomy Abraham,

It's an interesting thread.

I'm not familiar with Quantity Remote Catering but one obvious comment is similar to Ken's that the basic concept / practice being applied here appears substantially not in conformance to standard theory for ensuring safe (cooked) food.

And I presume also opposite to usual practice in India. ? Correct ?

If so, this would imply that the validation study you refer to is going to require some very careful examination.

Rgds / Charles.C

PS Just for general information, here is the document linked via Ken's first post '

 5 keys to safer food manual - manual_keys.pdf   3.84MB   109 downloads

[Ken]

Tomy

There is no loop hole - you need to read my last message for guidance on what to do next.

First priority is food safety and that in my opinion, overrides any specific customer requirement.

Your reference standard can be the '5 keys to food safety' given by Charles.

Ken

[Jomy Abraham]

Dear Ken

The organization has a good FSMS system

CCP s are cooking, baking, frying
OPRPs are chiller temp, freezer temp, thawing, hot holding ( 65 Deg c), cold holding ( +4 Deg c max), Blast chilling, Vehicle temp for cooked chilled prodcut ( +4 Deg C max)

6 month ago, they have started hot meal boxes due to operational constraints. Packing at above 65 Deg C lead to spoilages.

So the only option is to blast chill the product and provide micro wave ovens at consumer points.

Its not going to happen in next 2 month as the process is going on smoothly without any spoilages.....( they need to source atleast 2000 micro wave ovens in thier dessert offices). yes ofcourse- FSMS is expensive..let them purchase it to renew ISO 22000:2005

Regards
Jomy Abraham

Tomy

There is no loop hole - you need to read my last message for guidance on what to do next.

First priority is food safety and that in my opinion, overrides any specific customer requirement.

Your reference standard can be the '5 keys to food safety' given by Charles.

Ken

[Ken]

Jomy

A difficult one for you but it is a situation I have seen before where hot boxes were used and it was fine for a while, everything then went wrong and the question 'why didn't someone tell me I was doing this wrong' came up. Reply was that you didn't ask or let us know you planned to do things differently!
.
A food safety chain is only as good as it weakest link and storage temperature during distribution is the weak point. You need to get more information so you have solid evidence, hence the advice in previous e-mails.

It will be interesting to see how this develops.

Take care

Ken

[Charles.C]

Dear Jomy Abraham,

I think Ken has more or less said it all. In addition, I suggest to look into the history / theory / validation behind the existing recommended practices, eg temperature / control periods. IMEX it’s easier to be convinced if one sees the logic and relationship to previous incidents.

There is some variation between “experts” regarding actual time periods considered unsafe (eg see the 2006 document below, "factors to consider") but yr present problem is particularly that you hv no data to evaluate the potential (probable?) process risks plus a procedure which is clearly not within the usual safety norms. It is also possible that incident related data may well exist for the current scenario. Looks like some self-protection measures are urgently recommended.

I suppose this illustrates the ISO 22000 requirement that validation should be done before implementation. Hindsight is always so easy. Good luck.

 FS time-temperature abuse.pdf   124.33KB   73 downloads

Rgds / Charles.C

[Jomy Abraham]

Thx Ken and Charles for your valuable inputs...
I will update you about the progress in this regard....Let us see

Regards
Jomy Abraham

Dear Jomy Abraham,

I think Ken has more or less said it all. In addition, I suggest to look into the history / theory / validation behind the existing recommended practices, eg temperature / control periods. IMEX it’s easier to be convinced if one sees the logic and relationship to previous incidents.

There is some variation between “experts” regarding actual time periods considered unsafe (eg see the 2006 document below, "factors to consider") but yr present problem is particularly that you hv no data to evaluate the potential (probable?) process risks plus a procedure which is clearly not within the usual safety norms. It is also possible that incident related data may well exist for the current scenario. Looks like some self-protection measures are urgently recommended.

I suppose this illustrates the ISO 22000 requirement that validation should be done before implementation. Hindsight is always so easy. Good luck.

 FS time-temperature abuse.pdf   124.33KB   73 downloads

Rgds / Charles.C

[GMO]

Oh this is b. cereus vomiting outbreak waiting to happen. Having had b. cereus food poisoning, it's not pleasant.

I'm wondering why they want the food at 30 degrees? That's not going to taste "warm" so presumably this is food which can be eaten cold? So why not cool it down fully and transport in cool boxes and eat cold?

Personally I'd be wondering what they're waiting for. A huge outbreak? A death? You may think I'm overstating it but a relative of mine is a consultant and had a b. cereus death once, a fit, healthy woman in her 20s who ended up with problems with her liver as a result of the b. cereus toxin. Apart from the moral argument, there's a practicality one of having that many people ill presumably away from decent toilet facilities... I would think food safety would be trained into most recruits as it can as easily incapacitate an army just as much as injury from gunfire. Not good practice from the guys in charge and shows a lack of respect for their troops IMO.

[Jomy Abraham]

GMO

U said it excatly. I dont want to point out the nation, contractual requirements etc...The datas might be manipulated to define the criterias.

Being a technical consultant, I have highlighted all the risk that Ken and GMO has highlighted. but there are two middle organization between the customer and Food processor. So the food processor is not able to reach the consumer directly....

Army- contract to another org ( subcontract)- this org is given manpower contract to another org( subcontractor of the subcontractor)- this org has given the catering contract to a Multi national Caterign org ....So the middle org's has no idea about food safety. They just depends on cost. But the catering Co is ISO 22000 certified and they need to incorporate the New Proceesing unit into the certification process......

I have recomended blast chilling process to replace it. Still the middle org is not yet considering the Catering Co's request due to additional investments ( may be)

Reg
Jomy Abraham

Oh this is b. cereus vomiting outbreak waiting to happen. Having had b. cereus food poisoning, it's not pleasant.

I'm wondering why they want the food at 30 degrees? That's not going to taste "warm" so presumably this is food which can be eaten cold? So why not cool it down fully and transport in cool boxes and eat cold?

Personally I'd be wondering what they're waiting for. A huge outbreak? A death? You may think I'm overstating it but a relative of mine is a consultant and had a b. cereus death once, a fit, healthy woman in her 20s who ended up with problems with her liver as a result of the b. cereus toxin. Apart from the moral argument, there's a practicality one of having that many people ill presumably away from decent toilet facilities... I would think food safety would be trained into most recruits as it can as easily incapacitate an army just as much as injury from gunfire. Not good practice from the guys in charge and shows a lack of respect for their troops IMO.

[Ken]

Jomy

Have seen the this sort of scenario before - an even bigger recipe for disaster.

I'm sure that the army do have food safety requirements but these are being lost along the network of subcontractors. One of the most difficult things for a catering company is to tell a client they cannot do something - usually fear of upsetting the customer and jeopardising future contractual relationships.

In my experience the trigger for change was a food poisoning outbreak which led to a critical look of the logistics of an operation followed by changes to make it safe.

A subsequent investigation may try to 'blame' the caterer - asking why the caterer did something which they knew to be unsafe. My advice to a caterer has always been to spell this out in very simple terms to their client, ensuring it is in writing. A difficult but necessary thing to do in order to protect the reputation of the caterer.

I am also aware of situations where the caterer has simply refused to implement changes on the basis that they cannot guarantee food safety - either way it all sounds easy on paper but in the world of large catering contracts tends to be more difficult in practice.

As professionals, we never like to say 'we told you so' but I think you can predict with some certainty that the present conditions will result in food poisoning cases.

I can relate to any frustration you may be having!

Ken

Edited by Ken, 17 February 2011 - 10:26 AM.

[Charles.C]

Dear Jomy Abraham,

Case below (classic text) is not quite same as present but illustrative of nature of the problem.

Fried rice containing large number of Bacillus cereus has been responsible for acute vomiting, sometimes followed by diarrhoea in people eating food prepared in take-away shops. The rapid onset of sickness, usually within 2-4 hrs of eating the food, suggests that a toxin is released in the food. B.cereus spores readily and grows well at a wide range of temperatures. The spores can withstand near-boiling temperatures, particularly when protected by starch. In order to be ready to provide meals at a moment’s notice, large quantities of rice may be boiled the day before they are required and may be heaped in large colanders and left overnight in the kitchen. Refrigeration coagulates the rice particles. Portions are turned over in hot fat (fried) in the morning and kept warm pending sale, when they are flipped through hot fat for a final process.

Laboratory tests have shown that spores are present in many samples of uncooked rice grains and that they can survive boiling and germinate into bacilli which grow rapidly in the cooked rice. Spores are readily formed in most vegetative cells so that the second process of heating in oil still leaves spores alive to germinate and form more sporing cells which are not disturbed by the final treatment in hot fat. The effect of heat on the toxin is not known but it is possible that it withstands some of the cooking procedure.

Only a revision in the method of preparation to cut out the hours of storage between and after cooking will prevent this type of food poisoning.

Rgds / Charles.C

[Jomy Abraham]

Thx Ken and Charles

Caterer have submitted my proposal to their clients formally. Now the caterer is Safe atleast...I am just worrying about their upcoming Third party survilence audit. Until the client change their requirement from hot to cold, the poor Caterer cannot convince the third party auditor...Any suggestion to protect the Caterer in this case?

Regards
Jomy Abraham

Dear Jomy Abraham,

Case below (classic text) is not quite same as present but illustrative of nature of the problem.


Rgds / Charles.C

[Jomy Abraham]

Ken/Charles

One more concern about ISO 22000 certification in restaurants...

Scope : Purchase, cook, serve/distribute of food in a kitchen.

In kitchen, they have fixed 65 Deg C as hot holding temerature and time limit of service is fixed as 2 hours. If the costomer purchases the hot meals in a disposable container ( for example, baked chicken), how can the system assure the food safety at Consumer point. If the customer eats the product after 6 hours, how can the restaurant assure the safety of food. if the resturant instructs the costomer to consume it within 2 hours ( just print the message in the payment bills, display poster etc), does the ISO 22000 system accept it?

Regards
Jomy Abraham

Thx Ken and Charles

Caterer have submitted my proposal to their clients formally. Now the caterer is Safe atleast...I am just worrying about their upcoming Third party survilence audit. Until the client change their requirement from hot to cold, the poor Caterer cannot convince the third party auditor...Any suggestion to protect the Caterer in this case?

Regards
Jomy Abraham

[Ken]

Jomy

Who is responsible for the distribution of the food? If it is your client, you could argue that they are responsible for the food once it leaves the caterers kitchen but you still have the issue of the food leaving the caterer at 30 centigrade - I don't have an answer for you!

Ken

[Ken]

Jomy


The system cannot assure the safety of the food at the consumer point once it leaves the caterers premises as it is the consumer and not the caterer who has control over the time before the food is eaten. Hence the end point of a haccp plan for a say a takeaway will be at the services stage and your ISO 22000 management system will be aimed at achieving this.

Ken

[Jomy Abraham]

thx ken

Most of the haccp/iso 22000 trainers/consultants use the concept "farm to fork/plate". this thought is wrong in the restaurants who directly distribute the hot meal boxes within the restaurants.

What precautions to be taken by the restaurants to avoid any legal cases, if the customers report any food poison cases?

Regards
Jomy Abraham

Jomy


The system cannot assure the safety of the food at the consumer point once it leaves the caterers premises as it is the consumer and not the caterer who has control over the time before the food is eaten. Hence the end point of a haccp plan for a say a takeaway will be at the services stage and your ISO 22000 management system will be aimed at achieving this.

Ken

[Charles.C]

What precautions to be taken by the restaurants to avoid any legal cases, if the customers report any food poison cases?

The BRC (British Retail Consortium) Global Standards for food were created to ensure supplier compliance and secure retailers' ability to guarantee the quality and safety of the food products that they sell.

++ for the restaurant

LINK BROKEN / DELETED/ch.c/09/05/16

(or ISO 22000 of course)

Rgds / Charles.C

PS - sorry, I forgot the good lawyer !